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CNF Updates: Into or Out-of-the-Pot??

cnf Jul 30, 2019

Original Release Date: May 29, 2019


Just a quick note on ingredients for your saponified products...

It seems like every person does their CNF 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 have told me directly that we should be 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 or Potassium Olivate in this case, and including the resulting glycerin from the reaction. Sodium or potassium 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.




Edited To Add: I've heard from other makers that HC is still allowing both into and out-of-the-pot, so it's up to you which way you choose to submit. Or, you can contact HC directly to get confirmation that the way you choose to submit is acceptable. I teach out-of-the-pot as that's what I was told directly from my HC rep here 😊



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." 


Need more help prepping for your CNFs? Download our free CNF Help workbook now for help organizing all your data and info in one easy place so submitting your CNF's will be a breeze!


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