Maker of Soaps and Shaver of Men
Cooperstown, NY, USA
(This post was last modified: 04-19-2016, 04:31 AM by Barrister_N_Mann.)
To address a point made on the companion to this thread, selling products in the EU is not as simple as just "listing the potential allergens." First, you need to make sure that the fragrance complies with IFRA regulation. If you're buying fragrances within the US, even pre-made ones from places like Brambleberry and Nature's Garden, that is not necessarily going to be the case with every fragrance you purchase. And, I can tell you from experience, the IFRA Manual of Practice is not an especially accessible or user-friendly document.
Then you have to get the base certified for every single product. Each scent is regarded as a separate product, and so must be certified separately. For some manufacturers, that could be 5-10 soaps. For a very prolific soapmaker like CaD314, that could be upward of 20 or 30. That gets expensive very, very rapidly, especially for tallow soaps, which have special restrictions due to BSE and scrapie considerations. You must also have each fragrance certified independently and get an allergen declaration; there are several fragrance manufacturers who don't wish to part with that information, so that can become very difficult very quickly.
After that, you must have an agent in the EU to serve as the responsible party and importer. That means that they take on the legal responsibility in case anything goes wrong. Tough to find, especially if you're a smaller company. Most importers are gun shy about taking on the legal problems of a foreign manufacturer, though there are some who will do it.
Finally, you have to ship the stuff. Darn difficult to get an alcohol-based aftershave across the Atlantic, but it can be done. Expensive, though. And what happens if you're simply not familiar with the legal system in the EU, as many American soap manufacturers aren't? I'm a trained attorney and I'm in no way comfortable navigating the European legal system. My best friend happens to be quite well versed in international commerce law (and she's partly doing the work to get some of our products certified for sale in the EU), but, for anyone else, they'd have to hire an attorney, which can rapidly become a very expensive and time-intensive endeavor. To many American artisans, it's not worth it, and I can certainly understand their position.
Then you have to get the base certified for every single product. Each scent is regarded as a separate product, and so must be certified separately. For some manufacturers, that could be 5-10 soaps. For a very prolific soapmaker like CaD314, that could be upward of 20 or 30. That gets expensive very, very rapidly, especially for tallow soaps, which have special restrictions due to BSE and scrapie considerations. You must also have each fragrance certified independently and get an allergen declaration; there are several fragrance manufacturers who don't wish to part with that information, so that can become very difficult very quickly.
After that, you must have an agent in the EU to serve as the responsible party and importer. That means that they take on the legal responsibility in case anything goes wrong. Tough to find, especially if you're a smaller company. Most importers are gun shy about taking on the legal problems of a foreign manufacturer, though there are some who will do it.
Finally, you have to ship the stuff. Darn difficult to get an alcohol-based aftershave across the Atlantic, but it can be done. Expensive, though. And what happens if you're simply not familiar with the legal system in the EU, as many American soap manufacturers aren't? I'm a trained attorney and I'm in no way comfortable navigating the European legal system. My best friend happens to be quite well versed in international commerce law (and she's partly doing the work to get some of our products certified for sale in the EU), but, for anyone else, they'd have to hire an attorney, which can rapidly become a very expensive and time-intensive endeavor. To many American artisans, it's not worth it, and I can certainly understand their position.
“You could leave life right now. Let that determine what you do and say and think.” – Marcus Aurelius
Fine grooming products at Barrister and Mann.
www.barristerandmann.com
Fine grooming products at Barrister and Mann.
www.barristerandmann.com
