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You’re changing ingredient suppliers
...for just one of your ingredients. Sounds like a no biggie, right?
You’re already familiar with the properties of that ingredient.
You already understand that ingredient’s role in your product.
You’ve already completed safety, stability and performance/efficacy testing on your product, and they all passed with flying colours.
So why would you bother doing any retesting?
Let’s have a look at my grape vines for the answer.
Different suppliers = different ingredients
These vines were purchased from 2 different nurseries (suppliers) around the same time and have been growing next to each other.
As you can see, they are very different in colour and size. Additionally, the purple ones are crunchy and sweet, whilst the green ones are on the sour side.
Just like these grapes, your cosmetic raw materials can vary from supplier to supplier.
For example, just say you’ve purchased olive oil (Olea Europaea Fruit Oil) from Supplier B instead of your usual Supplier A.
Here are some of the variations you may encounter:
- Supplier B has different release specifications to Supplier A.
- Supplier B performs different tests on the olive oil to validate its safety.
- Supplier B has different accreditations/certifications to Supplier A (e.g. certified organic).
- Supplier B uses cold-pressing and sells extra virgin and virgin oils. Supplier A’s olive oil is refined. Different machinery/equipment are also used to extract the oil from the plant.
- Supplier B’s oil doesn’t contain an antioxidant whereas Supplier A’s contains Vitamin E.
- Supplier B sells single oils whereas Supplier A blends their olive oil with other vegetable carrier oils.
Each of these variations can affect the nutritive, physical and chemical profiles of the olive oil, and in turn, affect how it reacts to the other ingredients in your product.
OK, but do these variations warrant any form of re-testing?
Firstly, let’s see what the regulations state.
What do the regulations state?
The Australian Competition and Consumer Commission (ACCC) doesn’t prescribe specific tests or retests for cosmetic products, BUT under The Australian Consumer Law, you are required to ensure your product is of an acceptable quality, safe and effective under labelled or customary conditions of use.
The definition of acceptable quality is as follows:
(2) Goods are of acceptable quality if they are as:
(a) fit for all the purposes for which goods of that kind are commonly supplied; and
(b) acceptable in appearance and finish; and
(c) free from defects; and
(d) safe; and
(Reference: Competition and Consumer Act 2010 Volume 3, Schedule 2 – The Australian Consumer Law, Chapter 3 Specific Protections, Part 3-2 Consumer transactions, Division 1 – Consumer guarantees, Subdivision A – Guarantees relating to the supply of goods, 54 Guarantee as to acceptable quality)
Why you would retest your product
As you know, cosmetics formulating requires precision and is an applied science.
What “should” occur (the theory) is not always what “does” occur (the practice) and you cannot rely solely on theory, such as the supplier documentation or concepts in text books. Sometimes, you need to tap into your creative muscles and think outside the square.
Therefore, in order to confirm your cosmetics products continue to be fit for purpose, acceptable in appearance and finish, free from defects, safe and durable, retesting is recommended.
Retesting could offer you peace of mind and assurance that your products will continue to perform as expected, be safe and stable for the duration of its shelf life, AND are consistent with your previous batches.
The scope of testing will depend on the type of product and claims you’re making. If you’re unsure, check with an experienced cosmetic chemist or formulator to help you out.
When to consider retesting your product
Of course, changing suppliers isn’t the only instance in which you would consider retesting your product, over and above your regular batch testing.
Here are some other scenarios to keep in mind. When you:
- change your packaging and/or dispensing system (e.g. switch from plastic jars to glass bottles, or serum pumps to screw top lids).
- increase your batch sizes (e.g. increase from 1kg to 10kg to 100kg).
- change your equipment or workspace (e.g. purchase a filling machine or move to a new premises).
- change your manufacturing process (e.g. transition from being handmade to contract manufacturing).
- reformulate your product (e.g. use a completely different preservative, emulsifier, fragrance or humectant, or switch to certified organic or cruelty-free ingredients).
And speaking of changes, you may also decide to rebrand or update your product labels at the same time.
If you’d like to get Australian cosmetic labelling tips straight to your inbox, you’re welcome to join the Geraldine Pierre community for FREE. Your first freebie is an Australian Cosmetics Label Cheat Sheet with links to the regulations and guidelines for Australian cosmetics.