Making Cosmetics in Connecticut

Connecticut is one of the states that has permit, license, and inspection requirements for businesses that make cosmetics (officially called “cosmetic manufacturers”). While these laws and regulations have been on the books since at least 2009 (probably earlier), according to one person making handcrafted cosmetics they have only started to be enforced on small and handcrafted businesses within the last few years.

Permits and licensure are handled under the Connecticut Department of Consumer Protection, Drug Control Division. The Manufacturer of Drugs, Medical Devices and/or Cosmetics page has some additional information (not much) and a link to the application form. The application fee is $285 fee for manufacturers with 5 or fewer chemists; an inspection is required. The license must be renewed every year, with a new inspection and application fee.

There isn’t any information on the website about what the inspection entails, and I couldn’t find anything in the regulations or statutes. Since it is the same application form for drug, medical device, and cosmetic manufacturers, and it is unlikely that cosmetic manufacturers will be held to the same standards as drug manufacturers and compounders, I contacted them for clarification. 

In response, they provided me a document named “Cosmetic Information” which looks like the text they send prior to an inspection and a copy of the inspection checklist.

This is the complete content of that one-page document. “I”and “me” appears to refer to the inspector.

Please provide me several dates and times that are available for the inspection. I will be looking to:

  • Personnel are appropriately trained and are capable of performing and qualified to perform their assigned duties. Such training should be documented.
  • Compounding ingredients of the appropriate identity, purity, and quality are purchased from reliable sources and are properly stored according to manufacturer specifications or USP standards.
  • Bulk component containers are labeled with appropriate Occupational Safety and Health Administration (OSHA) hazard communication labels (see OSHA. gov), and Material Safety Data Sheets (MSDSs) are available to compounding personnel for all chemicals used in compounding.
  • All equipment used in compounding is clean, properly maintained, and used appropriately.
  • The compounding environment is suitable for its intended purpose; and procedures are implemented to prevent cross contamination.
  • Only authorized personnel are allowed in the immediate vicinity of the compounding operations.
  • There is assurance that processes are always carried out as intended or specified and are reproducible.
  • Compounding conditions and procedures are adequate for preventing errors.
  • All aspects of compounding are appropriately documented.
  • A Master Formulation Record should be created before compounding a preparation for the first time. This record shall be followed each time that preparation is made. In addition, a Compounding Record should be completed each time a preparation is compounded.
  • Compounding is done in an appropriately clean and sanitized area dedicated to this activity.
  • Only one preparation is compounded at one time in a specific workspace.
  • Appropriate compounding equipment has been selected and inspected for cleanliness and correct functioning and is properly used.
  • Documentation, written or electronic, enables a compounder, whenever necessary, to systematically trace, evaluate, and replicate the steps included throughout the preparation process of a compounded preparation. These records should be retained for the same period of time that is required under state law.
  •  The safety, quality, and performance of compounded preparations depend on correct ingredients and calculations, accurate and precise measurements, appropriate formulation conditions and procedures, and prudent judgment. As a final check, the compounder shall review each procedure in the compounding process. To ensure accuracy and completeness, the compounder shall observe the finished preparation to ensure that it appears as expected and shall investigate any discrepancies.
  • Finally there should be some method of tracking products that are sold to consumers and that may need to be returned to you due to manufacturing malfunctions.

These issues should be addressed in policy and procedures and should be available for review.

Good Manufacturing Practices

These guidelines appear to be based on basic Good Manufacturing Practices. If you are unfamiliar with general GMP guidelines, my book Good Manufacturing Practices for Soap and Cosmetic Handcrafters covers most of the points above. There are also a number of helpful posts under the category of Good Manufacturing Practices on this blog.

Good Manufacturing Practices cover

Every handcrafter’s situation is different. To work out the good manufacturing practices that will work for you, get my book from Amazon and use it.

