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cosmetic notification form

Cosmetic Notification Forms (CNF) – Part Two

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Wow, this month is flying by! I apologize for the delay in getting Part Two of this series on CNF published, especially since I know it is on the mind of so many of you these days.

In the first part of this series we talked about what a CNF is, and when you would need to file one. If you missed it, you can find it here. Today I’m going to talk a little bit about completing the actual filing process. A blog is not a good forum to actually walk through completing a form step by step, so I’m going to answer Frequently Answered Questions in this post.

The first thing to know is that there is no fee for filing a CNF with Health Canada.

Secondly, when you sit down to file your first one, it’s going to look really confusing; don’t panic, it’s really not that bad.

To file a CNF you will need to go to this link for English, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-eng.php, or this link for French, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-fra.php. Before you start actually filling out the form, I would suggest that you either print or download into another window the Guide to Filing Cosmetic Notification Forms, which is found here in English, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/guide-eng.php, and here in French, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/guide-fra.php.  This Guide will walk you through the steps to completing a CNF, and should make the process relatively painless, but if there continues to be confusion surrounding the process, let us know and we can put together a step by step tutorial. 

Questions:

1) Am I the Notifier, the Manufacturer or the Distributor?

The answer to this is sometimes you’re all 3! It depends on how you sell your product. If you are making product and selling it directly to the public, you are the Notifier (the company that is filing the form), the Manufacturer (the company that is making the product) and the Distributor (the company that is selling the product).

If you are selling product to stores at wholesale prices and they are selling to the public, you are the Notifier and the Manufacturer, and the store(s) would be listed as the Distributor. This also applies if you are making products for Private Label customers. You would have to file 1 CNF for your direct sales to the public, then file a separate CNF for each retailer or Private Label customer that sells your product.

2) What is a Notifier’s Reference and do I have to have one?

This is a description you use to identify a product for your own use. If you make Lavender Soap, you might use that description on your website, but for selling you may have an SKU identifier, such as SPLAV or maybe a number that identifies it on your system. You don’t have to enter this on the CNF form unless you want to.

3) Do I have to file a separate CNF for each different fragrance of a product?

If the manufacturer, distributor, function, and form of the cosmetic are the same for all the variations of the product, and the base ingredients remain the same, you can file one CNF and add all of the variations in colour, fragrance, or flavour by using the “May Contain” option. If you sell wholesale and/or Private Label as well, you would have to file 1 CNF for your direct sales to the public, and a separate CNF for each store or Private Label customer that sells your product.

4)  Do I list the exact percentage of that I use of each ingredient?

No. The reason for listing the ingredients is so that Health Canada can confirm you are not using ingredients that are prohibited from use in cosmetics, or if they are permitted but restricted, you are using a safe percentage. They do not need to know what your exact recipe is. If you use 20% shea butter in your lotion, you can use any range that contains your 20%. For instance, LL (Lower Limit, or the minimum that you would use) of 10% and UL (Upper Limit, or the maximum that you would use) of 40%. As long as your recipe stays within the ranges you list for each ingredient, you won’t have to file an amendment if you adjust your recipe slightly because you were short on shea butter and added a little more cocoa butter instead. NOTE: that only applies if all of the ingredients remain the same, and the amount you use falls within the range you have listed on your CNF. You cannot substitute ingredients without filing a new CNF.

5)  I only use fragrance oils in my products; how do I fill out the CNF for that?

If you make a product where the base is always the same, but you use multiple different fragrance oils, you file one CNF and you list your fragrance oils as “Parfum”. If you make some with fragrance oils and some with essential oils, you can still file one CNF, but use the “May Contain” option to list all of the options, including one for ‘Parfum”, and one for each different essential oil.

6)  When I’m listing my ingredients for soap, do I list what goes into the pot, or what comes out of the pot?

