Trading Standards have been contacted by several companies wishing to produce a range of products that would assist in the COVID-19 pandemic. We have produced the guidance on this page for businesses considering making or importing hand sanitiser.
We also advise businesses to think carefully about purchasing such products and to check the legitimacy of any products and test certificates.
The Office for Product Safety and Standards (OPSS) guidance Placing hand cleaning and sanitising products on the UK market explains that a product can fall under three requirements depending on the intended use (Cosmetics, Biocides and Medicines).
If you are manufacturing or importing a product that has the primary intended use of cleaning, conditioning or protecting the skin, you should consider the Cosmetic Products Regulations.
See the Cosmetics, Toiletry and Perfumery Association (CTPA) guide COVID-19: Advice for the Cosmetics Industry.
The CTPA are also offering an exchange scheme for manufacturing needs.
Biocides and Medicines
Biocides and medicines are products claiming to kill germs, disinfect or sanitise. Most hand sanitisers with a primary use of sanitising will fall under Biocides. The HSE is the National Competent Authority for assessing the safety of biocides production. Its guide Manufacture and supply of biocidal hand sanitiser products during the coronavirus outbreak also explains about Medicines and pharmaceutical preparations that make a medical claim.
For advice on what to do if you are already producing hand sanitiser or are considering changing your alcohol distillery to this type of production, see GOV.UK – Producing hand sanitiser and gel for coronavirus (COVID-19).
Pricing and weights and measures
All products should be clearly labelled with the quantity of the products. The price should reflect the general principles of good faith, as we have received complaints about excessive prices being charged. For more information see:
- GOV.UK – COVID-19: sales and pricing practices during Coronavirus outbreak
- GOV.UK – CMA COVID-19 taskforce.
Any claim that does not meet the requirements of the appropriate legislation may give rise to criminal offences.
We encourage all producers and distributors to carefully consider the Advertising Standards Authority guidance on advertising responsibly and to ensure any claims made (including medicinal) are fully substantiated.
You can find more information on common trading standards issues in our free self-help business advice guides.
For regular updates on a wide range of business matters that will be of use to both employers and employees, see Heart of the South West Growth Hub COVID-19 support for business.