Thistles & Sticks Blog

It’s not as simple as just selling soap!

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When I first thought about my new adventure selling soap, it seemed so simple… make the product, post it on social media/website, sell it. But wait, there’s more!

Several years ago, I made a sampling of my soaps, which I was very proud of and took to an acquaintance selling food products. Her comment was “Wow. They look great, but it’s almost harder to sell beauty products than food!” I stopped in my tracks thinking how can that be. It’s soap!

I spent the next few weeks finding out the actual protocol for selling soaps and beauty products in Canada and to say it’s not that simple is an understatement! Going through this lengthy, mostly confusing process I can see why most sellers wouldn’t give this a second thought. There are so many `cottage’ industries selling at local markets and fairs, after all, it’s “local” or only a ‘small business”.

The reality is we do need to have some regulations and accountability for selling such products. I’d like to think that the handcrafted products I am purchasing to eat or for my body have followed some guidelines from the making, handling to the selling. Just a quick look at the label tells me if the guidelines are being followed. It’s surprising how many are not.

My first inquiry being a`Soaper’ was searching to find out if there was a soap guild, just like a quilting guild and the like. I found our Canadian guild – Handcrafted Bath & Bomb Guild at website@hbbg.ca. I asked if I could take a workshop on soap making to give me the credentials that I thought I needed and the answer was “No’. My search then shifted to finding out “Do You Need a license to sell soap in Canada?”

Although not technically a license, if you make soap in Canada and intend on selling it, you need to first register with Health Canada.

You will also have to comply with the Canadian Food and Drug Act and other guidelines for cosmetics (including soap) on the Health Canada website. Everything from the making of the product to the labelling is very specific to Health Canada and its’ specific department – Food and Drug Act and Cosmetic Regulations.

To sell soap, each recipe must be filed with Health Canada using a CNF form. This discloses the ingredients in the products and within a range of how much is used. It is not an easy form to file but when it’s done, there is certainly a sense of accomplishment and a clear conscience knowing it’s been done. All recipes must be filed within 10 days of selling each product. If you change anything in that particular product, then an amendment must be filled.

All ingredients must be disclosed using the INCI protocol. INCI names (International Nomenclature Cosmetic Ingredient) are systematic names internationally recognized to identify cosmetic ingredients. In Canada, we have to show french on our labels. INCI names are internationally recognized so there is no need to display both french and INCI names. The following is just an example of the regulations:

Regulatory information for cosmetics – All cosmetics sold in Canada must be safe to use and must not pose any health risk. They must meet the requirements of the Food and Drugs Act and the Cosmetic Regulations.

Cosmetics legislation – Under the Food and Drugs Act, a cosmetic includes “any substance or mixture of substances, manufactured, sold or represented for use in cleansing, improving or altering the complexion, skin, hair or teeth and includes deodorants and perfumes.” This includes:

  • cosmetics used by professional esthetic services
  • bulk institutional products such as hand soap in school restrooms
  • “handmade” cosmetics sold through home-based businesses or craft sales

The Cosmetic Regulations and the Food and Drugs Act require that cosmetics sold in Canada are manufactured, prepared, preserved, packed and stored under sanitary conditions. The manufacturer and importer must:

  • provide a list of the product’s ingredients
  • notify Health Canada that they are selling the product

All cosmetics must also follow the requirements outlined in the Consumer Packaging and Labelling Act and its associated Regulations. Any chemicals found in cosmetics may be subject to the Canadian Environmental Protection Act.

My advice to anyone getting into this type of business is to make sure you are selling under the above guidelines. To have insurance – another hefty cost, all products being sold must have been filed with Health Canada the CNF. Without this filing, you will not be able to get insurance. It only takes one incident to change your future forever.

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