Selling Handmade Cosmetics and Bath Products

What counts as a cosmetic product?

Under UK law (retained EU Regulation 1223/2009), a cosmetic product is any substance or mixture intended to be placed in contact with the external parts of the human body with a view to cleaning, perfuming, changing appearance, protecting, or keeping them in good condition.

This includes:

• Bath bombs and bath salts
• Handmade soaps (bar soap, liquid soap)
• Lip balms and lip scrubs
• Body lotions, creams, and butters
• Face masks, serums, and moisturisers
• Scrubs and exfoliants
• Shampoo and conditioner
• Deodorants
• Perfumes and body sprays

If it goes on the body and is not a medicine, it is almost certainly a cosmetic. The regulations apply whether you sell at a craft fair, online, or from your front room.

Cosmetic Product Safety Reports (CPSRs)

A CPSR is a formal safety assessment of your product, signed by a qualified safety assessor — typically a toxicologist, pharmacist, or cosmetic chemist. It evaluates the ingredients, concentrations, and intended use to confirm the product is safe.

Key facts about CPSRs:

• Every unique formulation needs its own CPSR. If you make lavender bath bombs and rose bath bombs with different fragrance oils, each needs a separate assessment.
• Changing any ingredient — even swapping one fragrance oil for another — means a new CPSR for that variant.
• Typical costs range from approximately £50 to £150 per formulation from specialist providers. Some providers offer "flexi" assessments where you follow a pre-approved recipe, which can reduce costs.
• The assessor needs to see your full recipe (every ingredient, exact quantities), your manufacturing process, and your ingredient safety data sheets.
• You cannot write your own CPSR — it must be done by a qualified assessor.

The CPSR is not optional. Selling bath bombs or handmade soap at a craft fair without one is illegal, regardless of batch size.

The Product Information File (PIF)

Every cosmetic product must have a Product Information File containing:

• A detailed product description.
• The full ingredient list with quantities.
• The CPSR signed by your assessor.
• A description of your manufacturing method — this should be compliant with Good Manufacturing Practice (GMP).
• Packaging and labelling information.

The PIF must be kept by the Responsible Person (see below) and made available to Trading Standards on request. You do not need to submit it anywhere — just keep it on file. A well-organised folder on your computer is fine.

The PIF is your proof of compliance. If Trading Standards visit your stall or contact you, being able to produce your PIF quickly demonstrates you are operating properly.

The Responsible Person

Every cosmetic product on the UK market must have a designated Responsible Person. For small makers, this is usually you — the person who makes and sells the products.

The Responsible Person must:

• Ensure the product has a valid CPSR before it goes on sale.
• Maintain the Product Information File.
• Ensure the product is correctly labelled.
• Notify the OPSS (see below) before the product is placed on the market.
• Report any serious undesirable effects to the OPSS.

Your name and address as the Responsible Person must appear on the product label.

Notifying the OPSS

Before placing a cosmetic product on the UK market, the Responsible Person must notify the Office for Product Safety and Standards (OPSS) via the Submit Cosmetic Product Notifications (SCPN) portal.

This notification tells the authorities what you are selling. It is not an approval process — you do not need permission to sell. You are simply informing the OPSS that the product exists and providing basic information about it.

The notification is separate from the CPSR. You need both: a CPSR to prove safety, and notification to inform the authorities.

The SCPN portal is free to use. You will need to provide the product name, category, ingredients, and the Responsible Person's details.

Labelling requirements

Every cosmetic product sold in the UK must carry a label showing:

• The product name.
• The ingredients list — using INCI (International Nomenclature of Cosmetic Ingredients) nomenclature, listed in descending order of weight.
• The net weight or volume.
• The name and address of the Responsible Person.
• A batch number or production reference.
• The "period after opening" symbol (the open jar icon with a number of months) or, if the product has a shelf life of less than 30 months, a "best before" date.
• The function of the product, if not obvious from its name.
• Any warnings or precautions for use.

The 26 recognised fragrance allergens must be individually declared on the label if they are present above specified thresholds (0.001% in leave-on products, 0.01% in rinse-off products). Many fragrance oils and essential oils contain these allergens — check your supplier's safety data sheets.

Labels must be legible and durable. Printed labels are recommended — handwritten labels, while not explicitly banned, look unprofessional and are harder to keep accurate.

Common mistakes and enforcement

The most common compliance failures among new cosmetics sellers:

• Selling without a CPSR — by far the most frequent and most serious issue.
• Missing or incomplete ingredient lists on labels.
• Not using INCI nomenclature — writing "coconut oil" instead of "Cocos Nucifera Oil".
• Not declaring fragrance allergens.
• Not notifying the OPSS before selling.
• Making medicinal claims — saying your product "treats eczema" or "heals skin conditions" turns it from a cosmetic into a medicine, which triggers an entirely different (and much stricter) regulatory framework.

Trading Standards officers can and do inspect stallholders at craft fairs. Non-compliance can result in informal warnings, formal improvement notices, product seizure, or prosecution in serious cases.

The regulations exist to protect consumers. A badly formulated cosmetic product can cause serious skin reactions, chemical burns, or allergic reactions. Taking the time to get a proper CPSR and label your products correctly is not just a legal requirement — it protects your customers and your reputation.