Practical Experience

I spoke (by email) with a member of the Handcrafted Soap and Cosmetic Guild who has been through the annual permitting process in Connecticut. She had contacted the Department of Consumer Protection about 6 1/2 years ago when she started her business and was told that the permits weren’t required for businesses as small as hers, but that changed last year when they started to crack down on “anyone and everyone” making and selling products.

Her experience with the inspection was that it was pretty detailed, concentrating on GMP to ensure that the products manufactured would be safe and clean. She said that there was heavy emphasis on recall procedures, and a specific quarantine bin/cabinet (labeled as such and used for nothing else). They looked at her scales, checked her recipes, looked at batch records, and checked ingredient labeling and storage. In her case there were a few things that didn’t pass, but she was able to put them into place immediately and passed the inspection when they returned a few days later.

This handcrafter worked in a manufacturing studio in a commercial building. She reported that she knew of two cosmetic makers who work from home who were able to pass inspection, so there doesn’t appear to be a restriction against home-based manufacturing. However, she also said that each has a dedicated space that is not accessbile to outside guests, pets, or family members, and that the facilities (sink, fridge, etc.) can’t be used for anything other than production (so not working out of your kitchen).

In the Real World

What does it mean in the real world? Apparently, the State of Connecticut is getting creative on their enforcement. According to my sources, it’s becoming much more common for local stores to ask about licenses before buying and for managers of farmers’ markets to require proof of licensure for anyone vending cosmetics.

If you are in Connecticut and manufacturing cosmetics at any level, keep in mind that you are operating your business at risk if you haven’t gotten your permit and inspection and been approved.


59 responses to “Making Cosmetics in Connecticut”

  1. This is probably too specific of a question but I’ll give it a shot anyway. Do you need a license to sell if you are no longer manufacturing? I’m currently licensed and working out of an extra bedroom. I am letting my license expire this summer and turning my office back into a bedroom so my children can have their own bedrooms. Will I be able to continue to sell what I have left of my products after my license expires as long as I’m not producing new product?

    1. Marie Gale

      Generally, the license applies to MANUFACTURING, not SELLING. If your products will all have been manufactured while you had a license, then you should be fine to sell them.

  2. Hi. Thank you for the great information about starting a small business in CT. I think I just need to clarify this for myself so I am not mistaken but if I make soap in my basement and just label the ingredients of oil, lye and essential oils and just make sure I use the phrase soap then I do not need an inspection nor a license but I do need the LLC and tax info to sell? Also if I make homemade laundry soap do I then need a cosmetic license? Does that fall under the same pretense or do the ingredients make it a cosmetic?

    1. Marie Gale

      If you are not making cosmetics, then you don’t need to register in Connecticut. Soap, if it is lye/oil soap and is only marketed as “soap,” is not a cosmetic. Laundry soaps aren’t applied to the human body. So they aren’t cosmetics. Doesn’t matter what they are made of.

      The other stuff that applies to any business probably applies in Florida. You need to register with the state to collect (and turn in) sales tax. You need to register your business name (if you are doing business under a name different than your personal name). You don’t have to have an LLC, but if you want one, you can register that with the state. You’ll need the business registration to open a business bank account. You’ll need to make sure you keep track of your accounting, so you can correctly report your business income and expenses on your tax return. This page might help:

  3. Are Shower Steamers considered cosmetics as well? Similar to a bath bomb in CT?

    1. I believe that shower steamers are considered cosmetics.

      1. Amy Connery

        Thank you

  4. Elizabeth

    I too live in Connecticut and will only be doing soaps. My question is what information needs to be on the the labels?

    1. Marie Gale

      The label requirements for Connecticut are the same as for all states. See the Quick Labeling FAQ for the details. Information is covered in more detail in my book, Soap and Cosmetic Labeling (that’s a link to my page on Amazon) or on the FDA website.

