In response to member queries about making and selling wax wraps and lip balms we have collated some useful information


Additional insurance will be needed for manufacturing and selling of cosmetic products and wax wraps.
We recommend you do your own research on the insurances available for these products and ensure that you comply with all legal requirements.  Trading standards may also have information on the legal aspects too.

BBKA News articles are available to members on the BBKA News Archive site


Articles by By Dr Sara J Robb

Making and Selling Cosmetics: Beeswax Lip Balm
September 2019 BBKA News 

Making and Selling Cosmetics: Emulsions
January 2020 BBKA News 

Making and Selling Cosmetics: Body Butter Bars
October 2019 BBKA News 

Making and Selling Cosmetics: Beeswax and Honey Soap
December 2019 BBKA News 


Articles by Andy Bullen, Health and Safety Manager and Safety Assessor, ADSL Ltd
Selling Hive Product Cosmetics and the Law  
April 2020 and November 2020 BBKA News articles


Making Your Own Wax Wraps
By Angela Kirk, Shropshire North BKA
October 2020 BBKA News 




Wax Wraps - Information provided by the Food Standards Agency


The manufacture of food wraps of wax coated cloth is something that needs care and attention to be compliant with food safety law. Under ‘The Materials and Articles in Contact with Food Regulations’ the wraps should not be harmful in any way, nor alter the wrapped food to make it less desirable or wholesome.

 

Production of the wax for the wraps needs to follow what is called “Good Manufacturing Practice” which means some planning and forethought for such production.

 

Some things a bee keeper may need to think about in this respect :

 

The Wax

 

  • This is the fundamental component of any wrap and it is important that the source and purity of the beeswax is considered - preferably it should be demonstratively “food grade” (E901) or “pharmaceutical grade.” 
  • The treatment of the hives with any veterinary medicines or hive treatments for such things as wax moth may impact on wax quality and has to be considered. As with the safe production of apiculture food products appropriate documentation on any treatments is required and is open to examination by enforcement authorities.
  • Wax from brood comb usually has a higher amount of slumgum and thus is unsuitable for such use. Similarly extensively recycled wax is unlikely to achieve the requisite standard.
  • If the wax comes from hives in distress then it is best avoided. If in any doubt as to the quality of the wax it should not be used, non-compliance to the food contact materials requirements includes changes in the taste or aroma of contacting foods, so safe but malodourous wax can be deemed non-compliant.
  • There is statutory sampling of honey by national authorities under European Council Directive 96/23/EC, with the following classes of chemicals looked for as given in Annex I and II, which has potential implications for what may be present in beeswax and may need to be especially considered:
    • Antibacterial substances including sulphonamides and quinolones
    • Carbamates and pyrethroids
    • Organochlorine compounds including polychlorinated biphenyls (PCBs)
    • Organophosphorus compounds
    • Chemical elements (heavy metals such as lead)
  • Refining and treating the wax is acceptable. Consideration of any processing of the wax may be made by making reference to European Council Regulation 1069/2009 laying down health rules as regards animal by-products and derived products not intended for human consumption with regards to its importation - the ‘Animal By-products Regulation’. The relevant part of this is:
    • Chapter II - Specific requirements for the importation into and transit through the [European] Union of animal by-products and derived products for uses outside the feed chain for farmed animals other than fur animals;  Table 2, entry 10. Apiculture by-products – Raw materials: Category 3 materials referred to in Article 10 (e). Import and transit conditions :
      • “… (b) In the case of beeswax, other than beeswax in the form of honeycomb, for purposes other than feeding to farmed animals, the beeswax has been refined or processed in accordance with any of the processing methods 1 to 5 or processing method 7, as set out in Chapter III of Annex IV before importation” see further -
    • https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32011R0142&from=EN
    • This law is covered by Defra rather than by the Food Standards Agency.
  • Filtering the molten wax should be done with its eventual use in mind, so using ad hoc filters such as nylon hosiery is inappropriate.
  • The harvested wax should not be softened using mineral oils. Any oils that are used should be recorded, including their rate of incorporation.

 

As to making the wraps themselves, please find some general information on further considerations:

 

Preparation

 

  • It’s important for anyone making wraps at smaller premises, for example at home, to pay particular attention to good hygiene practices. This may include:
    • Ensuring before starting work that the work area is clean and disinfected.
    • Hands are regularly and thoroughly washed.
    • Clean clothes or an apron is worn.
    • Any pets are kept out of the work area.

 

The Additives

 

  • The source and purity of any additives that are used, such as jojoba oil or pine resin, should be assured; could there be pesticide residues of concern?
  • Has the supplier confirmed they are suitable for use with food?
  • Again, if the additives have a strong odour that could have a negative impact on the food, that is a problem.

 

The Cloth

 

  • The type of cloth used has the same level of importance as the rest of the components. What kind of cloth is it? If there are synthetic fibres (polyurethane laminate - PUL - for instance) then it’s a plastic, and there are special rules on food contact plastics.
  • If its natural fibre, how has it been processed? Cleaning and bleaching may leave detrimental residues.
  • It is best to use a close weave cloth, to prevent food getting trapped inside the material and causing a build-up of germs.
  • What inks or dyes have been used to colour the cloth? Can the wrap fabricator guarantee that any colours will not run from the cloth?

 

Labelling & Presentation

 

  • The maker is legally obliged to provide labels as to the care of their wraps to ensure safety when in normal use. Are there any foods that could be wrapped that will react badly? Will cleaning after use get rid of any food allergens? How are the wraps to be stored (before and after sale)? Prior thought of the practical problems that may arise is needed and then advice given to tell people how to avoid them.
  • Customers should not be misled as to what the wraps’ can, or cannot, do. If claims are made that they will keep food fresher for longer the maker needs to demonstrate that is a fact, and the authorities will want to check that claim is valid with official documentation.
  • How is the wraps to be packaged? The supplier needs to make sure they remain clean before sale and are secure to avoid chemical contamination and spoilage.

 

Paperwork

 

  • By making food wrappings a person is legally a “Food Business Operator.” That means they are responsible to trading standards officers to ensure they follow all the rules and have the documents to prove it. They can find their local Trading Standards office at the following link:
  • The wraps need to be traceable back to the manufacturer, so they need to put their business name and address with the wraps.
  • The maker might want to batch their production, such as the date of production, just in case something is found to be wrong they will not have to ask for all the wraps back.  They should be able to correlate their starting materials with the finished articles as part of their quality control.
  • Trading Standards can check to ensure the materials and their combination are safe, so things like heavy metal, pesticide and bee treatment medicine residues are not a potential concern.
  • To ensure compliance they may need to have their product tested, the United Kingdom Accreditation Service (UKAS) can be consulted about suitable testing:

 

The Law

 

The national legislation that is applicable is (for each individual country of the United Kingdom):

 

  • The Materials and Articles in Contact with Food Regulations 2012
  • The Materials and Articles in Contact with Food (Amendment) (EU Exit) Regulations 2019

 

The legislation can be found at:

 

https://www.food.gov.uk/business-guidance/food-contact-materials

 

http://www.legislation.gov.uk/uksi/2012/2619/contents/made

 

http://www.legislation.gov.uk/uksi/2019/704/contents/made