Selling Handmade Soap and Cosmetics Legally in the UK: CPSR, Labelling and Notification

Making soap and balms is one of the most satisfying homestead skills, and one of the easiest to turn into a little income. Then you sell your first bar and discover that, in the eyes of the law, you are not a crafter any more. You are a cosmetics manufacturer, and cosmetics are one of the most tightly regulated things a small producer can put on a table. The good news is that the rules are clear and the same for everyone. The catch is that most of the work has to happen before you sell a single item, not after.

This is a plain-English guide, not legal advice. The rules are technical, they change, and they differ across the four nations, so treat this as a map and confirm the current detail with the linked primary sources before you sell. Read the caution below first.

First, is what you are selling actually a cosmetic?

A cosmetic product is essentially something you put on the outside of the body, on the skin, hair, nails, lips and so on, to clean it, perfume it, protect it or keep it in good condition. That definition sweeps in almost everything a homestead maker sells: soap of every kind, bath bombs and bath melts, lip balm, salves and healing balms, hand and body lotion, beeswax skincare, face masks, scrubs and deodorants.

Two points trip people up. First, both cold-process soap made from scratch and melt-and-pour soap made from a bought base are cosmetics. Buying a ready-made base does not move the job onto someone else; the moment you cut, colour, scent or rebrand it and sell it, you are making a cosmetic product available and the full set of duties lands on you. Second, "making available" is broader than selling. The OPSS guidance covers products that are sold and products that are given away, including free samples, so handing out testers at a market is not a way around the rules.

The five things you need before you sell

For the Great Britain market (England, Scotland and Wales), the framework comes from the retained EU Cosmetics Regulation, Regulation (EC) No 1223/2009, as amended for the UK. In plain terms it gives you five non-negotiables, and they apply to every product you sell, including each variation.

The pre-sale checklist, in order

1. 1

   A Cosmetic Product Safety Report (CPSR)

   Before a product is made available, its safety must be assessed by a qualified safety assessor: someone with a university degree in pharmacy, toxicology, medicine or a similar discipline. The report has two parts. Part A, the safety information, is compiled by you and covers the ingredients, their concentrations, the product's stability and how it will be used. Part B is the assessor's conclusion on whether it is safe, with any warnings. One report can often cover a range of similar recipes, which keeps the cost down, but you cannot write your own unless you hold the qualification.

2. 2

   A UK-established Responsible Person

   Every product must have a Responsible Person who ensures the rules are followed. They must have a UK established address, which gov.uk says does not include mail forwarding or PO box addresses. A sole trader making their own products is usually their own Responsible Person. If you sell another maker's product under your own brand, you may become its Responsible Person, so understand that duty before private-labelling.

3. 3

   An OPSS product notification (SCPN)

   The Responsible Person must notify each product to OPSS before it goes on sale, using the Submit Cosmetic Product Notifications service. This is the UK replacement for the EU's CPNP portal and is not interchangeable with it. You will need the product name and category, where the PIF is kept, a named contact, the ingredient summary, an image of the label and a photo of the packaging.

4. 4

   A Product Information File (PIF)

   Keep a PIF, in English, for every product. It holds the product description, the CPSR, the record of good manufacturing practice and evidence for any claims you make. It must be kept for 10 years after the last batch was made available, and you must be able to produce it if an enforcement authority asks.

5. 5

   Good manufacturing practice (GMP)

   Manufacture must follow good manufacturing practice. The recognised standard is ISO 22716, which covers clean premises, staff training, batch records, traceable raw materials, quality control and handling of complaints. You do not have to be certified to it, but you do have to work to that standard and record that you did.

Getting the label right

The label is where a lot of otherwise-compliant small makers slip up, because Article 19 of the Cosmetics Regulation is prescriptive. The container and packaging must carry the following, in indelible, easily legible and visible lettering.