  5. Hi, I wanted to start a sugar / salt scrub small business in CT , I’m a bit confused as to what a “cosmetic “ would be defined as ? Would scrubs be defined as cosmetics ? These are home based made items , no store, so I guess my confusion also comes with if it is a home based business what kind of inspection / license would I need ? And where on gods earth do I even find this information, for I can’t seem to find anything on scrubs ? Thanks for any responses

    1. Marie Gale

      Anything that is applied to the human body for the purpose of cleansing, improving appearance, or beautifying is a cosmetic. Scrubs, bath bombs, lotions, etc., are all cosmetics. See What is a COSMETIC? for a more detailed explanation.

  6. Una Luna

    Thank you for this blog. This is excellent guidance because DCP’S information is very cryptic although you have to pay the non-refundable $285 fee just to find out the details of the permit process. Do you know if you can set up your manufacturing space in an unused bathroom? I have three bathrooms, one of which would be solely dedicated for making cosmetics.

    1. Marie Gale

      Makes some sense in the bathroom—it probably has non-porous surfaces, running water and good ventilation!

  7. I have a cottage food license to make dried teas and also make facial teas (facial steams that go in boiling water for breathing in steam they don’t actually touch the skin). Would those be considered cosmetic or would I be able to sell them through my cottage food license since they aren’t applied to skin?

    1. Marie Gale

      I believe that a “facial steam” would be considered a cosmetic because the steam is being applied to the human body. You could check with the state to see if that’s the way they interpret it.

  8. Hi Marie, I’m looking to sell my homemade horse coat shine spray, would this have to be under the same cosmetic license or am I in a totally different category?

    1. Marie Gale

      A cosmetic, by definition, is “applied to the human body.” So something that is applied to animals is not a cosmetic. Just make sure that it clearly states “not for human use” or something similar. There were some issues in the past where “horse mane and tail” shampoo was being promoted for people too, and it was interpreted as a “cosmetic” by the FDA because of that.

  9. Hello

    Thank you for all the great information. I am making a sugar scrub at home with products used in the kitchen.I read the previous responses and I appreciate your help and the information. Must admit I am a bit discouraged. My question is can I make a product in my basement ? The page you shared refers to the manufacturing taking place in a room where no visitors or other people can enter. My basement is no longer visited by many since kids are out of the house but it does have exercise equipment etc. The manufacturing area is in a corner of the room but not separated by walls will this pass the inspection ?

    1. Marie Gale

      The most important thing about the space is that it must be clean and in an area in which the product is unlikely to become contaminated. If your basement is completely finished and has adequate ventilation (not outside windows as they can bring in dust), then it might pass. It really depends on what the inspector sees. They are looking for a space and procedures to ensure that the product will not be or become adulaterated.

  10. Can you sell bath bombs in CT? Do I need an inspection and permit to sell?

    1. Marie Gale

      Bath bombs are cosmetics. In Connecticut you need to get licensed as per this post.

  11. hi, i live in connecticut and i make soap with olive oil, coconut oil and lye + essential oils and micas. sometimes i use avacado oil, castor oil. do i need any certificate?
    secondly i am not selling my soaps yet but if i plan to sell me soaps online or in a store what licences do i need. if you can provide information
    for beginners like me. and links as well.

    1. and 3rd question. is there a training compulsion for soap making in CT?

      1. No. I would, however, suggest that you consider joining the Handcrafted Soap and Cosmetic Guild and get at least your basic soapmaker certification.

    2. If your soap is the alkali salt of fatty acids (lye/oil soap) and the only thing yoy claim it will do is cleanse, then it is not a cosmetic. No additional requirements or registration are needed in Connecticut. If you make any claims for the soap that it will moisturize or provide other benefits, then you have moved back into the soap being a cosmetic and would need to follow the regulations for Cosmetic Manufacturers.

      As for other licenses, it depends on what the local regulations are for a facility manufacturing soap. Some cities or counties restrict where busineses may be located or have building codes depending on what is being done in the building. You’ll have to check locally for that. You will probably also need to register your business name with the state and get a sales tax license—the same things that are required for any business. You won’t be able to open a bank account in the business name without those things in place.

