“Hand-made manufacturing” of cosmetics

From 1 May 2021 (the expiry of the transition period for the 2017 Swiss Food Law), a Product Information Document (PID) including a safety report must be created for all cosmetics. The work required, in particular for the creation of the safety report, is considerable. Furthermore, there are very strict requirements for the author of the safety report, with the result that outsourcing is required for practically all smaller manufacturers. There is an exception from this obligation for hand-made products and local, small-scale distribution of cosmetics (VKos, Art. 1, para. 3). In the Information letter 2020/8 from the Federal Food Safety and Veterinary Office (BLV) from 18 December 2020, it is once more clearly explained that this interpretation is extremely narrow. Only school fairs and bazaars (one-off) are covered. If a “self-made” cosmetic is sold through a shop, an online shop or a single small boutique, this is enough for the extensive obligations of the PID and safety report to apply. How this can be implemented in practice, or whether all non-industrially manufactured cosmetics must disappear from the market, only the future will tell.