How-to: Product Updates
Your cosmetic product may get updated for several reasons: replacing a raw material, new packaging or updated artwork. Usually not a problem, but it is important to always keep your files up to date. How to deal with these changes as a Responsible Person?
Cosmetic products are constantly evolving. As a business owner, you may have experienced the frustration of launching a new product that is selling well, only to find out that the cosmetics legislation has been updated. This can be time-consuming and inconvenient, especially if you have a wide range of products in your portfolio. You may wonder if you can still sell your product and if you are at risk of any consequences. What if the NVWA (Netherlands Food and Consumer Product Safety Authority) decides to inspect your products?
Apart from legal changes, there are other reasons why a cosmetic product may need to be modified. For example, the label of the product may need to be changed based on feedback from the market to improve sales. Additionally, there may be issues with the availability of raw materials, leading to changes in the formulation of the product. It is essential to keep an up-to-date file documenting all these changes and have them assessed by a Safety Assessor. This is crucial to ensure that the product remains safe even after modifications.
What are the risks of not maintaining an up-to-date product file?
Firstly, there may be a temporary halt in sales if a product does not comply with the updated legislation. In such cases, the formula of the product needs to be adjusted before it can be reintroduced to the market. The reformulation process can take anywhere from 3 to 6 months, depending on the specific ingredient.
Furthermore, if the NVWA conducts an inspection and finds that your product file is not up to date, you may face substantial fines. The amount of the fine depends on the extent of the deviation and how quickly it can be rectified.
In more serious cases where the safety of the product cannot be guaranteed, it may be necessary to recall the product from the market. This can have a significant impact on the brand's reputation and image.
When consumers use unsafe products, they may experience health issues and may complain about them, especially through social media platforms. This can further damage the brand's image and reputation.
To avoid these risks and ensure the safety of your products, always ensure to discuss them with your safety assessor.
How to deal with a product update in the SkinApp?
As Responsible Person, you are responsible for keeping your files up to date. Always let SkinConsult know about a change in your product, whether small or big, so we discuss whether it's necessary to update your files.
Do not make any changes yourself in previously finished projects in the SkinApp: we have a quick way to duplicate your product and create a new project in the blink of an eye. This way, the previous versions of your products will get archived and remain available: handy, since multiple versions of your product might circulate in the market.
So in short: any change to your product might have an impact on the safety report, so always contact your safety assessor about it!
We hope to have informed of product updates, what they are and when you are obilgated to let SkinConsult know to remain compliant with EU legislation. Please do not hesitate to contact us if you have any other questions about product updates: office@skinconsult.com.
Remember, safety first!