The definition of ingredients for the purpose of filing a CNF “excludes ingredients consumed during the manufacturing process”. Since lye is used up during the soapmaking process, the proper way to list the ingredients is by using the INCI for the soap that is produced. For instance, saponified olive oil is sodium olivate, saponified coconut oil is sodium cocoate, etc. You can find an INCI listing in the Files of our Facebook group Soapz and Stuffs.

NOTE: Although glycerine is created during the soapmaking process, you do not add it to your ingredients. The definition of ingredients for the CNF is “any substance or component that is deliberately added to the formulation.” Glycerine is created during the process, not added. Please note that you DO need to add it to your label. 

7) Ok, I’ve got my number now what?

Once you’ve filed your CNF, you may receive an email or telephone call asking you to change or clarify some information. If you don’t receive any questions, at some point you will receive an email or letter containing your Cosmetic Number. File it away in a safe place. If you change your recipe, or discontinue selling the product, you will need that number to file an amendment to your CNF. You will also need to have it to show to Health Canada inspectors who may show up at a market where you’re selling, or may find you online.

8) I’ve changed my recipe, now what?

Anytime you make a change to your recipe that increases or decreases an ingredient so that it no longer falls within the range listed on the approved CNF, you will need to file an amendment. You will also need to file an amendment if you make an existing product but use a new essential oil. You don’t need to file an amendment to add a new fragrance oil or flavouring, because the generic “parfum” and “flavour” used on your original CNF will still apply.

Okay, those are the FAQs that we see most often. If any of these answers are unclear, or you have other questions, please feel free to leave a comment below, and I will answer as quickly as possible. You can also post a question in our Facebook group, as we have many people there who are experienced in filing CNFs and would be happy to help.

cosmetic notification form

Cosmetic Notification Form (CNF) : Part One.

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imageIf you are new to the handcrafted bath and body industry in Canada, you may be wondering what all the fuss is about the Cosmetic Notification Form (CNF). I started to write a short post about CNFs, which quickly turned into an encyclopedia, so I have turned it into a two or three part series. Up first, what is a CNF and why do I need one?

Health Canada requires that anyone who sells a cosmetic product in Canada must file a CNF with them within 10 days of first making the product available for sale. Anyone means everyone, from the big name sellers such as L’Oreal or Lush, all the way to your neighbour who sells a few bars to family and friends just to help cover the cost of her raw materials: no exceptions. Aside from reviewing the ingredients in your product to confirm that all of your ingredients are approved for use in cosmetics, the CNF also provides Health Canada with your contact information, which will be used in the event that your product causes an allergic reaction or other issue that is reported to them. They will contact you and ask you to recall the product.

To get you started, here are some commonly asked questions about filing a CNF:

  1. Is my product a cosmetic? Health Canada defines a cosmetic as “”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 bath bombs, bath salts etc.
  2. What is not considered a cosmetic? If you make any claims that your product has any therapeutic or healing effect, it is no longer a cosmetic. For example, claims that your dandelion balm treats eczema, or that your tea tree oil mask clears up acne will result in your product being regarded as a drug or Natural Health Product, which requires testing and approval. Some products, such as bug spray or sunscreen are automatically excluded from the cosmetics category even if you make no claims about them. Sunscreen is considered a drug, and bug spray is a pesticide, and they must conform to much stricter regulations. Sale of handmade sunscreen is prohibited in Canada, and sale of handmade bug spray is currently under review.
  3. If I file a CNF, can I say that my recipe is approved by Health Canada? No. The only things that are screened by Health Canada when you file a CNF is that the ingredients you are using have been approved for use in cosmetics, and that you are not exceeding the maximum usage rate of any ones that are restricted. 
  4. What happens if I sell product and don’t file a CNF? That depends on how and where you sell your product. If you are that person who is just selling to family and friends, your chances of getting “caught” are pretty slim. However, there is always the chance that your product may cause an allergic reaction in someone, and it may get reported to Health Canada. Fines for non-compliance range from $1,000 to $25,000 per offence. Now you may think, “my friends would never do that to me”, but imagine if your product caused a reaction in their young child? Or, what happens if your friend buys soap from you and gives it as a gift to someone you don’t know? Still feel confident? It is always better to be in full compliance with all regulations. There is no fee to file a CNF. If you sell your products online, in stores, or at a market, your chances of being found non-compliant are increasing every week. Health Canada has staff reviewing websites and attending markets, and you could find yourself under scrutiny at any time.
  5. Okay, I’ve filed my CNF…now what? Once you’ve filed your CNF, one of two things will happen. You may receive an email or phone call from Health Canada indicating a problem with your submission. Respond to their inquiry, and work out the problem. If you aren’t contacted, then at some point you will receive a notice that your CNF has been approved and they will provide you with a number. Keep that number in a safe place. If you ever change the product you will need that number to file an amended CNF. More importantly, this is your proof of compliance which you can show to a Health Canada inspector if one shows up at your market, or contacts you by email requesting to see your CNF.

