Hey there,
Just wanted to pass on some updates to you as I've been receiving them from Health Canada.
It seems like every person does theirs a little differently, but I was of the opinion that both the CNF and labels should list your ingredients as they go 'into-the-pot'. Ie. Olea Europaea (Olive) Fruit Oil and Cocos nucifera (Coconut) Oil.
However, as of speaking with Health Canada, they want to move toward listing the final ingredients in products that include a chemical reaction, like soapmaking.
This means that instead of Olea Europaea (Olive) Fruit Oil, you would be listing the saponified version of each oil, Sodium Olivate in this case, and including the resulting glycerin from the reaction. Sodium hydroxide remains excluded as it doesn't appear in the final product.
As such, I will be sharing more information on how to figure out the final ingredients in soaps, but all other products (bath bombs, lotion, etc) can still be entered the same way as before.
Ah well, off to amend my own CNF and labels now haha. To everyone who has purchased my CNF Help ebook, I will be updating it with this new knowledge and will send you all the updated version so you can make your own updates.
Thanks!
Jess
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I've also included the original email from the Product Safety Officer I spoke with at HC here for your reading pleasure:
"Any ingredient that is used in the preparation of the cosmetic but which is not found in the final product as a result of the chemical process should not be listed in the ingredients. However, you must list the ingredient which results from that reaction.
Incidental ingredients should not be declared on the notification form nor on the label of the product. Incidental ingredients are any processing aid added and removed or converted to a declared ingredient, or any ingredient of another ingredient or processing aid either not present at all in the finished product or present at an insignificant level and having no technical or functional effect.
All ingredients present in the finished product must be declared in the ingredient list on the label and on the Notification form."
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If you're ready to jump in and tackle these forms with confidence and clarity, check out our CNF101 online masterclass. We'll guide you step by step through the entire process with videos and screen recordings! Enrollment is open now and the course will launch July 2019!! Click here for details.
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Hey Kitty,
Yes, you’re right. I was also of the same opinion and used into-in-pot labelling for a long time, but if that’s what HC wants, then we don’t have much choice haha.
Some things you can do are have an into-the-pot ingredients list on your website listings, and you can talk more about the raw ingredients you use (like olive oil) on your website or social media.
Thanks for your comment and hope that helps,
Jess
This is actually somewhat disappointing, in terms of labelling. I’ve found “Olea Europaea (Olive) Fruit Oil” sounds much better to the average consumer than “Sodium Olivate”. At least the first one specifically says (Olive) and has the words “fruit oil” so even if people haven’t heard of INCI they can usually puzzle it out and understand it’s olive oil. I preferred in-the-pot labelling for this reason.