No, in general you will only need a licence if your beard oils are sold as medicines or suggest they are by making medicinal claims on labels, promotional material or websites, in which case you will need either a Product Authorisation under the UK Medicines Act or a Traditional Herbal Registration under the Traditional Herbal Medicinal Products Directive.
However, if you manufacture your beard oil, your premises may be subject to notification under the Cosmetic Regulations or licensing by your local authority. But there is no legal requirement to be an aromatherapist or to sell essential oils like beard oil or make aromatherapy products containing them.
Have it in mind that you can legally sell your beard oil in the UK, but you cannot make medicinal claims for them and you will have to identify which of the several sets of legislation your products have to comply with and then develop, manufacture, label and market them to comply with that legislation.
To start selling your beard oil, you will have to decide if you are going to develop and make the products yourself, commission someone else to make them or sell other peoples products as a distributor or retailer. Then you will have to identify the legislation that relates to your products and then make a business plan to ensure that you understand how much it will cost to develop, manufacture, package and/or sell your products.
Although there is no single piece of legislation that applies to the manufacture and sale of essential oils like beard oil and aromatherapy products containing them, there are other pieces of consumer protection legislation that might apply to these products. They include the General Products Safety Regulations and the Cosmetic Products safety Regulations. The specific regulations that apply to your beard oils will depend on the ingredients and can be difficult to identify.
Howbeit, in addition to the wording specified by the General Product Safety Regulations, weights and measures and any other regulations relevant to your product, it is good practice to have the common name and full botanical name of the beard oil (or product name if a mixture), directions for use, contraindications where applicable and specific warnings like do not take internally and keep away from children together with a batch number and use by date.
Also note that it is good practice to follow the labelling requirements specified by the Medicines Act or the Traditional Herbal Medicinal Products Directive and include the name of the product and a list of active ingredients, the name of the client the product is provided to, your name and address, instructions for use and any contraindications and/specific or general warnings like do not take internally.
Things to Know Before Selling Beard Oil in the UK
Product safety is imperative when selling homemade cosmetics in the UK or anywhere else. Your reputation depends upon it, get it right and you’ll get repeat customers and grow your business. And most importantly it’s the law.
Know your ingredients
Before selling things like beard oil in the UK you want to make sure you know your product inside out. What are the true ingredients? Ingredients can be hidden behind terms like ‘concentrate’ or ‘scent’. Colourings, fragrances and essential oils are composed of many chemicals – some of those allergenic. Therefore, to be sure you fully understand your product’s composition request from your supplier accurate and detailed information on INCI names, CAS numbers and allergens.
Note that you want this information explicitly stated out so draw up your formulation in a table listing ingredients down left hand side and quantities on the right, including CAS or EC number in the middle. You can go further and include a forth column with the function of the chemical – diluents, fragrance, colouring etc.
Product Safety Report
Note that one most important part of selling things like beard oil in the UK is the cosmetic safety assessment – also known as a CPSR. By going through the CPSR process, you will more or less find out if your product is safe to market and in compliance with the UK cosmetic regulations.
First step is to contact your suppliers and request 1) Safety Data Sheets also known as Material Safety Data Sheets 2) Certificates of analysis – or ‘CoA’ and 3) allergen information (Allergen Declaration List). Get these together with you formulation, get a Product Information File, and make a submission through the CPNP
Microbiological testing and stability lab testing requirements
Essential oils like beard oil can deteriorate over time due to microbial growth or changes in chemical and physical properties. Note that this is why it is necessary to arrange microbial and stability (packaging compatibility) lab testing.
This involves sending a sample to a specialist lab for testing. It can take time – you may have to wait several months for the results. But when the results are in you know your product can be safely marketed for a reasonable period of time after it has been manufactured.
Have it in mind that not all products require microbiological testing. Products that contain mostly oils or glycol (propylene glycol) may not require microbiological testing. This is because the properties of oil and glycols do not support microbial growth. Water-based cosmetics are likely to require testing because the water provides the microbes nutrients to grow.
Marketing claims on product label
You will have to think extensively about your labelling – what do you want to say about your product? What marketing claims do you want to make? Try to avoid claims like ‘relieve’, ‘restore’ and ‘replenish’ because claims with these terms tend to fall foul of the cosmetic regulation. Remember that beard oil is for external use and generally for soothing or perfuming beards rather than for healing or relieving anything.
- Brexit and the changing regulatory landscape in the UK: UK regulation is derived from EU regulation but as we all know, the UK has now officially left the EU. So what does that mean? Submission to the CPNP is still required for UK cosmetics. However, notification to a new UK-only portal is on the horizon.
- Animal Testing: Animal testing is prohibited for cosmetic products and their ingredients.
- Good Manufacturing Practice or ‘GMP’: In the manufacturing of your beard oil, adopt Good Manufacturing Practices to ensure high quality of product. Benefits include longer shelf lives, less wastage and safer products.
In the UK, you will only need a license if your beard oils are sold as medicines or suggest they are by making medicinal claims on labels, promotional material or websites, in which case you will need either a Product Authorisation under the UK Medicines Act or a Traditional Herbal Registration under the Traditional Herbal Medicinal Products Directive.
In addition, when disposing your beard oil, contact your local Hazardous Waste disposal contractor, see local telephone or trade directory or search online for contact details, and follow their instructions. Beard oil in bulk are considered to be hazardous waste and may be flammable.
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