How to Check Supplier Compliance: A Simple Guide for UK Cosmetic Makers
In today’s cosmetic making community, one topic keeps coming up again and again: supplier compliance. With so many makers relying on accurate SDS, IFRA, and allergen documents to keep their products safe and legal, it’s never been more important to make sure the suppliers you buy from are fully compliant and up to date.
But how do you actually check that?
This guide breaks it down into simple steps, helping you protect your business, stay on the right side of UK regulations, and avoid the stress caused by incorrect or outdated documents.
Why Supplier Compliance Matters
Every product you make, whether it's a body butter, shower steamer, or whipped soap, relies on correct technical documents. These documents form part of your CPSR, your PIF, your labels, and your OPSS uploads.
If the supplier isn’t compliant, you’re the one who ends up at risk, not them.
That’s why checking supplier compliance is one of the most important habits you can build as a maker.
1. Check the Version Numbers on SDS, IFRA & Allergen Declarations
The very first thing you should look at is the version number and revision date.
For example:
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SDS: Should follow the most recent format (usually updated within the last few years).
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IFRA: The current valid version is IFRA 51, but many suppliers are still giving out IFRA 48, 49, or 50, which is not acceptable.
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Allergen Declarations: Should reflect the most up-to-date allergen lists, not old ones missing new entries.
If your documents say things like:
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“IFRA 49”
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“Prepared in 2018”
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“Updated: 2019”
These are already red flags.
2. Look for Missing or Incorrect Allergen Information
Incorrect or incomplete allergen declarations are one of the biggest issues right now.
Check for:
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All allergens listed in Annex III
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Correct percentages
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No missing key allergens like Limonene, Linalool, Coumarin, Citronellol, etc.
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No allergens listed that aren’t actually in the assessment
If the assessment’s allergen list doesn’t match the supplier’s allergen list at all, ask questions.
3. Make Sure the IFRA Category Matches Your Product
A compliant supplier must provide the correct IFRA category for the product type you’re making.
If you’re unsure, always double-check, incorrect categories can completely change the legal usage rates.
If a supplier gives you an IFRA where:
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Categories are missing
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They’ve only given you category 12 for everything
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The numbers don’t match the product type
…this is a strong sign they are not compliant.
4. Check the SDS for Proper Sections & Updated Formatting
A standard SDS should include 16 sections. If you’re missing sections, or it looks “homemade” that’s a bad sign.
Look for:
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CAS numbers
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Harmonised classification
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Hazard statements
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PPE guidance
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Toxicology information
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Storage and handling instructions
If the SDS is only one or two pages long (some are!), it is not compliant.
5. Check That the Supplier Updates Documents Regularly
A supplier should update their documents:
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When IFRA releases a new version
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When regulations change
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When ingredients change
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Every few years as standard practice
If a supplier is sending documents from 2017, 2018, 2019, or even early 2020, that is completely unacceptable.
Modern compliance relies on accurate, current data. Anything outdated means you can’t trust it.
6. Compare Multiple Documents for Consistency
A compliant supplier’s documents should always match each other.
For example, the allergen declaration should match:
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the IFRA document,
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the SDS,
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and the ingredients listed in your CPSR.
If the SDS says “Aroma” or “Flavouring” when you’re clearly using a fragrance oil — that’s a mistake.
If the allergen declaration lists allergens the CPSR doesn’t, something is wrong.
If the IFRA lists completely different ingredients, even bigger problem.
This is where many makers first spot inconsistencies.
7. Ask the Supplier Directly. Their Response Tells You Everything
Sometimes the biggest clue is how the supplier reacts when you ask for updated documents.
A compliant supplier will:
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Provide the updated documents
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Give a clear explanation
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Fix errors
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Reassure you
A non-compliant supplier might:
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Ignore messages
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Send outdated files again
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Get defensive
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Tell you "it's fine" when it isn’t
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Say they “can’t be bothered” (yes, some have said that publicly!)
Your safety and legal compliance depend on their documents — so if they aren’t willing to help, that’s a major red flag.
8. Evaluate Their Website & Documentation Access
A professional, compliant supplier will usually:
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Provide documents on every fragrance page
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Keep uploads current
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Clearly list IFRA version
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Offer downloadable SDS & allergen sheets
If a supplier has:
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Broken links
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No documents available
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“Request only” policies
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Missing IFRA documents
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No allergen documents
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Documents labelled incorrectly
…they may not be compliant.
9. Watch Out for Signs of Forged or Altered Documents
Sadly, this has become a growing issue.
Common signs include:
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Different fonts or formatting
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Poor quality logos
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Incorrect IFRA versioning
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Missing CAS numbers
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Typos everywhere
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“Copy/paste” looking tables
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New documents that contradict older ones
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IFRA 51 created before IFRA 51 was released
If something feels off, trust your instincts and dig deeper.
10. Keep Your Own Records, Don’t Rely on Suppliers
Always save:
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Every SDS
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Every IFRA
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Every allergen declaration
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Email conversations
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Document revision history
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Screenshots of supplier pages
This protects you if anything ever gets questioned by Trading Standards, OPSS, or your assessor.
Final Thoughts: Compliance Isn’t Optional, It’s a Responsibility
As a maker, you depend on your supplier to protect your business.
By taking the time to check your documents, understand red flags, and choose suppliers who prioritise compliance, you’re protecting:
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your business
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your customers
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your assessments
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your own peace of mind
And remember, you don’t have to navigate compliance alone.
At Cosmetic Assessment Support, I’m always here to help you understand documents, spot issues, and keep your products safe and legal.