Natural Cosmetics: A Best Practice Checklist for Formulators in South Africa

Part 1: Chain of Integrity

South Africa's cosmetic regulatory regulations aim to ensure that cosmetic products placed on the market are safe for human use and do not pose any health risks. When formulating natural products it is important to consider your sourcing, production methods, branding and labelling.

Cosmetic Advertising Code of Practice - South Africa 2022

1. Understand Regulations
   • Familiarise yourself with the South African cosmetic regulations, including labelling requirements, product registration and prohibited ingredients. South African Department of Health and the Cosmetic, Toiletry, and Fragrance Association (CTFA) and SAHPRA
2. Source High-Quality Natural Ingredients
   • Research and find reputable suppliers of natural ingredients. Essentially Natural has an extensive range of all-natural ingredients.
   • Ensure ingredients are ethically and sustainably sourced.
   • Consider using locally sourced ingredients when possible.
3. Develop Safe and Effective Formulas
   • Educate yourself on natural ingredient properties, interactions, and preservative systems.
   • Create formulas that are free from synthetic fragrances, parabens, sulfates, and other controversial ingredients.
   • Test formulas for stability, efficacy, and safety.
4. Invest in the Right Equipment
   • Acquire the necessary equipment for formulating, such as scales, pH meters, and mixing tools.
   • Ensure proper sanitation and storage conditions for raw materials and finished products.
5. Establish a Proper Manufacturing Process
   • Set up a dedicated workspace or manufacturing area.
   • Implement Good Manufacturing Practices (GMP) to ensure product quality and safety.
   • Develop standard operating procedures (SOPs) for each product.
6. Packaging and Labelling
   • Choose eco-friendly and sustainable packaging options.
   • Design attractive and informative labels that comply with South African regulations. (See below for tips)
   • Include clear instructions for use and ingredient lists.
7. Product Testing and Certification
   • Conduct stability and allergy testing and efficacy evaluations for your products.
   • Consider obtaining certifications for natural or organic products, such as ECOCERT or BDIH.
8. Marketing and Branding
   • Develop a strong brand identity that resonates with your target audience and your 'natural' values.
9. Continuous Education and Improvement
   • Stay updated with the latest trends, research, and regulations in the natural cosmetic industry.
   • Continuously refine and improve your formulas based on customer feedback and industry developments.
10. Seek Professional Advice
    • Consider consulting with cosmetic chemists, regulatory experts, or industry associations for guidance and support.
    • Collaborate with other small businesses in the natural cosmetic industry to share knowledge and best practices.

Formulating natural cosmetics requires diligence, attention to detail, and a commitment to safety and quality. By following this checklist, you can establish a solid foundation for your small business in the natural cosmetic industry in South Africa.

Part 2: Labelling

When labelling natural cosmetic products in South Africa, it's crucial to follow the guidelines set by the relevant authorities. Here are some specific points to consider:

What Should Be on the Label:

1. Language: Labels should be in English. (Other languages can be used, but English must be the primary language.)
2. Product Name: Provide an accurate and descriptive name for the product informing the consumer of exactly what is in the packaging.
3. Ingredient List: List all ingredients in descending order of concentration, using the International Nomenclature of Cosmetic Ingredients (INCI) names.
4. Net Contents: Clearly state the net weight or volume of the product in metric units.
5. Batch Code: Include a batch code or lot number to ensure traceability.
6. Manufacturer Details: Provide the name and physical address of the manufacturer or the responsible person within South Africa. Include one of the following statements: "Product of [insert country of origin]" if all ingredients are from that country, or "Produced in [insert country of origin]" if the ingredients used are from a different country than the country in which the products were manufactured.
7. Expiry Date or Period After Opening (PAO): Indicate the expiry date or the period after opening (PAO) symbol, along with the number of months the product can be used safely after opening. The date of minimum durability must be clearly expressed and must consist of either the month and year or the date, month and year, in that order.
8. Warnings and Instructions for Use: Include any necessary warnings (e.g., "Avoid contact with eyes") and instructions for safe and proper use. List known allergens.
9. Product Claims: Any claims made on the label, such as "natural" or "organic," must be substantiated and comply with relevant regulations.
10. Certifications (if applicable): If your product is certified as natural, organic, or by any other recognized certification body, display the relevant logos or seals.
11. Typography

• The product name must be printed in type equal to or greater than 4mm in height
• A description of the product must appear in the same size, font and prominence as the name
• Storage instructions must be printed in type equal to or greater than 3mm and in bold capitals
• All other info must be printed in type equal to or greater than 1mm in height

Note: According to No. 41351 GOVERNMENT GAZETTE, 22 DECEMBER 2017 If a package is too small or has a shape that precludes labelling with information mentioned in sub-regulation (1)(f) and (1)(h), the information shall be mentioned-

• on an attached leaflet, label, inlay, tape, tag or card;
• by abbreviated information or symbol

In the case of soap, bath balls and other small products, where it is impossible for practical reasons for the information to appear on a leaflet, label, inlay, tape, tag or card, the information shall appear on a notice in immediate proximity to the container in which the cosmetic product is exposed for sale.

