Saturday, 21 February 2015

License and Registration Please



This blog is not a place of controversy, I do not generally write about the hard topics that tend to, at times, divide the green community, and I do not really talk much about the green community at all here. There are different types of green bloggers, we are driven by different passions and tend to concentrate on what is important to us. Some people are just starting their journey, and you can follow their progress and learn as they learn, others have an extensive knowledge of the industry, and there are even some who have backgrounds in science, that gives them a greater insight into ingredients. This space has always been reserved for straight up reviews, without trying to preach the wonder of organic/natural (at least I hope there was no preaching), because chances are if you ended up here, you already know that. I also wanted it to be about the products that are great in their own right, who wants to use a mascara that is acceptable for a "natural" mascara? I want a brilliant mascara as good as any, that happens to also be natural. This has been my goal, to share amazing beauty products and some other things, like fashion and holiday destinations to keep things varied.

Let Me Introduce Myself.

I have always been fascinated by beauty products, when I was a kid, going through my aunt's vanity table was one of my favourite things. I tried to make my own cream and rosewater when I was 8, by mixing my moms preexisting creams with some apricot shampoo, to make it smell nice, and putting rose petals in a bottle filled with cold water, then shaking really hard (clearly I had a lot to learn). When I was a teen I was more interested in makeup than skincare, I had a few spots as most teens do. In my late teens things changed drastically, I was breaking out like crazy and had to see a dermatologist (luckily a very good one, who had a holistic approach). Looking back on it, I know that the causes were pretty poor diet, combined with stress of college, and some unhealthy personal relationships, but I had to learn the hard way. With the help of my dermatologist and regular facials, my skin was clearing up, not a flawless airbrushed perfection found on the covers of magazines, but nothing I couldn't live with. The problem was I couldn't seem to find a skincare routine that I was happy with. Every payday Boots was my first destination, I would come back with a few bottles, read every bit of information on the products (without really understanding any of the Ingredients). After getting hooked on Lush and reading the Lush Times, I started to gain a bit more understanding of the ingredients. But this new fondness for more natural beauty was a slow journey, there was not a great deal of information, no wikipedia, no green blogs that I was aware of, no Content store and no Whole Foods. When Mr RF (fiance at the time) and I moved in together, in an effort to save money, I tried to make most of the beauty products myself. I was successful with face washes, toners and masks but not moisturisers, those I still bought from a store (from more conventional brands I should add). This was the time that I also became obsessed with Organic Life magazine, unfortunately a fairly short lived publication, that never the less had a huge impact on me and gave me that push to switch completely to natural/organic beauty. Now we have  finally reached the era of  Content, 2008 when I placed my first order with them (no my memory is not that good, I had to look it up), I am proud to say that I was with them from the very first year that they opened, and they are still my favourite destination for beauty and wellbeing. I did not start blogging until 2011, and at that point my skincare and body care were all pretty much "green", but not my makeup. The posts that I did were not exactly frequent. Fast forward to 2013 and I discovered the existence of other green blogs, and that gave me a boost to be much more serious about my own. Now to the present day, if we are talking well known green beauty brands that have existed for a few years there are very few that I haven't tried, I know how to read a label and rarely come across ingredients that I don't know (it still happens occasionally but less and less often), I also know what works for my skin. Most reviews that I do are for things that I purchased myself and I tend to take a long time before I am ready to post. I take pictures while the product is still mostly full, but I don't start writing until I have been consistently using it for at least about 4 weeks if it is skincare. Whenever I get offered something for a review, my first reaction is gratitude, because to me that says that what I do means something to other people, and it gives me a chance to review something of interest to my readers and yes it helps to keep the blog alive, because I am not rich and I can not just go and buy every single beauty product out there, no matter how much I wish it was the case. The second thought is, is this brand as good as it sounds, and the third is would it work for me? That means I have to do a little digging, have a look at the ingredients, and sometimes agonise over emails about how to phrase certain uncomfortable questions, in order not to offend but also to get a straight answer.

License and Registration Please.

I think this is a good time for a metaphor in a shape of a story (just to be clear this is completely made up and I would never actually do something like that). I have no driving license, but I do know how to drive, I just never bothered to take a test. While hubs is asleep I decide to take his car for a spin, as I have a sudden urge to pop into Harrods. My friendly neighbour, who is aware that I have no driving license, but otherwise we are not close, tries to tell me it is not legal for me to do that, but I brush his concerns under the carpet, and proceed anyway, because a close friend told me it was ok. I never actually bothered to find out for myself. On my way to Harrods, there is a random police check where they stop everyone, and once the police officer realises that I have no driving license he suddenly becomes less friendly. Somehow, my assurances that I know how to drive, and my pleas for him to trust me fall on deaf ears. He seems to think that the law is the law, and no matter how safe a driver I am, I have no actual documents to back that up, and taking my word for it is simply not good enough, no matter how wonderful a person I might be.

