The Handcrafted Soap and Cosmetic Guild (HSCG) is a non-profit trade association for small businesses handcrafting soaps and cosmetics and the handcrafted soap and cosmetic industry as a whole. The HSCG works to provide legislative advocacy for all soap and cosmetic handcrafters at both the state and federal level.
The handcrafted soap and cosmetic industry is a comprised of small microbusinesses. These microbusinesses are largely women-owned companies (over 95%) that average 1-3 employees. While the size of each handcrafted soap and cosmetic microbusiness is quite small, the number of these companies well exceeds 250,000 nationwide and industry-wide employment estimates are over 750,000.
The HSCG supports current cosmetic legislation that makes it illegal to manufacturer an unsafe, adulterated or misbranded product and agrees with the FDA and other industry experts that U.S. manufactured cosmetics are among the safest consumer products sold in the United States.
The HSCG is deeply committed to supporting the FDA’s efforts in substantiating safe cosmetic ingredients. If an ingredient is not safe, handcrafted soap and cosmetic businesses want to know and will not use it in their products.
Handcrafted soap and cosmetic businesses do not invent new ingredients. These microbusinesses blend already deemed safe ingredients to make small batches of custom, handcrafted products. The vast majority of ingredients used by handcrafted soap and cosmetic microbusinesses are food grade and can be found in any grocery store.
At a Federal level, the HSCG monitors for legislation that could affect the handcrafted soap and cosmetic industry and has been working to make our industry known. We are becoming recognized stakeholders in matters concerning the handcrafted soap and cosmetic industry.
Mary Ann Walsh, of Walsh Capitol Consulting, has been retained to represent the HSCG in Washington, DC. Part of our strategy has included several visits to DC to meet with Members of Congress who are, will be, or could be active players in any future legislation. Our goal is to educate them on the issues facing our industry and our position regarding potential cosmetic legislation.
The HSCG is a member of the Handmade Cosmetic Alliance (HCA).
The HSCG considers that it is likely that new cosmetic legislation will be introduced sometime in 2013. In order to accomodate the many handcrafted soap and cosmetic microbusiness, our position is that the following provisions should be included in any new cosmetic legislation:
- Establishment of the definition of "microbusiness" as "a small business which, together with affiliates, has average annual gross receipts of two million five hundred thousand dollars ($2,500,000) or less over the previous three years, or is a manufacturer with 25 or fewer employees." The State of California, in 2012, under Governor Arnold Schwarzenegger, codified this definition of microbusiness.
- Exemption of small manufacturers that meet the microbusiness definition from facility registration to a publicly accessible FDA data-base. With most handcrafted soap and cosmetic companies operating from a personal residence or in a separate structure located adjacent to the business owner's home, registering the address presents serious safety issues for the owner and their families.
- Exemption of small manufacturers that meet the microbusiness definition from registration fees. A registration fee creates a barrier for entry into the market and impedes growth opportunities for these emerging small businesses.
- Exemption of small manufacturers that meet the microbusiness definition from registering each batch, each supplier change, and company secrets. Handcrafted soap and cosmetic companies produce small batches of custom products and purchase ingredients as orders are placed. In a given month a handcrafted soap and cosmetic business, producing a mere 100 batches, could easily have well over a 5000 product and ingredient filings. Without an exemption, microbusinesses would be overwhelmed with paperwork and the FDA would be buried in filings.
- Requiring the FDA to maintain a publically accessible data-base identifying safe and unsafe ingredients, including common and nomenclature names. This data-base will facilitate labeling compliance for all cosmetic manufacturers and provide consumers full access to ingredient safety.
Regulations are the implementation of any legislation passed by Congress and approved into law. The process for implementing new regulations or changing existing regulations is lengthy and detailed and has many opportunities for input from concerned parties. The HSCG monitors potential regulation changes or implementations and provides input when needed to ensure that the needs of our industry are addressed.
In August 2012, the HSCG submitted a Citizen Petition to change the wording of the existing labeling regulations to allow a USPS Post Office Box in lieu of a street address on product labels. See the full details.
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