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Posted by Gillian Kenyon, Sep 14 2010 12:52PM

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Making your own Aromatherapy products

I recently receibved an enquiry relating to how to go about making and marketing Aromatherapy products for the public.

It seems that not only do Cosmetic Regulations now have to be taken into account, but also, the regulatory process may now have potential catastrophic effects on what Aromatherapy product makers can put on their labels, literature and web-sites in relation to their products.

It is difficult to argue with the MHRA’s rationale for protecting public health by restricting S12(1) to those on the statutory register when herbalists attain statutory regulation and are recognised in law as healthcare professionals. But this does not help Aromatherapists, who, by current definitions, are not Herbalists.

The THMPD is part of European Medicines Law and will regulate herbal drugs by the end of the transitional period on 30 April 2011.

MHRA are saying in their consultation documents that you cannot have regulated herbalists with the regulated products that they use and then allow anyone else to do the same thing.

The responses to the MHRA consultation documents would in the main appear to endorse this position.

The Herbal Medicines Advisory Committee (HMAC) which was set up to give Ministers and the MHRA independent expert advice on the THMPD, strongly supported the recommendations for statutory regulation of herbalists under the Reform of S12(1).

Although there is a high degree of professional self-regulation of the aromatherapy profession including the National Occupational Standards for Aromatherapy and the Aromatherapy Council’s Core Curriculum, it is difficult to see how there could be special exemptions even for a recognised voluntary self-regulated body since there is no way this could be enshrined in law.

In short, Aromatherapists will no longer be able to make any claims about health benefits for their products. Insurers will thus not allow you to marklet your products as anything more than nice smelling things even if you do manage to get them all tested in accordance with legislation
Amanda Clegg
Sep 14 2010 1:16PM
Bit of a bummer this! Yes I agree there have to be consumer safeguards, but it's all getting a bit too nanny-state!

Don't forget, you can sell preparations to your clients provided you have had a face to face consultation with them. I don't do this very often, but when I do I use ready-made base products from Absolute Aromas or Essentially Oils, and whilst I only label them with the date, use by and the client's name, of course we discuss the contents!
Gillian Kenyon
Sep 14 2010 3:34PM
Amanda

Great to hear from you again - you are quite right to poitn this out. However, please be aware - according to the legislation, you still will NOT be allowed to make any claims or to infer and health benefits in using these products - event to your clients.

This is why so many of the companies who used to just sell 100% essential oils are now starting to sell tested, blended product for specified purpose.

I think this was foreseen by many of the 'Professional Bodies/Affinity groups' some time ago. That is why so many Aromatherapy Courses with pre-blended oils suddenly got launched.

Shame they didn't alert us all to what they saw coming.
Lynda Shepherd
Jan 17 2011 1:49PM
Hi,
I've only just come across this post and am interested in it as I have spent a lot of time trying to develop aromatherapy products to sell. I had initially contacted the CThA last year, with regard to the making and selling of these products, and was told that as long as my labelling included all ingredients, cautions and batch numbers, etc, then I was ok to proceed.

This news is very confusing for me and I'm now unsure how to go from here. As far as I can tell from your very thorough information, I would be able to sell, for example, hand cream containing essential oils as a fragrant cream, but not an oil which claimed to relieve aching muscles or a cream which claims to treat spots.

Does anyone have any more information on this subject and are there relevant websites or institutions that I should be contacting?

Many thanks,

Lynda.
Amanda Clegg
Jan 17 2011 6:46PM
|Hi Lynda

yes that's about it: a fragrant cream for no specific purpose! Ho hum. Mind you, who can police what may be discussed verbally, as long as you know your clients?
Amanda Clegg
Jan 17 2011 6:50PM
hit post too soon!

Of course you have to couch it in vague terms of 'might' or 'anecdotal evidence to suggest it may...' and of course avoid words like cure, relieve pain etc. You could say ' may possibly support

BTW - nice to hear from you again Gill. what's happened to your pic - you look a little squashed! :)
Lynda Shepherd
Jan 18 2011 6:43PM
Many thanks for your quick response, Amanda.

Sorry to keep going on about this but I'm still in the dark about a couple of points.

I was hoping to sell to the general public using blends of safe oils and provide all relevant safety data with each product. I was under the impression that this was allowable as companies such as Lush and Neil's Yard, (to name but a few), sell many products containing essential oils, not to mention the perfume industry.

However, I see mentioned under this topic that a face to face consultation is required before a blend can be sold on. Do you know if this is the case only with respect to the treatment of medical conditions or does this apply to selling a hand or body cream too?

I hope I'm not waffling on too much and confusing the issue. I've thought about contacting Trading Standards to see if they'd have any guidelines regarding this.

Any advise appreciated.

Lynda x
Amanda Clegg
Jan 18 2011 9:24PM
No - it's only 'untested' products - ie blends prepared by a qualified aromatherapist for one particular client. If you are making commercial blends to sell to the public then yes, you do have to get all the requisit tests done on each one. Essentially Oils have a lab testing service which I believe isn't too expensive and is based upon their base products which they obviously know are ok to blend with essential oils. Aromatherapy council are quite helpful with info about percentage amounts of particular oils that you can use safely. I've not gone into it in any more detail as I decided it wasn't worth trying to find the capital to proceed. I'd be happy to consider selling your products for you if you do get off the ground! Keep us posted, and best of luck.
Amanda Clegg
Jan 18 2011 9:26PM
Sorry, didn't answer fully: even with commercially tested products you still won't be able to make any health claims unless you do go down the full medical testing route which frankly is pretty impossible for our type of product. Frustrating. Again, Aromather. coun. has guidelines on labelling I think, and Trading Standards also would be good to talk to.
Lynda Shepherd
Jan 25 2011 11:53AM
Sorry Amanda, I didn't see your very helpful reply until today. My email decided not to alert me to it!

I will definitely keep you posted on any progress (if any), that I make. I've just sent an inquiry to the Aromatherapy Trade Council which seems to offer advice on this topic.

Lynda x
Julie Egginton
Jul 17 2011 11:42AM
www.aromantic.co.uk run courses on how to make cosmetic products from scratch, one of which is around legal and labelling requirements if you intend selling your products as a retailer direct to the public (like Lush and NYR do). They also provide contacts to get products safety tested.

Hope this helps.
Lynda Shepherd
Jul 17 2011 12:04PM
Great, Julie, thank you.

Lynda
Amanda Clegg
Jul 18 2011 8:28AM
yes I think aRomantics courses look really good. BYW, EssentiallyOils have ceased trading. I found similar base products for private blending at Essential Oils Direct. Don't know yet if they have the same testing facilities that EO used to have - 4got to ask!

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