In Part 2 of this series, we will take a closer look at the actual filing process.  In the meantime, if you have any questions about the CNF, come join our Facebook group, Soapz and Stuffs and post a question. The group is open to everyone, not just HBBG members, and someone is always around to help.

 

All About Preservatives

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imageI think every handcrafted bath & body person out there probably starts their journey down the lotion making path by creating a beautiful, whipped body butter. Some people stop there, while others start thinking about how they could tweak this product to be less greasy, more moisturizing, silkier, drier….and so on, and so on… If that’s what you’re thinking about, then eventually you are going to run up against the reality that emulsified lotions, body butters, etc. contain water, the breeding ground for bacteria, mold, and fungus, and your journey into the wonderful world of preservatives has begun.

Before we start talking about preservatives, let’s look at what isn’t a preservative:

Grapefruit seed extract (GSE), rosemary oil extract (ROE), tocopherol (Vitamin E) are not preservatives, they are anti-oxidants, which can help prolong the shelf life of your carrier oils by slowing rancidity. They have no effect on mold, fungus, or bacteria.

Honey has no measurable preservative effect on anything other than itself. Although amphoras of honey have been found in edible condition after hundreds of years, as soon as the container is opened and moisture introduced, it begins to deteriorate.

Glycerin is a sugar alcohol which can act as a preservative, but must be used at greater than 50% to be effective. Ethyl alcohol is another option, but again it must be used at a rate that would be unpleasant in most products, greater than 20%.

Okay, moving on to synthetic preservatives, there are a multitude available. The ideal preservative is a broad spectrum one that protects against gram positive bacteria, gram negative bacteria, mold, and fungus. There are many excellent options to choose from that will protect your product for up to 3 years, including the powerful parabens, which will stop anything in its tracks, but have been the subject of much negative publicity over the past few years.

On the other end of the scale are the natural preservatives, such as fermented radish root, benzoin, and potassium sorbate. Most of the natural preservatives are effective against one or more of the bacteria/mold/fungus trio, but the challenge for cosmetic chemists is to find one that is effective against all three. 

Outlining all of the options for preservatives would turn this post into an encyclopedia, and the subject has been covered in detail by far more experienced people than me, so instead of giving snippets of information, I’m going to point you to the best practical, readable resources I’ve found.

Point of Interest is fantastic blog written by Canada’s own, Susan Barclay-Nicholls. Whether you’re just beginning your journey into handcrafted lotion, shampoo etc., or you have years of work under your belt, pour yourself a cup of coffee and get comfortable. Susan’s blog is full of valuable information on not just preservatives, but absolutely everything from raw ingredients to processes and preservatives and more.

The most comprehensive and approachable study of preservatives that I’ve found is Reviews of 27 Preservatives found on the Making Skincare website. This study also isolates Ecocert approved preservatives. 