What Should Not Be on the Label:

1. Misleading or Exaggerated Claims: Avoid making claims that cannot be scientifically substantiated or that may mislead consumers. Any image of a product contained in packaging may not be misleading as to its content
2. Undisclosed Ingredients: All ingredients must be listed, and no ingredients should be omitted or hidden.
3. Prohibited Ingredients: Do not include any ingredients that are prohibited or restricted by South African cosmetic regulations, such as certain preservatives, colorants, or fragrances. SAHPRA maintains a list of prohibited and restricted substances that cannot be used in cosmetic products due to potential health risks.
4. Therapeutic Claims: Unless your product is registered as a medicine or therapeutic good, do not make any claims related to the treatment, prevention, or cure of diseases or medical conditions.
5. Inappropriate Language or Imagery: Refrain from using language or imagery that could be considered offensive, discriminatory, or unsuitable for the intended audience.

Notes: Cosmetic Advertising Code of Practice - South Africa 2022

• A cosmetic product can be claimed to be "Natural" or "Naturally Occurring" only if its content is of natural origin as prescribed by the definitions contained in SANS 16128-1 and SANS 16128-2, or any other internationally accredited equivalent standard.
• Claims for organic products or ingredients must be substantiated that they contain ingredients from organic farming, as prescribed by the definitions in SANS 16128-1 and SANS 16128-2, or any other internationally accredited equivalent standard.
• Companies should also be transparent to consumers and not imply that this type of product is safer than other cosmetics just because they make 'natural' or 'organic' claims.
• Use of the word "Pure" requires substantiation and the ingredients referred to shall be of a cosmetic grade or higher.

It's essential to follow the labelling requirements set by the South African Department of Health and the Cosmetic, Toiletry, and Fragrance Association (CTFA) and the Cosmetic Advertising Code of Practice - South Africa 2022 to ensure compliance and protect consumer safety. If you have any doubts or specific questions, it's recommended to consult with a regulatory expert or seek guidance from the relevant authorities.

Part 3: Branding and Labelling

Here are some labelling tips to help you create attractive yet compliant designs for your natural cosmetic products in South Africa:

1. Use Clear and Legible Typography:
   • Choose a simple, easy-to-read font for the product name and other important information.
   • Ensure sufficient contrast between the text and background colours.
   • Consider using a larger font size for the product name and a smaller size for other details.
2. Incorporate Your Brand Identity:
   • Use your brand's colour palette and logo consistently across all product labels.
   • Develop a recognisable design style that aligns with your brand's personality and values.
3. Highlight Key Selling Points:
   • Emphasise the natural, organic, or eco-friendly aspects of your products through visuals or callouts. Subject to Cosmetic Advertising Code of Practice - South Africa 2022
   • Use icons or symbols to represent important features, such as "cruelty-free" or "vegan."
4. Leverage High-Quality Imagery:
   • Include appealing product photographs or illustrations that showcase the texture, colour, or ingredients.
   • Ensure that any imagery used complies with regulations and does not make misleading claims.
5. Organise Information Effectively:
   • Group related information together, such as ingredients, usage instructions, and warnings.
   • Use hierarchy and spacing to create a visually appealing and easy-to-navigate layout.
6. Consider Multilingual Labeling:
   • If targeting a diverse consumer base, provide information in multiple languages commonly used in South Africa, but remember that English is the required language.
   • Ensure accurate translations and follow any specific language requirements outlined by regulations.
7. Try Incorporating Eco-Friendly Materials:
   • Use sustainable and recyclable materials for your labels, such as paper or plant-based plastics.
   • Avoid excessive packaging or materials that may harm the environment.
8. Comply with Mandatory Information:
   • Prominently display all required information, such as the product name, ingredient list, net contents, and manufacturer details.
   • Ensure that mandatory information is clearly visible and not obscured by design elements.
9. Seek Professional Design Assistance:
   • Collaborate with a graphic designer or label design specialist to create visually appealing and compliant labels.
   • Ensure the designer is familiar with the specific labelling regulations for natural cosmetics in South Africa.
10. Regularly Review and Update Labels:
    • Stay informed about any changes in labelling regulations or industry standards.
    • Update your labels accordingly to maintain compliance and accurately reflect your product formulations.

Remember, while aesthetically pleasing labels are important for attracting customers, compliance with regulations should always be the top priority. By following these tips, you can create attractive and informative labels that meet both design and legal requirements in the South African natural cosmetic industry.