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I apologise for the preaching nature of this post. I'm kicking this potential hornet's nest in the hope that it may encourage positive outcomes, as crazy as it sounds.
I will preface this by saying that the way in which the artisan 'movement' has expanded our choice and voice has been fantastic. When I first began to explore soap and aftershave in 2011, forum discussions were often about reformulations or discontinuations of favourite shaving soaps. (I never did get hold of a Sir Irisch Moos stick). Thankfully, today's small-scale soapmakers care about their customers, their products, and their craft. That is a truly good thing.
But I have concerns as to another recent development. Namely, the recent spate of EU-based distributors of non-compliant cosmetics (particularly American artisan soaps) who are breaking EU and UK laws to profit from supplying niche and artisan shaving products. This business practice is either negligent or exploitative.
You can read the documentation at your leisure:
Regardless of one's political views on the EU, profiting financially through bypassing the law is wrong. It may well be expensive for small businesses to ensure compliance. It may be bureaucratic. It may stifle entrepreneurialism. But it is legislation that these vendors are meant to be accountable to. Soap producers like Nanny's, Wickham, Calani, Faena et al all have to comply. Distributors also have to ensure that the lines they stock comply. I won't name-and-shame those that do not. It is too obvious to be necessary. Gifts & Care, Connaught, and Gallant & Klein are among many who do. Significantly, Retro Grooming chose to dissolve rather than compete for market share illicitly.
You may well note that there are many long-standing vendors who have withheld from stocking non-compliant cosmetics. Is this a stunning lack of business acumen on their part? Of course not. They know that achieving compliance from most non-EU soapmakers is a) unprofitable, b) impractical, or c) impossible. They also hold principles that mean that they won't pursue unlawful commercial activities. Others, however, have grasped the nefarious opportunity left by this 'gap in the market'.
Some may advance an irrelevant (and likely flawed) 'free market' argument. For many, the issue will inevitably come back to this: 'If I enjoy x soap then what's the harm?'. These vendors are hardly living it up in ivory towers and lathering virgins' tears with unicorn hair brushes for their own daily shaves. But I disagree with those who assuage their conscience by denying injury and/or victim. I appreciate that ethics are personal and that this is a complicated picture. Perhaps it'll be made simpler if and when soapmakers and vendors (past, present or future) choose not to make or supply because it would mean sharing a market with others who contravene the law to get a competitive advantage? Then again, I realise that there will be a vocal minority who couldn't care less whether their money goes to Help the Aged or Idi Amin so long as they aren't inconvenienced.
Ultimately, buying non-compliant soap and cosmetics for personal use doesn't compromise anybody's ethics. NB: There is a distinction between buying a non-compliant product from an EU-based importer and buying directly from the maker. But to run a business selling products that breach the law is fairly repugnant.
Ideally, these persons will quickly seek to a) certify their stock and achieve compliance, and b) cease trading in non-compliant goods. That is not unreasonable. Hopefully, most consumers will redouble their efforts to support responsible businesses.
Over and out.
I will preface this by saying that the way in which the artisan 'movement' has expanded our choice and voice has been fantastic. When I first began to explore soap and aftershave in 2011, forum discussions were often about reformulations or discontinuations of favourite shaving soaps. (I never did get hold of a Sir Irisch Moos stick). Thankfully, today's small-scale soapmakers care about their customers, their products, and their craft. That is a truly good thing.
But I have concerns as to another recent development. Namely, the recent spate of EU-based distributors of non-compliant cosmetics (particularly American artisan soaps) who are breaking EU and UK laws to profit from supplying niche and artisan shaving products. This business practice is either negligent or exploitative.
You can read the documentation at your leisure:
- EU - Cosmetics Regulation ((EC) No. 1223/2009): http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:342:0059:0209:en
DF - UK - Cosmetic Products Enforcement Regulations 2013: http://www.legislation.gov.uk/uksi/2013/1478/made
- CTPA provide a digest: http://www.ctpa.org.uk/content.aspx?pageid=423
Regardless of one's political views on the EU, profiting financially through bypassing the law is wrong. It may well be expensive for small businesses to ensure compliance. It may be bureaucratic. It may stifle entrepreneurialism. But it is legislation that these vendors are meant to be accountable to. Soap producers like Nanny's, Wickham, Calani, Faena et al all have to comply. Distributors also have to ensure that the lines they stock comply. I won't name-and-shame those that do not. It is too obvious to be necessary. Gifts & Care, Connaught, and Gallant & Klein are among many who do. Significantly, Retro Grooming chose to dissolve rather than compete for market share illicitly.
You may well note that there are many long-standing vendors who have withheld from stocking non-compliant cosmetics. Is this a stunning lack of business acumen on their part? Of course not. They know that achieving compliance from most non-EU soapmakers is a) unprofitable, b) impractical, or c) impossible. They also hold principles that mean that they won't pursue unlawful commercial activities. Others, however, have grasped the nefarious opportunity left by this 'gap in the market'.
Some may advance an irrelevant (and likely flawed) 'free market' argument. For many, the issue will inevitably come back to this: 'If I enjoy x soap then what's the harm?'. These vendors are hardly living it up in ivory towers and lathering virgins' tears with unicorn hair brushes for their own daily shaves. But I disagree with those who assuage their conscience by denying injury and/or victim. I appreciate that ethics are personal and that this is a complicated picture. Perhaps it'll be made simpler if and when soapmakers and vendors (past, present or future) choose not to make or supply because it would mean sharing a market with others who contravene the law to get a competitive advantage? Then again, I realise that there will be a vocal minority who couldn't care less whether their money goes to Help the Aged or Idi Amin so long as they aren't inconvenienced.
Ultimately, buying non-compliant soap and cosmetics for personal use doesn't compromise anybody's ethics. NB: There is a distinction between buying a non-compliant product from an EU-based importer and buying directly from the maker. But to run a business selling products that breach the law is fairly repugnant.
Ideally, these persons will quickly seek to a) certify their stock and achieve compliance, and b) cease trading in non-compliant goods. That is not unreasonable. Hopefully, most consumers will redouble their efforts to support responsible businesses.
Over and out.