Both of these sources are also very responsive to questions…

Although you will encounter very strong opinions on preservatives, the final decision is yours and you need to make the one that feels right to you, for yourself and your customers, whether they are paying ones or family and friends. 

 

 

Welcome Voyageur!

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voyageursmThe Handcrafted Bath & Body Guild is excited to welcome Voyageur Soap & Candle to our list of Vendor Members! 

Located in Surrey, BC, Voyageur is Canada’s premier supplier for Soap Making Supplies, Cosmetic Packaging, as well as thousands of ingredients for your Aromatherapy, Mineral Makeup and Skin Care products.

Handcrafted Bath & Body Guild Members receive an additional 5% discount on top of their Customer Reward Discount, for a total discount of 10%. Visit them today at www.voyageursoapandcandle.com.

Not a member yet? Visit www.hbbg.ca now and take advantage of our Special Offer….a 30 day free trial plus a discount off your first year Membership.

Welcome yellowbee!

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imageThe Handcrafted Bath & Body Guild is very happy to welcome yellowbee as a Vendor Member! Guild Members get a 5% discount on purchases. Not a member yet? Subscribe now.

yellowbee is a young and energetic company, based in Calgary. They are putting together a choice lineup of packaging solutions, many of which have not been available in Canada until now.

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Check out their EcoFriendly clamshells, available in April

 

 

 

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Black or White Plastic Tubs in 3 sizes. 

 

 

 

 

Or maybe a Soap Stamp?                                      image

Visit their website at http://www.yellowbee.ca 

Why Start a Non-Profit Corporation?

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  When we started discussing forming a new Canadian Guild, there was really no question in our minds that a federal Non-Profit corporation was the only viable option.

Let’s look at why:

– Since none of the volunteers that form the Board profit from the association, every penny of the Membership fees collected goes towards programs and activities that benefit the Membership;

– under the Canada Not-For-Profit Corporations Act, Annual Reports must be filed with Corporations Canada each year, and made available to the Members of the Non-Profit, which means you get to see exactly how your Membership fees are spent ;

– an Annual General Meeting of the Members must be held every year, and every Professional Member has the right to ask for a resolution to be presented to the Meeting, including nominating a Director to fill a position which is coming up for renewal at the next Meeting;

– every active Professional Member has the right to vote on any resolutions presented at the Annual General Meeting;

Once we chose to be a Non-Profit corporation, the next decision was whether it should be provincial or Federal. Again, there was really only one choice we could make. Our membership is spread from coast to coast. A Canadian Non-Profit Guild is the only structure that makes sense.

To summarize, a Non-Profit corporation makes sense to us because it provides transparency and a voice to its’ Members.

(Please note: The complete ByLaws for the Handcrafted Bath & Body Guild can be found online at our website.)

Welcome Baraka!

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logoThe Handcrafted Bath & Body Guild is very happy to welcome Baraka Supplies as a Vendor Member.

Baraka Supplies imports Shea Butter directly from Ghana. It is Certified Organic and Fair Trade, and every purchase directly benefits women, children and families in northern Ghana. Visit their website at http://www.barakasupplies.com for more information.

Handcrafted Bath & Body Guild Members receive a 10% discount off every order from Baraka Supplies. Visit our website to become a Member today, and check out our other Member Benefits while you’re there, like a free listing in our Business Directory!

Who We Are

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guild

 

guild
ɡild/
noun
– a medieval association of craftsmen or merchants, often having considerable power.
– an association of people for mutual aid or the pursuit of a common goal.

As we launch our new Guild, we face the challenge of defining who we are, and what is our purpose or vision. So this first blog post will attempt to outline some of our thoughts on this subject.

Who We Are

Support & Education

The handcrafted soap and toiletries industry has exploded over the past few years, and shows no sign of slowing down. Most of us started making our own products because we were looking for more natural alternatives to commercial products, either because of a desire to make healthier choices, or because of troublesome skin conditions or allergies. When this “natural is better” movement began, we were all stumbling around in the dark, because sources of accurate information were hard to come by. With the advent of the Internet, information has exploded, but ironically, accuracy is even harder to come by.