  12. Hi Marie, I am so happy to fin your valuable information here. Thank you so much for all of that.
    I make cold process soap, olive oil coconut oil and shea butter + micas and lye and distilled water. I don’t think I need more than LLC and Insurance right?
    However, reading about cosmetics license here, I am thinking to get Whipped foaming base soap, which is made from a big company supplier. Do I need a license to sell that product? I wanna make sugar scrubs and body bath butter. It is basically soap in foam presentation

    1. Marie Gale

      In order to be exempt from the definition of a cosmetic (following the federal regulations) the product must be the alkali salt of fatty acids AND must be marketed and sold only as “soap.”

      First, a whipped foaming soap base is PROBABLY a detergent based product, not the alkali salt of fatty acids. So it wouldn’t be exempt from the definition of a cosmetic anyway, but you should check with the supplier. However, if you market the product as a sugar scrub or body bath butter it would be a cosmetic because it isn’t being marketed as just “soap.”

  13. I don’t have a dedicated sink. I am working from my basement and make solid shampoo and conditioner. Will that be a problem? I won’t be able to install a dedicated sink since I’ve just started out and can’t spend the extra money. Does that mean I have to shut down?

    1. Marie Gale

      What I got from the inspection list is that you must have a space that is clean and appropriate. It does say that it should be a dedicated space, but you might be able to get approval if you can show that you have sufficient procedures in place. The bottom line is that they want to make sure that the products will be clean and not get contaminated by other stuff in the environment. That you know what you are doing, and the space is set up appropirately. The only way to know for sure is to go through the process.

      If you do, please share how it goes!

  14. I’ve been trying to find information on press on nails, gel polish and acrylics. Not to be a technician but to create my own gel and acrylic colors from bases and FDA approved colorants. Would I still need a license? Is that considered cosmetic?

    1. Marie Gale

      Gel polish and acrylics are definitely cosmetics. If you are making them to sell, then you need to comply with all the regulations concerning cosmetics.

  15. Madeline

    Hello, I live in Connecticut and I am interested in selling soaps but as a souvenir for events such as baby showers, using glycerin melt & pour and adding only aroma, I will need some permission or license if I sell it from my house.

    1. Marie Gale

      Yes, most likely you will. If you are manufacturing cosmetics in Connecticut you need a license and inspection. Based on the FDA definition, which CT probably uses, a soap is exempt from the definition of a cosmetic if the bulk of it is “the alkali salt of fatty acids” (which means is is made from the chemical reaction between lye, oil, and water, and is not detergent-based). So the determination as to whether your soap is a cosmetic or not is determined by the formulation. You’d have to check the ingredients and/or check with the supplier to determine the case. Also, of course, you could ONLY claim that the soap “cleans”—no other cosmetic claims.

  16. If I am repackaging and relabeling cosmetics, what would my inspection entail? Thanks!

    1. Marie Gale

      Generally the inspections are to determine whether Good Manufacturing Practices are being followed. If GMP is in place, then there is a reasonable certainty that the products will be safe and will not be adulterated or contaminated, and that they will be what they are supposed to be.

  17. Dorothy DAutorio

    Hi Marie so glad I found your site. I just received a call from a church holiday fair that I need a license from the state of CT to sell my homebased products at the church fair in the fall. I have been making and selling cold pressed soaps, sugar hand scrubs, aroma sprays made with essential oils for the last 4 years. With reading the blog my soap should not require a license and the sugar scrubs will. What about the aroma spray? Its made with essential oils, witch hazel and distilled water. I have a good following with my very part time business. I don’t mind rules because you need to keep things safe but I feel it’s just another way to squeeze more out of us. I will contact my representative to voice my concerns. I am a massage therapist and my association had to fight to keep us tax exempt. Thank you for listening and giving me heads up on the room sprays if you know.