What does this have to do with beauty? Well very simply anyone who manufactures and sells beauty products in EU has to be registered with CPNP, and I mean anyone. If I make a cocoa butter massage bar and give it to my mother in law that is fine, however if she asks me to make her another one and gives me a fiver for my efforts that makes me a seller in EU, and that also means I should register my product with CPNP before I take that money. 'Simples', right?


'Simples' it is not.

You made your batch of yummy sugar scrub, that smells like frosting and makes skin baby soft, and you are aware that you have to register with CPNP.  You take some photos of your ingredient labels and your packaging, and try to upload them to the database. Unfortunately that is not how it works. You have to get your product assessed first for safety by a qualified person (and you need to be careful who you choose), your labels or outer packaging, or inside leaflet included with the product has to include INCI ingredients, batch number and manufacturing address. You also have to have a few documents on file before you register with CPNP and start selling. Here is a link that gives more info on this.


Welcome to the Jungle.



Natural and Organic are just words that only become meaningful once backed up by certifying bodies like EcoCert, Soil Association etc. In the last few years, since natural/organic has become trendy, and with phenomenon of Etsy, you are spoilt for choice, and brands are claiming all sorts of things. Sometimes big splashy promises of Organic Argan oil on a shampoo bottle, waiting for the unwary customer, are making you think that it is a good buy, but apart from that one ingredient the product is really not much different from your ordinary shampoo and you instantly feel duped. As a consumer in the 'green' industry you have to be pretty savvy but at times also trusting. Smaller brands simply can not afford to have these more expensive certifications, that does not mean that what they have is a product that isn't truly organic or natural, since if they use all organically certified ingredients it is an organic product, just without certification. What proves their claims is the traceability of the ingredients used, which is part of the Product Information File and a legal requirement for beauty product manufacturers in the EU (and for products that are imported with intention to sell).

Don't stomp on the little guy.



While I don't request to read the Product Information File before purchasing from hand made brands or any brands for that matter, it is an option that I know I have when buying products in EU. Jumping through registration hoops for a small business is time consuming, costs money and can be a serious headache. But from a consumer perspective I know that what the ingredients label says is what I am actually getting, without documents to back it up the label is actually meaningless. While I keep an open mind and trust that smaller brands are telling me the truth, well I did not switch to 'green beauty' because I had great belief in the cosmetic industry or the ingredients that they use, it would be strange if I however suddenly started taking claims of hand made beauty producers at face value. I love and support hand made beauty, but they get the same scrutiny as any other beauty product. US beauty products do not have the same strict legislation to follow, which is why you see so many more hand crafted beauty goodies over the pond, but that is also one of the reasons why most of them will never get a European stockist, the process of registering is just too costly and only worth it to those companies who want to expand. So yes I like all sorts of brands yet hand crafted, properly registered UK brands get my support every day of the week, and I vote with my wallet.

The Grey area.

The common names on the labels are much easier to read, and on a personal level I don't really have a problem with common names. Go ahead and include them in brackets next to INCI ingredients, or on your website if you are selling in EU. However if I get a product, be it for review or purchased online and it only has common names and no INCI it is a red flag. How could you possibly have gone through all the proper registration and not have the correct labelling? Yes I am a blogger, and if a product was sent to me it is technically a gift, there for the rules are a bit grey as no money exchange took place, so no law broken. Yet if I test it and review it, I need to know that you are in fact following the legislation, otherwise I am openly promoting what is effectively a rogue operation. Why on earth would I do that? Let us not forget that every blogger is also a customer or a potential customer, the way you handle communication with us is the way you treat your customers. Some of us have connections and are more than happy to share the advice necissary for a start-up, after all that is what 'green' beauty community is about, support. But at the end of the day every single one of us also buys beauty products, a lot even, and we are pretty loyal to brands we like. If we like your products you are likely to have a customer for life, who will also shout from the roof tops how amazing your products are. Yet if you are not complying with the law and not listening to what we have to say, you will never get our custom. It is not a bloggers job to prove to you what the law says, Trading Standards Office is a free resource that is there to help with exactly that. It is also not a bloggers job to drag every non complying business into the sunlight (unless of course it is what their blog is all about), we are not 'green' beauty police.

In conclusion.

While I do buy some products from across the pond that have common names instead of INCI on the labels, I am very selective, and actually would prefer for them to have INCI labels so things could be standardised. When it comes to products sold in EU it is a deal breaker, for the absence of INCI makes me instantly suspicious, and it is also against the law. Current Legislation does pose an entry barrier to new businesses and yes can be very costly, but it is also there to protect consumers, from getting potentially unsafe formulations (as there are plenty of natural allergens and essential oils have to be used in certain proportions). While I like to believe that 'green' companies are basically honest and founded by people who want to make a genuine difference, good intentions do not excuse anyone from following the letter of the law. If you feel that this particular law is disagreeable and unjust, you need to change it through politics, not by ignoring it.