As soon as companies realized that a whole new audience was available to them, at a fraction of the cost of traditional print and television advertising, the avalanche of misinformation began. The approach? Tell them whatever is required to make them open their wallets. Unfortunately this misinformation gets spread so widely across the Internet, from blog to blog, that finding accurate information in Google search results is next to impossible. Examples? Try doing a search for natural sunscreens and insect repellents, or essential oils, and see what you find.

Another contributor to the wealth of misinformation on the Internet is the DIY movement. We all started as DIYers, and we are very supportive of anyone who wants to jump in and try it for themselves. Unfortunately many of the DIY recipes on the Internet are disasters waiting to happen. No, grating up a bar of soap and mixing it with water or aloe or hydrosols does not make liquid soap….it makes a runny, slimy impersonation of liquid soap. Melting grated lipstick with Vaseline is not going to give you the quality handcrafted lip gloss or balm that you’re looking for. Grapefruit seed extract is not a natural preservative. The misinformation is endless, and everyday it gets spread further and further.

So, one of the aims of our Guild is to encourage our members to share accurate information about the amazing ingredients and techniques that we use everyday, so that experienced crafters can continue to grow, and newcomers can benefit from the experience of those who have learned the hard way.

Our longer range plans include member conferences and core technique courses/certificates, which will be added on as our membership grows.

So how do we share this information? For our Members, we have a password protected site that will soon contain a variety of proprietary tools and resources, such as a searchable INCI Database in English and French, an interactive map of all suppliers in North America, with direct links to their websites, Fragrance Calculator worksheet to help you figure out exactly how much fragrance to add to your product, and…and….well you get the picture. Something you’d like to see added? Let us know.

Professional Members will be featured in our Business Directory, allowing customers to locate you by Province or City.

We also have a Members Only Forum, where you can start or join discussions on any subject pertaining to the handcrafted bath & body experience. We’ll get you started by setting up some Boards, but feel free to suggest any new ones that you’d like to see.

Wait, what about Discounts?

Who doesn’t love a good discount? Even if you join the Guild just for the vendor discounts, you’ll cover the cost of your membership in the amount you save buying supplies from our Vendor Members over the course of the year. However, when you see the list of our Vendor Members, you aren’t just seeing potential discounts, you’re seeing Vendors that are used by our Members on a daily basis. We have made a commitment to continually search for solutions to our Members problems, so if you’re having trouble sourcing an ingredient or packaging solution, ask the Membership or ask us….we’ll get on it! Have a favourite vendor that isn’t currently a Member? Send them an email and ask them to join, or send us an email suggesting that we add them, or both.

We are only a week old, so our Vendor Member list is short, but we are actively communicating with many Vendors, some old faces and some you may not be familiar with, so check back often for additions.

Who We Aren’t….

We aren’t the Bath & Body police 🙂

The Guild is here to help and support you;  to brainstorm and share ideas with people facing the same challenges as you are. Hopefully you’ll find solutions here, but we will never tell you how to run your business, or what you should think and feel about any issue.

We aren’t all “natural”…..for a couple of reasons:

a) in Canada, there is no legal definition of “natural” as it pertains to cosmetics, and

b) not everyone has the same goal in mind when they handcraft bath & body products. Some want to eliminate all synthetically produced ingredients from their products, while others are okay with adding safe synthetics, they just want to be able to make an amazing product that they can afford.

So, that’s us in a nutshell. Sorry this was a little bit long, we promise to keep them shorter in the future. If you’re interested in becoming a member, drop into our website and take advantage of our 30 day free trial membership. If you’re not quite ready to join us, come visit us in our Facebook group, Soapz and Stuffs, for lively, informative discussions on all things handcrafted bath & body…we’d love to see you there!