    1. Marie Gale

      It the aroma spray is intended to be applied to the human body (or the label says that it CAN be), then it is a cosmetic (like a perfume). In that case, all the cosmetic manufacturing, licensing and reporting rules hold true. If it is ONLY for spray into the room, and says “not to be applied to the body” then it is just a room freshener and not a cosmetic.

  18. Thank you. I contacted my state representative. I know nothing will change but at least I can bring it to there attention that there needs to be some exemptions.

  19. Thank You again Ct for making it hard for small businesses. I agree with Kate, i have a small shop in my home. I thought I was doing everything right, insurance, llc etc… I was selling lotions, lip balm and such. I practice GMP. There should be an exception for 1 person trying to provide all natural products instead all of the additives in store bought products. I was ready to to the jump but I’m frustrated. Someone contacted me who has a similar business and told me that they were turning people in for not having a license and she contacted the state. I had no idea I had to have a license. They called me and told me I could not even make lotion and give it to my family members. I will not be getting a license. I will no longer be making these products and will not be expanding my business. I know people will say it protects me and my customers but I’m not going to get a license and go through inspections, documentations, that cost me more than I make in product.

    1. Marie Gale

      I’m sorry to hear that. I agree that there should be exemptions for small businesses. The Handcrafted Soap and Cosmetic Guild is working hard to ensure that any federal laws that get passed DO include appropriate exemptions. Hopefully if/when that goes through, the states will reconsider and adopt similar exemptions.

  20. Can I purchase lotion base from a manufacturer to resell to avoid getting a license in Ct

    1. If you purchase completed and labeled products you are not a manufacturer. However, if you purchase a base and then package, repackage, label or relabel, then you would need a license. See the Connecticut Manufacturers page.

  21. How does it work if a company is in another state but has independent contractors mixing ingredients, bottling and shipping? Will those independent contractors need a license or permit?

    1. Marie Gale

      I don’t know. You would have to check with the state. It would probably depend on where the contractors are located, and if they are in Connecticut, they they would probably have to be legal for doing their business of cosmetic manufacturing in the state.

  22. Thank you for this information Marie. I haven’t start my handmade cosmetic business yet, but I’m in the process.
    Does Connecticut law requires that you have any training license or work experience records etc…? Cause I do have great experience in cosmetic formulations. I’ve been taking free and paid online courses without certification and been formulated for friends and family who inspired me to start my own business.
    And I’m still renting so I’m thinking of preparing a room in my house/Apt to start with. And by the way regarding the recall procedures. Does that mean I can start the business for a couple of months, start selling online then begin the Drug Control Division inspection after? 80% of my ingredients are natural and organic, no chemicals whatsoever. Did you find any information about the New York handmade cosmetic business please?
    Sorry for bombarding you with all these questions.

    1. You should check with the state to make sure you go through the licensure process correctly. Also be sure to check with your local city/county to verify the area you are in will allow a business. I don’t believe that New York has any special requirements for cosmetic manufacturers.

  23. Hi Marie, my questions are: Can my location Workspace be in a commercial office building without private a sink, but I can add a fridge and storage cabinets for ingredients etc… My kitchen is too small and, an industrial warehouse is way too expenssive in Connecticut especially in the Stamford area.
    Thank you so much for this information which is no where to be found online
    or anywhere else, but here. Again thank you.

    1. Marie Gale

      The requirements are generally in line with good manufacturing practices. I would think that a sink would be a necessity in order to ensure the manufacturing space and equipment can be cleaned and maintained sufficiently to ensure that the product doesn’t become adulterated. There might also be issues with a landlord in a commercial office building.

      I would suggest you check out at least those two issues carefully before committing to a lease or rental.

  24. Candice Flewharty

    Hi! I too make soaps and lotions and have been encouraged to start a side business. Sounds like to easiest way to get started (not that I am looking for the path of least resistance more that I find that I work best if I put all extra energies into one thing at a time) is to only sell soap and once that’s going then work on a license for lotion. Can you possibly offer direction? Is license to make soap as complicated as cosmetics (lotion)?

