CPSRs - Buying valid ingredients
When we issue a Cosmetic Product Safety Report (CPSR), we deliberately allow flexibility wherever possible. With the exception of fragrance oils, which are assessed based on the specific proprietary composition supplied by the fragrance manufacturer, most ingredients can be purchased from any supplier. This means that if your usual supplier is out of stock, you do not necessarily need a new assessment just because you have bought your cocoa butter, sweet almond oil or glycerine from somewhere else.
However, it is important to understand that a product name does not always tell the full story. Many cosmetic ingredients are actually blends of several ingredients rather than a single raw material. A good example is avocado butter. Depending on the supplier, this may contain Persea Gratissima (Avocado) Oil combined with Butyrospermum Parkii (Shea) Butter, Hydrogenated Vegetable Oil and Tocopherol. Another supplier's avocado butter may contain a completely different combination of ingredients. Although both products are sold as "avocado butter", they are not necessarily the same material from a regulatory perspective.
The same applies to ingredients such as Vitamin E. One supplier may sell mixed tocopherols diluted in sunflower oil, another may use soybean oil, while another may offer pure tocopherol. Botanical extracts are another common example. An extract is rarely just the plant itself. It may contain glycerin, water, propylene glycol, alcohol or another carrier system, and these additional ingredients can vary significantly between suppliers.
This is why it is essential to check the INCI declaration or specification of the ingredient you are purchasing. The ingredient listed on your CPSR is what has been assessed for safety. If the INCI composition of the ingredient you buy matches the specification listed on your CPSR, then it does not matter where you purchase it from. However, if the INCI is different, even if the ingredient has the same common name, then it may no longer be covered by the assessment.
For example, if your CPSR lists Tocopherol, Helianthus Annuus (Sunflower) Seed Oil, and your new supplier sells a Vitamin E blend containing Tocopherol and Glycine Soja (Soybean) Oil, then this is not the same ingredient and should not be substituted without checking with us first. Likewise, if your assessment specifies an extract in glycerin and water, but your new supplier's version is dissolved in propylene glycol, it should not automatically be assumed to be interchangeable.
Natural butters, oils and simple raw materials are generally straightforward, and buying these from different suppliers is usually not a problem provided the INCI remains the same. Blends, extracts, actives and speciality ingredients deserve much closer attention. A change in supplier does not necessarily mean a problem, but a change in INCI composition may mean that the ingredient falls outside the scope of the original assessment.
The easiest rule to remember is this: don't compare ingredient names, compare INCI names and percentages. Your CPSR is based on the ingredients listed in the specification and their % ratios, not on marketing names or product descriptions. If the INCI and % inclusion matches, you are generally fine. If it doesn't, please check with us before using it. A quick email is much easier and cheaper than discovering later that your product no longer complies with the assessment.
As a cosmetic maker and the responsible person for your product it is up to you to understand this and follow this for your safety report to remain valid. We give you flexibility, but it has to be within what's reasonable and safe.