This article is brought to you courtesy of Jess.
Are you feeling overwhelmed at the thought of filling out your Cosmetic Notification Forms? If you've spent any time listening to other soapmakers going through the process, you might be. I've been through the process myself, so I get it. If you've found yourself staring at the Health Canada website with your eyes glazing over, this article is for you.
Ready to break it down?
Once you've developed your product line and know which ingredients you will be using, it's time to submit your Cosmetic Notification Forms (CNFs) to Health Canada. You can fill out your forms up to 10 days after your first sale. But why wait until you are in the busy filling orders?
If you make cosmetics in Canada, and sell those cosmetics, submitting your CNFs is something you cannot skip. Here are some tips to make the process easier.
(Fear becomes your biggest enemy when starting a business! Don't let it stop you.)
1. Research & learn about cosmetic regulations in Canada
There is a wealth of information on the website, including a guide for filling out your CNFs, a link to the Canadian Food and Drug Act, a link to Canada's Cosmetic Regulations, the definition of what products qualify as a cosmetic, and more.
In Canada, 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."
Some examples are "beauty preparations (perfume, skin cream, nail polish, make-up) and grooming aids (soap, shampoo, shaving cream, deodorant)."
Takeaway: Don't think that as a small operation you are excluded. Health Canada specifically mentions that it includes "handmade cosmetics sold at craft sales or home-based businesses."
Health Canada also keeps an up-to-date hotlist of ingredients that are either restricted or prohibited for use in cosmetics. Make sure to check this list in your research and development phase to avoid using any prohibited ingredients. If you use any restricted ingredients, refer to the list for warnings you should display on your labels.
If you don't understand something, don't be afraid to ask questions! Health Canada has contact info online, and they are very helpful. Chances are someone has had the same issue as you, so there's no need to reinvent the wheel.
(Not in Canada? Here's help with the United States cosmetic regulations.)
2. Get organized before starting your Cosmetic Notification Forms!
Before sitting down to fill out your Cosmetic Notification Forms, compile all of the information you'll need, including:
- your business contact information
- formulas for all of your products
- INCI names for all ingredients used in your formulas
Health Canada requires submitting ingredients using the International Nomenclature of Cosmetic Ingredients (INCI) format. If you aren't familiar, INCI is a naming convention based on Latin and English words that are recognized around the world.
Most suppliers will have these names on their website. It is always best to consult the Cosmetic Ingredient Dictionary rather than rely on random Google searches if your supplier does not give you the information.
While essential oils each have an INCI name, fragrance oils can be lumped under the term 'fragrance' or 'parfum'.
Also, you'll need the percentage of each ingredient used in each formula. Make sure you have all the masses of your ingredients handy and calculate the percentage of each ingredient in your final product.
For soap, you should be entering the final product ingredients, the 'out-of-the-pot' ingredients. Make sure to:
- Exclude the lye
- Calculate the amount of glycerin produced
- Account for any water that evaporates during the cure
This is time-consuming, but you'll use this info on your labels as well. So, it's time well spent!
3. Fill out the online CNF for Health Canada
Set a block of time aside to fill out your Cosmetic Notification Forms. If you've taken the time to prepare before you tackle the online web form, it should take you an hour or less.
Pro tip: If you have one base recipe that you make all of your bars from, you only need to fill out one CNF. Enter your base oils, water, and glycerin, then add every single ingredient you use in each variation and set those as "May contain".
You can save the form and return to it later, but once you're in the groove, it will be easier to just get it all done at once. Have all of your information handy, grab your beverage of choice, and get going!
4. Submit & save your required forms for selling cosmetics in Canada
Once you have completed and submitted a Cosmetic Notification Form on Canada Health's website, make sure to save it using the instructions on the bottom of the form. Then you can make amendments if you need to. Or you can review the information you entered.
5. Check your Cosmetic Notification Form twice (at least)
Learn from me! The first time I filled out the form I forgot poppy seeds and water! Make sure you have entered all your ingredients and percentages correctly. Review your contact information too.
Did you notice a mistake after you hit submit? Just upload the saved web form, make your changes, and then resubmit!
And that's it! You may not hear back for several weeks or even several months. But, as long as you've submitted the form, you can start selling your cosmetics.
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