How to label your AW Aromatics White Label Products?

Creating your own line of cosmetic or other chemical products through AW Aromatics White Label is an exciting venture. As you prepare to launch your brand, one crucial aspect to consider is product labeling. Effective and compliant labeling not only helps attract customers but also ensures transparency and safety. In this guide, we will walk you through the process of labeling your AW Aromatics White Label cosmetic products.

Labeling Cosmetic Products

A cosmetic product is any substance or preparation that is used to enhance or alter the appearance of the body, particularly the face, skin, hair, or nails. These products are typically applied topically and include a wide range of items such as makeup, skincare products, hair care products, fragrances, and personal care products.

Common examples of cosmetic products include foundation, lipstick, eyeshadow, mascara, moisturizers, cleansers, shampoos, conditioners, perfumes, and deodorants. These products are typically available in various forms, such as creams, lotions, powders, gels, sprays, and sticks, to cater to different preferences and application methods. It's important to note that cosmetic products are different from pharmaceutical products, as they are not intended to diagnose, treat, or cure any medical conditions. Instead, they are primarily used for cosmetic purposes to enhance one's appearance and personal grooming.

Example of Cosmetic Product Label

Before designing your labels, it's crucial to familiarize yourself with the legal requirements for cosmetic product labeling in your target market. Laws and regulations may vary between countries or regions. Ensure your labels comply with the guidelines set forth by regulatory bodies such as the EU/UK Cosmetics Regulation (in the European Union), or local regulatory authorities.

Labeling Non Cosmetic Products or Other Chemicals

Non Cosmetics would be other items such as fragracnce and essential oils. Non cosmetics that could be hazardous or not. They could also be raw materials or mixtures.

Labeling non-cosmetic products such as fragrance oils, essential oils, and candles is important for providing essential information to consumers and ensuring compliance with regulatory requirements.

Here are some general guidelines for labeling these products for UK and EU:

Always check the specific labeling regulations and requirements of your country or region, as they can vary. It is essential to comply with all applicable regulations to ensure the safety and transparency of your products.

1. Product Identity
Name of the products and scent
2. Name, Address and Telephone Number of Manufacturer/Distributor/Reseller - 
This can be our company or yours if you obtain our CLP documents (usually downloadable from each product page) and be willing to provide these anyone who'd like to see them. Could be any selling platforms such are amazon, ebay or etsy etc.
3. CLP Information if relevant (Signal Word such as "❗️Warning", "⚠️ Danger", Hazard Statements, Pictograms) 
This is usually available on each product page to download. CLP labels are intended to be easily understandable and consistent across different hazardous substances and mixtures, helping users and consumers make informed decisions about handling, storage, and disposal of chemicals.

4. UFI Number if a hazardous Mixture
The UFI is part of the harmonized poison center notification requirements in the EU. The purpose of the UFI number is to provide a specific reference to a particular mixture, making it easier for poison centers to identify the exact formulation in case of emergencies or incidents involving hazardous substances. It helps ensure that the appropriate advice and guidance can be provided promptly. Provided on each single product page to download.

5. Nominal Quantity
It is important for the nominal quantity or volume of the fragrance oil to be stated on the bottle. The nominal quantity refers to the amount or volume of the product contained in the bottle. This information is typically provided in standard units such as milliliters (ml) or fluid ounces (fl oz).

Where to register a Cosmetic Product in the UK ( if you want to be RP for the product) 

In the UK, to sell cosmetic products, you must ensure that your products comply with the UK Cosmetics Regulation. A key part of this is designating a Responsible Person (RP), who is responsible for the product's safety, compliance, and registration. Here’s how it works:

Steps to Register a Cosmetic Product in the UK:

1. Responsible Person (RP) Designation:

   • Every cosmetic product sold in the UK must have a Responsible Person.
   • The RP can be the manufacturer, importer, distributor, or a third-party company authorized by the manufacturer.
   • The RP is responsible for ensuring the product's compliance with UK regulations, including safety assessments and labeling.

2. Notification to the UK Office for Product Safety and Standards (OPSS):

   • The RP must register the cosmetic product on the UK’s Cosmetic Product Notification Portal (UKCPNP).
   • The registration must include details such as product ingredients, labeling information, and a safety assessment.

3. Safety Assessment:

   • A cosmetic product safety report (CPSR) must be completed by a qualified safety assessor before placing the product on the market.

4. Product Labeling:

   • Labels must include mandatory information like the name and address of the RP, ingredient list, batch number, and warnings or usage instructions (if applicable).

UK Responsible Person Requirements:

• The RP must be established within the UK.
• They are accountable for compliance with cosmetic regulations, including keeping the Product Information File (PIF) readily accessible for authorities, which contains safety data and product details.

