What is a PIF?
If you are making cosmetics for sale in the UK or EU then you've probably discovered the regulations that you need to follow, and in turn started researching what each of these regulations entails.
A PIF is one such regulation and is an absolute necessity when making and selling cosmetics.
PIF stands for Product Information File. It is a file containing all information about your product. It can be written and formatted however you like, but it MUST contain certain information.
A PIF will be stored at the place of manufacture. I like to keep one electronic version and a printed version.
Why do you need one?
It exists for a number of reasons.
- So that you or staff members can make batch after batch of your product with consistent results.
- To have all information about your product available for regulatory bodies such as Trading Standards, when requested.
- If a customer has an issue such as an allergic reaction, you can provide all information about the product to those who need it.
- For safety.
A PIF must be kept for 10 years after the product first goes to market, regardless of if you are still in business or not.
It is the responsible person who keeps the PIF. A responsible person being the person who takes full responsibility for the products, obtains the product safety reports and details of whom are on the product label. Every cosmetic seller in the UK and EU needs their own responsible person.
Below is a list of what needs including, plus a couple of extra 'best practice' items to include:
- You Product CPSR
- Technical documents for your ingredients
- You Method of Manufacture
- Your GMP Statement
- No Animal Testing Declaration
- Product Photos & Label Image
- Stability Testing Data & (if applicable) Challenge Testing Data
- Packaging Specification
- Product Specification
- Proof of Claimed Effect Declaration
- Any additional information such as complaints log, batch records etc.
I don't live in the UK or an EU country, do I need to do this?
If you want to sell your products to UK or EU customers then yes you will need to follow UK and EU regulations.
Note that since the UK left the EU, you would now need a separate responsible person for the UK and another for the EU.
The responsible person MUST live in the same country as the product is being sold, so if you live in the USA for example, and you would like to sell your products to UK customers, you would need a UK based RP.
How do I find an RP (responsible person) in another country?
There are companies who will act as an RP for you for a yearly fee. This usually involves helping you with all the other regulations, including doing a safety report for your products, to ensure that you are complying with all regulations and that your product is safe for intended use.
One such company is ceway.eu (no affiliation) who provide RP services for selling in both the UK and EU. They also provide a lot of information on what is required to sell your products in most countries.
Regardless of where you live, I'd say that a PIF is a great thing to have even if your country doesn't legally require it. It's useful for you to refer back to and store all the batch records and information about your products. If you get in the habit of making these, you are half way to be being able to sell elsewhere if you decide to.
If you are unclear on what any of these items are, then I suggest that you watch THIS VIDEO.
If you need help compiling your PIF, I have created a best selling template which is available HERE.
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