PIF, Product Information File, is nothing more than the identity card of the cosmetic product. This document must contain all the necessary information to the marketing of such product. Without this document, the cosmetic is not marketable on the European market. Summarising, P.I.F. is a cumpolsary document which must stay in the company. Don’t know how to make a PIF? We know well how complex gathering all the necessary information is! If you decide to elaborate it independently you can take part to one of our P.I.F. training courses. In this case, beware of irregular P.I.F.: they are subject to administrative sanctions as explained below.
It is our duty to inform you that the competent authorities are increasingly turning to us for support in checking the safety documentation of many Italian cosmetic companies.
Many ASL (Italian acronym for Local Health Authority) and NAS (Italian acronym for Anti-adulteration and Health Unit) contact us more and more for technical advice on Regulation 1223/2009 and verification of safety documentation produced by other cosmetic safety assessors.
According to our checks, 90% of P.I.F. in circulation are irregular.
Many irregular P.I.F. are are the result of the following reasons:
- Inexperienced safety assessor: it is the situation in which many companies find themselves, where the consultant, often a newly hired or trusted external person, has many gaps on a new topic such as EC Reg. 1223/2009.
- Not-up-to safety assessor: it is the case of many Italian businesses that, in trust, have relied on a consultant who ‘passes off’ under the guise of P.I.F. the old cosmetic dossier required by Directive 76/768/EC; in the most serious cases the situation arises where the consultant does not issue the P.I.F. in contravention of Article 11 of Regulation (EC) No 1223/2009, but above all the company wonders whether the consultant has really drawn up and signed it.
- Using a not-up-to-date software: not all software in circulation has been perfectly adapted to EC Reg. 1223/2009. There are still non-standard programmes for drafting safety documentation.
We would like to remind you, even though all cosmetic companies are now aware of this, that the penalties provided for by LEGISLATIVE DECREE No. 204 of 4 DECEMBER 2015 are extremely high:
- Art. 8. Missing, incomplete, irregular P.I.F.: Penalty foreseen from 10,000 to 100,000 euros.
- Art. 9. Failure to notify the CPNP: Penalty: from 1,000 to 6,000 euros.
- Art. 13. Irregular label: Penalty: from 500 to 5,000 euros.
Many cosmetics businesses chose safety assessors and programmes to elaborate the new dossier, either because of the commercial prowess of the service provider, or because of the low costs, knowing that the checks would never start. Today the situation is definetely changing, even more so now that the Italian State has to make money.
With the competent authorities taking action, the risk for many companies is to spend much more because of the penalties rather than relying from the start on a reliable partner with in-depth knowledge of cosmetic legislation.
In the course of the next few weeks we plan new P.I.F. audits of Italian companies.
Tips to know how to draft a P.I.F. correctly:
- be well informed about the differences between the old dossier and the P.I.F.;
- always demand the delivery of the P.I.F. if you use an external consultant;
- verify that the programm you use is up-to-date with current legislation (e.g. includes toxicological data section, digitised signature, document is protected against misuse, etc.);
- check well the qualification of the security assessor and his actual knowledge of the subject matter.
If you would like to preempt the checks and verify the status of your documentation with us, we are completely available to help you to prevent unpleasant situations, even through a meeting at our headquarters.
PIF ITALIA has already issued several authenticated reports following the control of the documentation held by companies unaware that they did not have the right certifications; this report has enabled these companies to take recourse (in the most extreme cases even legally) against the consultant who sold an irregular service.
In many cases, they deceided to rely on our services, which since this month are collected in a more orderly manner on our new website nearing completion (www.pifeurope.com).
Our clients appreciate us for our professionalism and reliability, competence in this matter, ethic and honesty offering them services which protects them from any unforeseen, with the certainty and guarantee of NOT being sanctionated. Can you say the same thing about your consultant or your consultancy agency?