    1. Marie Gale

      If soap is “soap” (alkali salt of fatty acids and is only marketed as soap) it is exempt from the definition of a cosmetic, so no licensing is needed.

      If you make soap that you want to be treated as a cosmetic (that is, it is either made with detergents OR it is marketed as a cosmetic), then you need the standard cosmetic licensing. It might be a little simpler than, say, lotions or creams, but the requirements will be basically the same.

      The biggest thing for licensing is to make sure that you have your GMP in place. Look over the requirements as discussed in the blog post and consider purchasing my book on GMP. That will give you some guidelines to work toward as you start with soap.

  25. It seems like every small farmer’s market in CT has 1-2 soap makers, most of whom make cosmetics claims or offer products that are technically cosmetics as well – but very few do proper ingredient labeling. Most give the impression of being “kitchen table” enterprises and not formal businesses. In my day job I’m an engineer and do a lot of manufacturing and quality projects, so as a consumer I won’t buy from these folks; I don’t have confidence that they follow GMP or have any product traceability and hat gives me no recourse if their lip balm burns my kid’s lips or I find cat hair in my “moisturizing” bar of soap.

    As a hobbyist whose friends have encouraged me to make the jump from hobby to side business, this is helpful information. I was not aware of these licensing and permit requirements on the cosmetics side until I did a Google search and found this post.

    I do find it interesting that now Connecticut has a cottage food law with a $50/year license and no kitchen inspection requirement, making it much cheaper and easier to for my friend to sell cookies baked in her home kitchen than it would be for me to sell bath fizzies made at my basement workbench. Oh, well!

    1. While most small soap and cosmetic handcrafters have exceptional products, sometimes I see their labeling fall short. Usually that’s due to not realizing there are regulations to follow (or not understanding them). Connecticut is one of the few states that has licensing regulations for cosmetic manufacturers. Unfortunately, where state regulations exists (including Connecticut) they are geared to large production facilities.

      The food industry has realized that there are “cottage food makers” which have much different risk factors than large food processors and have adjusted the regulations accordingly. Even Congress realized that, and so the FDA has provisions for farm-to-table and small food businesses.

      The HSCG is working dilligently to make sure that members of the House and Senate are informed about the small soap and cosmetic industry and that any forthcoming regulations will take their business models into account. The risk factors are so much lower with handcrafted products than with cosmetics made by large manufacturers, using created proprietary ingredients, and intended for widespread distribution.

  26. Hi guys, great thread. If I manufacture shampoo for men does that require a license? It has only 6 Ingredients and none of them hazardous. Example, baking soda, tea tree oil, purified water etc.. Thanks!

    1. Marie Gale

      There aren’t any exemptions for small business. So, YES, you do need to follow all the regulations if you are making shampoo. Even if it contains only 6 ingredients and none of them are hazardous.

  27. Marie, would this apply to re-sellers of cosmetics manufactured by someone else out of state?

    1. Marie Gale

      Not exactly. There is a different form for out-of-state manufacturers to file. I believe they need to file if they are selling in the state. If a business is buying private label, then the manufacturer may need to file the out-of-state form. If the business is just buying finished product for resale, then it doesn’t need to file the out-of-state form.

  28. Is handcrafted soap included in the regulations?

    1. Marie Gale

      Soap is exempted from the definition of a cosmetic IF the soap is mostly the alkali salt of fatty acids (lye/oil), AND it is only marketed as “soap” AND it only claims to clean. To manufacture soap that isn’t a cosmetic, you don’t need to be licensed and insepcted as a cosmetic manufacturer.

      However, if the soap is NOT exempt from the definition of a cosmetic, then it IS a cosmetic and you do need to get permitted. That would be the case if, for example, you claimed that your soap or any of the ingredients “moisturized” or had any other cosmetic benefits that improved appearance.

  29. Thank you! This will be great to share with makers thinking of starting a new business in CT.

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