16 comments:

  1. very thorough and informative... i hope that one day we will hold all our beauty companies across the pond to higher standards and accountable to consumers

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    1. Thank you! It would be nice just to be able to get a beauty products without worrying about all these things!

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  2. Great post and beautiful water colors, Tammy! xo I admire your stance in this issue and the fact that you have the strength to post about this. I have had strong concerns about these "mom and pop" beauty shops too, especially the ones on Etsy. A lot of times, they don't post the full list of ingredients (and INCI is a far far cry). I've literally seen some people I follow start making green beauty products on their kitchen stove and selling them online. I am not saying those are not safe, but I would rather buy my products from sources that are well trusted, have the proper documentation etc. I alluded to a bit of this littering issue in my latest post too - It's become so easy for anyone and everyone to DIY something and sell online that now is the time to be much more cautious. Of course, whereas US encourages free market, it also does little to regulate the beauty industry. It's very sad.

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    1. Thank you Ruhi! Well you know I love a bit of DIY, but when you making things for sale there are lots of things to consider. Making sure your packaging is sterile and actually properly protects the products etc I can completely understand that getting something that has been a bit more established is more appealing at times. Xx

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  3. Well done Tamara for bringing these issues into the spotlight. As you know I feel strongly that companies need to get on top of these regulations because it's unfair to those who are diligent about their requirements as a company. I have been accused of bullying companies over labelling but as you mention here I feel strongly that I don't want to write about brands that break the laws but as you point out if you can't get INCI correct are they meeting other obligations and therefore how do I know the product is safe? I am a customer with allergies so I'm need labelling to be correct and I can't stress that enough. I don't want to police brands it's not my job but I can't ignore what I know is wrong. There are some amazing small brands out there but if only they would listen to us bloggers and achieve the potiential they deserve.

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    1. Yes Sarah you tend to be a bit more vocal than me on most things lol. You know how I love to play the devil's advocate and growing up in a family of a small business owner I know exactly how frustrating and unfair regulations can seem at time. I was hoping to bring the issue to light from a consumer perspective, but also from a blogging one, as I personally feel I just couldn't talk about a brand that I did not trust.

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  4. For me in Germany it is normal to get my products with all INCI information. Abroad, I feel uncomfortable or even insecure when INCI declaration is missing. For me, a product with halfhearted information is no good to blog about. So thanks for your wonderful posting!

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    1. Thank you very much! I feel that way too! The beauty of INCI is that I can read a product with a label in any language and even though the description makes no sense, I know exactly what is in it!

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  5. Fantastic post Tammy, thank you so much for sharing your thoughts with us on this issue in such a diplomatic way. Hopefully things will change in regards to companies complying and ensuring INCI labeling, especially across the pond as there are so many lovely brands that don't have this yet. I truly loved this post and highlights yet again how careful we as bloggers must be with our information as well. Xx

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    1. Thank you for the support Nic! It was a difficult post to write, we both share the passion for smaller brands but like you say, recommending something on a blog comes with responsibility. I wish everyday that the world of green beauty was so much easier to navigate xx

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  6. Really interesting and food for thought Tamara. I do think that we sometimes have a tendency to trust 'green' companies and not hold them up to the same standards and scrutiny. If you're going to sell to the public, you need to have the paperwork in order. simples. I don't believe that all companies (green or otherwise) are purposely trying to cause harm, I do believe that it is now about making money.

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    1. Thank you Lynda! I agree I don't think that they intentionally try to cause harm. But I think some are unaware of the rules of the trade and maybe reluctant to listen when you give feedback, thinking that it is a personal attack on their company when it really is not. It is of course a business and registration process can take for ever and cost a pretty penny, who wouldn't want to avoid that if they could? I also was talking to a small green beauty brand owner the other day and she mentioned that a chemist who was testing her products wouldn't allow a higher percentage of Tamanu oil than 1%, because while a brilliant healing oil it has potential for toxicity at a higher rate. Now I have a billion diy books and am familiar with tamanu yet never new that! So I wonder how many untested brands also lack this sort of knowledge? Xx

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  7. Very insightful post Tamara! I feel you especially the part where you mention Etsy stores/small businesses. There are SO many people dabbling into creating their own natural beauty products because they 'can't find something that suits their skin' and go into business with it. I think it's great that we're doing that and raising awareness on health risks that come with conventional skincare, but at the same time there is no security or guarantee that their handmade products are going to be 'better' for consumers. I think on our part as consumers we also have to educate ourselves on issues like that, and not just follow suit blindly.

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    1. Thank you Ru! Wholeheartedly agree with your comment. It does make me feel sad that a lot of people don't try products from smaller green brands thinking that they might be not of high quality, when in fact all the good ones have the proper paperwork and very imaginative creations that are just wonderful for the skin.

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