EU Cosmetic Regulation and the Vanishing Small Producer

This is a copy of a blog by Amanda Saurin which makes absolutely vital reading for any small business or sole trader. What she has to say is not good news for any of us – but we need to know about it and we need to act collectively and speak out against the kind of blind bureaucracy, sometimes driven by a corporate agenda, that threatens so many small businesses.

Amanda is  a local cosmetics producer based in Lewes. Her products are produced with quality, integrity and love – the kind of values often seen in local producers who care as much for the environment as they do for their customers and wider community. Here it is:

“I have a wonderful job. As those of you who read this blog will know I spend my time growing, picking and distilling plants which I make into beautiful skincare products for my own company Wellgreen Lewes, Firle Place Herb Garden, Glyndebourne and Flint in Lewes. The pleasure is in the small scale production and the freedom to create with immense care, combinations of scent that smell wonderful and often have a therapeutic benefit.

In July of this year a new EU directive came into force, (now adopted into UK law) which is quietly destroying the business feasibility of many small producers. Many more small businesses will close as the stringent requirements are enforced by Trading Standards.

The EU wants to bring all cosmetic producers into line by creating a Europe-wide set of enforceable requirements; meaning that if we all work under the same legal directive, rogue producers who are not careful will stop producing, standards will be the same for everyone and the consumer will be protected.

As an idea on paper it makes sense and it’s difficult to argue against consumer safety – conformity = safety across the EU. However, all EU countries are not equal, many will half-heartedly impose these regulations and others won’t bother at all. Rogue traders will carry on because they have never conformed anyway. It is the small ethical UK producer who is compromised.

Practically for us in the UK what it means is that new Cosmetic Safety Assessments have been introduced by chemists interpreting the directive, in the UK at least, to the letter. This is not a criticism, merely an observation. The new Safety Assessments are so stringent that they are incredibly expensive to undertake because the tests are exhaustive – microbiological tests, stability tests, toxicity tests, challenge tests and more.

The cost of all this is horrific for those of us who are small producers – I have had quotes of between £650 and £1500 PER PRODUCT. With 20 products, the costs are somewhere between £13,000 and £30,000 which is more than I will make in a lifetime of production. One chemist is trying to offer flexible testing for less but it reduces the choice of essential and other oils and precludes the development of new slightly unusual recipes.

But actually, there is a far greater sadness, which is that as more and more chemicals, colours, sparkly bits and all the rest are put into cosmetics, there is a far greater risk of harm to the consumer. The big pharma companies can pay for these assessments and continue the relentless drive towards unsustainable twinkling youth with increasing amounts of fillers, firmers etc. However for those of us who produce skincare carefully and thoughtfully using herbs and oils with centuries of pedigree of benefitting the skin and the soul, we risk being completely squeezed out. This is not a question of safety for the consumer it is an issue of economic muscle driven by big pharma. It is a further example of big business seeking to control the market, drive out small competition and eradicate those ingredients that we use with integrity but which are not commercially viable on a large scale. What we are moving towards at an alarming pace is the equivalent of factory farming for the skin and the eradication of choice – how sad.

For you the consumer, this is a disaster. The integrity, transparency and ethical nature of many small producers is a wonderful thing but we will disappear if big pharma pressure continues. There are many great bloggers and proponents of truly ‘green’ products out there and your choice will be severely limited – soon… and all the fantastic plants we grow locally will not be used for your benefit – what a crying shame”.

Postscript: As co-ordinator of the Lewes Pound, I have just written to our MEP’s and I will keep you updated with any responses


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