Updated: Jul 15
Our ambition at Cannafull is to ensure that the compliance element of your product launch is as easy as possible so that you have more time to build your brand.
This article outlines the way in which we’ve designed our services to address the skincare regulatory framework requirements and what you can expect when you source your CBD skincare from us.
If you’ve not yet read our article on CBD cosmetics regulation in the UK & EU, we’d recommend you have a look at this first as it covers useful information to set the context for the points we discuss below.
White Label product certification and registration
All our white label products undergo a safety assessment by a third-party lab to certify that the formula is safe for its intended use.
As part of this, all products that include water also undergo a Preservative Efficacy Test (PET – also referred to as a "challenge test") to demonstrate that the preservative in the formula is suitable to prevent or inhibit growth of bacteria, yeast and mould. Whilst preservatives sometimes get a bad rap, without their inclusion, hydrous cosmetics are a nutrient-rich breeding ground with plenty of “bug food” which could easily harbour bacterial growth – so their presence plays a vital role.
On the back of the safety assessment and PET, our 3rd party lab issues a Cosmetic Product Safety Report (CPSR). This certifies that the product is safe for sale.
As part of the onboarding process for new customers, the CPSRs for the relevant products are issued against your brand name, with you as the Responsible Person.
The final step to allow your cosmetic to be placed on the market is to register it on the relevant database for the EU (CPNP) or the UK (SCPN). We hold your hand through this process to make sure the process is quick and painless.
Rules about what information is mandatory on cosmetics labelling are relatively prescriptive and, to ensure compliance with both cosmetic and weights and measures regulations, it's important you get this right.
We provide product–specific guidance which covers all the information that needs to be included on your label and / or carton artwork.
In addition, we also share a generic cosmetic labelling guide with all our customers which provides guidance on the key elements such as:
Inclusion of country of origin
How to list the ingredients using both the using International Nomenclature of Cosmetic Ingredients (INCI) and common ingredients names that consumers recognise
What logos you can and can’t use to demonstrate specific credentials of the product (vegan, cruelty free, recyclable etc.)
Once you’ve completed your artwork design, we are happy to provide a complementary review of the files to act as a second set of eyes and make sure there are no red flags.
In addition, for Cannafull products using full spectrum oil, we test our raw CBD oil for terpenes (for an example click this link). This allows us to calculate the concentration of terpenes in the final product to ensure that, if any of the terpenes present are also cosmetic allergens, they are appropriately identified on the product.
As part of the labelling guidance, we also provide examples of what you can and can’t state about the product, based on the ingredients included.
It’s important to remember that cosmetics are not medical products, and therefore you want to ensure that you’re not making claims that are unsuitable for cosmetics
COA testing on each batch
All Cannafull’s customer orders are manufactured to order to maximise the freshness of the product. We will confirm your order’s batch number soon after your initial payment – this is important information as this needs to be printed on the packaging!
Every customer order that we produce also undergoes a Cannabinoid Certificate of Analysis (COA) test at a third-party lab. Prior to despatch, this COA will be sent to you to demonstrate that the CBD strength of the product meets or exceeds the advertised amount, per the order form.
Whilst including CBD strength on cosmetics packaging is not a legal requirement – for us it is a critical part of the service we provide. Historically, the CBD industry has received a lot of bad press for products containing significantly less CBD than their label states. Our COA test provides you with the confidence that this will not happen to your brand!
Good Manufacturing Practices (GMP)
All our products are produced in-house at our facility in Scotland, where they are made to GMP standards.
As part of this we certify that the correct controls and processes are in place to ensure that the products are made in a way that is safe and to the right quality standards. These cover controls such as traceability of all incoming batches of raw ingredients, retention of samples of all products that we make and quality checks of the product during the manufacturing process.
As part of the process of getting a white label product registered under your brand as the RP (Responsible Person), we will also need you to confirm that the packaging and any claims made will be compliant (i.e. in line with the guidelines we provide in the labelling guidance)
Product Information File (PIF)
The PIF is a batch-specific document which provides information such as:
The manufacturing process
Batch information of all raw materials used
Cannafull maintains a copy of the PIF for all batches made so that, in the case of a query from a customer or the authorities, this information can be provided quickly.
Undesirable and Serious Undesirable Effects
We provide all our white label customers with templates to collect the relevant required information if a customer suffers a reaction after using one of our products.
Whilst the chances of this are highly unlikely, it is a regulatory requirement that you are equipped with a framework for the information you need to gather from a customer should this happen.
If this was to occur, we will work with you through the process to make sure you are equipped with the correct and optimal information to represent your brand.
Let's pick up the conversation...
Whilst the above might feel like quite a lot of red tape, these requirements ultimately exist to protect the health of consumers. The good news is that if you choose Cannafull, we’ll make the regulatory elements as painless as possible whilst ensuring that you are selling product in a compliant way.