Where to register a cosmetic product in EU ( if you want to be RP for the product )

In the European Union (EU), to register a cosmetic product and act as the Responsible Person (RP), you need to follow the guidelines set out by the EU Cosmetics Regulation (EC) No 1223/2009 , . Here's the process:

1. Responsible Person (RP) Designation:To sell cosmetics in the EU, a legal entity (either a manufacturer, importer, or a third-party company) must be designated as the Responsible Person (RP). This person or entity is responsible for ensuring that the product complies with EU regulations.

2. Cosmetic Product Notification Portal (CPNP):All cosmetic products intended for sale in the EU must be notified through the Cosmetic Product Notification Portal (CPNP), an online platform. This is mandatory before the product is placed on the market.

   Steps to register:

   • Create an account on the EU Commission Authentication Service (ECAS).
   • Access the CPNP via your ECAS account.
   • Submit product details, including its formulation, intended use, and labeling information.
   • Upload the Product Information File (PIF) that contains safety data and other important information.

3. Product Information File (PIF):As the RP, you are responsible for keeping a Product Information File (PIF) for each product you place on the market. The PIF includes:

   • A detailed product description.
   • A Cosmetic Product Safety Report (CPSR).
   • Manufacturing method and Good Manufacturing Practice (GMP) compliance.
   • Proof of the product's effects, if applicable.
   • Labeling and packaging information.

4. Cosmetic Product Safety Report (CPSR):Before the product can be notified, it must undergo a safety assessment. A qualified safety assessor prepares the Cosmetic Product Safety Report (CPSR), which is part of the PIF.

5. Labeling and Claims:Ensure that the product labeling complies with the EU's cosmetic regulations, including ingredient lists and any claims you make about the product (e.g., "anti-aging" or "moisturizing").

6. Compliance with EU Cosmetics Regulation (EC) No 1223/2009:As the RP, you must ensure that the product complies with all aspects of the regulation, including banned substances, permitted ingredients, and labeling requirements.

In summary, to be the RP for a cosmetic product in the EU, you must:

1. Register the product through the CPNP.
2. Maintain a Product Information File (PIF).
3. Ensure the product meets all EU regulatory requirements under EC No 1223/2009.

If you are unfamiliar with the process, some companies specialize in acting as the RP or assisting with compliance.

Cosmetic Product Safety Report (CPSR)

To legally sell cosmetic products in the UK, the Cosmetic Product Safety Report (CPSR) is a mandatory requirement. It certifies that your product is safe for human health when used under normal or reasonably foreseeable conditions.

Here’s how to obtain a CPSR for your cosmetic products:

Steps to Obtain a CPSR:

1. Engage a Qualified Safety Assessor:

   • The CPSR must be conducted by a qualified professional, such as a toxicologist, cosmetic chemist, or another expert with relevant qualifications and experience.
   • You can hire a cosmetic safety assessor from specialist companies or freelance consultants who provide safety assessments.

2. Prepare the Necessary Information for the Assessor: The safety assessor will require the following information to prepare the CPSR:

   • Full Product Formula: The complete list of ingredients, including percentages and any raw material safety data sheets (SDS).
   • Product Specifications: Information on how the product is made, including pH, viscosity, and microbiological stability.
   • Raw Material Documentation: Safety Data Sheets (SDS) for each ingredient from suppliers.
   • Packaging Information: Details of the packaging material, which should be compatible with the product.
   • Intended Use and Warnings: Clear information on how the product should be used and any precautionary statements.
   • Label Information: Complete labeling, including the Responsible Person’s details, batch code, and ingredients.

3. Product Testing (if applicable):

   • You may need to conduct certain tests, such as microbiological tests, preservative efficacy tests, or stability testing, especially for water-based products.
   • The safety assessor may recommend these tests if the product type or formulation requires them.

4. Receive the CPSR:

   • Once the safety assessor has reviewed all the data, they will issue the CPSR, which consists of two parts:
     1. Part A: Cosmetic Product Safety Information – This includes detailed information about the product's composition, use, and exposure to the skin.
     2. Part B: Cosmetic Product Safety Assessment – The safety assessor's conclusion on whether the product is safe under normal or foreseeable use.

5. Keep the CPSR on File:

   • The CPSR must be included in the Product Information File (PIF) and kept readily accessible for authorities. The RP is responsible for ensuring this is available at all times.

Where to Find Safety Assessors:

• Consultancy Companies: Some companies specialize in cosmetic regulatory compliance and safety assessments, such as Formula Botanica, Cosmetic Safety Assessments, or Delphic HSE.
• Freelance Cosmetic Chemists and Toxicologists: Many professionals offer their services independently.
• Online Platforms: Some websites allow you to find cosmetic safety assessors globally, such as on professional freelancer websites like Upwork or cosmetic regulation-focused platforms.