Two further labelling traps are worth naming. Weight and volume must be the nominal content, and if you sell by weight you may also need to meet weights-and-measures rules, so check with your local Trading Standards. And claims are policed: your labelling and advertising must not say the product does something it does not do, and you must be able to prove any claim you make. "Moisturising" is fine if it moisturises; "cures eczema" turns a cosmetic into an unlicensed medicine and is a different, more serious problem.

Candles, wax melts and diffusers are a different rulebook

Because so many soap makers also pour candles, it is worth being clear: candles, wax melts and reed diffusers are not cosmetics, because you do not apply them to your body. They do not need a CPSR or an OPSS notification. Instead they sit under general product safety law (the General Product Safety Regulations 2005) and, because scented waxes and fragrance oils are chemical mixtures, under the GB CLP rules on classifying, labelling and packaging hazardous mixtures. That means hazard pictograms, signal words and hazard statements on the label, not INCI lists and PAO symbols.

The point here is only to stop you assuming one set of paperwork covers both. It does not. If you make and sell home fragrance alongside your cosmetics, treat them as two separate compliance jobs. Our companion guide, how to sell soap and candles in the UK, walks through the candle side in more detail, and if you are selling any of it through a website or a marketplace, selling online in the UK covers the consumer-rights and distance-selling duties that apply on top.

Nation by nation

The core message is that OPSS, the SCPN service and the retained Cosmetics Regulation apply across Great Britain: England, Scotland and Wales are treated the same. The complication is Northern Ireland.

Within Great Britain, enforcement is carried out locally by Trading Standards, and your local authority is the body most likely to ask to see your PIF or query a label. That is a good reason to keep your file tidy and your labels right from day one, wherever in Great Britain you are based.

The traps people fall into

• Treating soap as a craft rather than a cosmetic, and selling before any of the safety work is done.
• Assuming melt-and-pour, because the base was bought in, does not need a CPSR. It does.
• Believing there is a small-batch or craft-fair exemption. There is not; one bar needs the same file as a hundred.
• Forgetting that giving away free samples counts as making the product available, so the rules still bite.
• Using a PO box or a mail-forwarding address as the Responsible Person address, which gov.uk expressly rules out.
• Thinking the old EU CPNP portal still covers the GB market. You must use the UK SCPN service instead.
• Writing your own safety assessment without holding the required qualification.
• Getting the label wrong: missing INCI names, no batch number, or a best-before date on a product that should carry a period-after-opening symbol.
• Making a medicinal claim ("heals", "cures", "treats"), which pushes the product out of cosmetics law and into medicines law.
• Assuming your cosmetics paperwork also covers your candles. It does not; candles follow GPSR and GB CLP.
• Assuming a GB notification also covers Northern Ireland, which runs on the EU regime.

Before you sell cosmetics: check these

1. Have you confirmed each product is a cosmetic, and grouped your recipes so one CPSR can cover a range where possible?
2. Do you have a Cosmetic Product Safety Report from a qualified safety assessor for every product or range you sell?
3. Is there a named Responsible Person with a genuine UK established address (not a PO box or mail-forwarding address)?
4. Have you notified each product on the OPSS Submit Cosmetic Product Notifications service before putting it on sale?
5. Have you assembled a Product Information File, in English, for each product, ready to keep for 10 years after the last batch?
6. Are you manufacturing to good manufacturing practice (ISO 22716) and keeping batch records?
7. Does every label carry the Responsible Person's name and address, nominal content, a durability date or PAO symbol, the batch number, the function, warnings and the full INCI ingredient list?
8. If you also sell candles, wax melts or diffusers, have you handled those separately under general product safety law and GB CLP?
9. If you sell into Northern Ireland, have you checked the separate EU-aligned position rather than assuming the GB rules apply?
10. Have you arranged suitable product liability insurance before your first sale?

When in doubt, work from the primary sources (the OPSS guidance on gov.uk, the SCPN service, and the Cosmetics Regulation on legislation.gov.uk) and speak to your local Trading Standards before you sell. On cosmetics, the paperwork genuinely does have to come first, and a compliant start is far cheaper than a recall.