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Pet testing & safety sheet
Hi everybody
I did search this and a lot of other fora incl. google without finding the right answer, so any help is really appreciated.
Q: Is PET testing required when simply bying a finished product, just refilling it in own bottles with own label.
And what if it is to be sold under different private label.
Primarely in the EU, but any answers are welcome
Awaiting your appreciated reply´s
Regards
Carsten -
12 Replies
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Preservative Efficiency Testing is not normally carried out on cosmetic products . Single use products would normally be sterile but these are rare.
I have not heard of PET being used on, or for, cosmetic products before as they should be formulated in such a way and with sufficient preservative to allow multi-use containers to be used.
It goes without saying that all equipment and containers (yours or third party) should be clean and that is where microbial testing might be of use.
As an aside, I was part of an investigation once looking at potential sources of common microorganisms in the environment. One of the dirtiest places found (apart from obvious things like toilet bowls and seats) was the bottom of ladies handbags and purses where some quite horrendous pathogens were common (Streptococci, E coli, Pseudomonas and others). It is these things that cosmetics should be formulated to protect against and, in the main, they do.
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it depends how much you trust the person/company you’re buying it from
ideally, they should have done it themselves before offering it for sale
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If you’re buying a product in the EU to private label, the developer/manufacturer of that product would have to have done a safety assessment and registered that product before it could be sold in the EU. Most likely, that would have included a Preservative Challenge Test … Just ask them for the documentation.
You could also ask that they provide you with documentation that each lot you purchase has passed a microbial QC plate count test … that’s standard.
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Thanks a lot, thats what I thought myself, but you cant be to safe. Our case is buying cream and hairbases in bulks, fill it in own bottles and label it with our name, so one more Q: Do you know if we have to register it in the CPNP database ?
Further I guess we need to PET test only if we add different oils, perfumes, actives etc. Right ?Thanks again.
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I am not certain … I would ask the manufacturer you are purchasing the product from. I do not have experience with private labeling in the EU, only with new product development.
If you add different oils, perfumes or actives to the base, it becomes a new product and you would most likely have to register your ‘enriched’ version of the product. You could probably save a lot of time and money by using the same Safety Assessor that issued the original report as the only ingredients that would need to be reviewed would be the new ones you add to the already approved base.
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@MarkBroussard
Hey Mark, thanks a lot for your kind & informative reply. It´s really appreciated -
@cbwp as far as the law is concerned, the Responsible Person, i.e. the company whose name is on the product’s packaging, needs to register their products on the CPNP
but in practise, customers who don’t have technical staff usually subcontract this work to the manufacturer
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In the US you would be responsible for the safety of your products. If there was a problem you couldn’t simply point to your supplier and say it is their fault. So, it comes down to how much you trust your supplier’s testing procedures.
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@Bill_Toge @Perry
Thanks, If we are buying soaps in bulks from i.e. Stephensons (should be a trusted supplier), and the only thing we do is refilling in own bottles, then we need to register in CPNP with our own brandname. Correct ? -
I formulated a Pet Shampoo for a client. In researching her reference formulas, we found that one of them was simply purchasing a Pet Shampoo from Vermont Soap that Vermont sells for $7.00 for a 16 oz bottle. The reference client was doing nothing more than buying the Vermont Pet Shampoo, bottling it with their own label and marketing it as a “premium” Pet Shampoo for $40 for a 16 oz bottle. The did nothing to enhance the base, simply rebottled it.
Stephensons is a very reputable company. You should have no issues. But, best you check into the registration requirements.
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if your company is the brand owner, and your company’s name and address appears on the pack, then in the eyes of the law, you do need to register your products on the CPNP
(apropos of nothing, my old line manager, from my first 1-2 years in the industry, is one of the chemists at Stephensons)
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Thank you all for your kind answers, I did get a lot wiser. Remember… enjoy life…
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