This time of year, I get a lot of inquiries to make commercial natural sunscreens or to help others make their own for personal use. My official position and other thoughts on this are as follows:
Yes I do make sunscreens for myself and fully accept the risk, but I don’t make them for commercial use. I am not paying thousands of dollars or jumping through the many legal hoops and regulations to get a product like this to market. I am also hesitant to endorse many of the popular ingredients mentioned on social media. And, just to be clear, I am not writing this piece to promote, discourage or evaluate the performance of natural or chemical ingredients which are typically used; rather the legal issues and financial burden which may fall upon your shoulders should you make such a product for other people.
According to Health Canada, these types of products are classed under a regulated category of cosmeceuticals. There is a short list of ingredients which the government approves for use, and most are not natural. Some are controlled substances which require a licensed facility to actually purchase the ingredients and then produce the product; much like the dandruff shampoo or bug repellent industry. There are a few ingredients which are more natural including zinc and titanium dioxide, but you must know how to formulate them and testing is still required.
Studies are required to prove the safety of your product using one or more of these approved ingredients. This in itself is quite costly. Then there is liability insurance. With the booming skin cancer industry, you could be a target for someone’s wrath. Even many basic product liability insurance policies require an extension to include products like this, so make sure you are covered.
If you market any product with claims towards sunblock, sunscreen, sun protection etc., it falls under this category even if you are making it for a small group of customers or friends and family. All sunscreen products sold in Canada are to be registered and have a declared SPF (sun protection factor) which must be supported through studies and trials. Failure to do so invites the microscope of Health Canada. Don’t think you can get away with some cutesy ambiguous name for your product. If there is even a hint of intent, HC will begin to scrutinize your website, Facebook, promo material or even customer comments to determine your product’s fate. This can have wide ranging implications for yourself and business.
If you are attempting to create one which is more natural for yourself, then at least stick to the ingredients which HC has approved (titanium and zinc oxide) and learn how to formulate them properly with adequate amounts. A lot of information circulates the internet about what to use, but these ingredients are mostly untested and unrated with only anecdotal stories to justify use. To post information or recipes for the DIY crowd on the internet about a common ingredient such as coconut oil, raspberry oil or myrrh oil as valid sunscreen is just plain irresponsible and opens you to legal action from many directions. Do you think that the people posting this stuff are going to leap to your defense and pay legal costs?
In my courses, I do allude to traditional uses dating back to ancient time for some of these items from an educational point of view and nothing more. I also indicate that you are not to use these in commercial sunscreens. Just because you’ve had success using some pulp from a yellow fruit found only in the Amazon mixed with the sweat of a purple iguana which was posted on social media does not mean that Health Canada will agree; and there in lies the rub, or should I say burn?
Enjoy Your Summer
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