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PIF for Oral Care Products (Including Toothpaste, mouthwash, breath spray)

PIF for Oral Care Products (Including Toothpaste, mouthwash, breath spray)

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Introduction

Oral care PIFs carry a particular emphasis on claims substantiation, since this category sits closest to the cosmetic/medicinal borderline. Evidence supporting any whitening, freshening or protective claim needs to be clearly filed and distinguishable from a therapeutic claim that would require different regulatory treatment entirely.

What Your PIF Includes

      Product description and CPSR cross-reference

      Manufacturing method (mixing, filling, tube/bottle production) with GMP statement

      Claims substantiation for whitening, freshening or protective claims, with clear separation from any therapeutic-adjacent wording

      Fluoride concentration documentation, cross-referenced to your CPSR

      Animal testing declaration

Who This Is For

Oral care brands maintaining PIF documentation for toothpaste, mouthwash or breath spray.

Legal Framework

      Article 11, Regulation (EC) No 1223/2009

      Schedule 34, SI 2019/696

      ISO 22716

      MHRA borderline-products guidance (claims positioning)

Why Brands Choose Spectra Cosmetic Compliance for Your PIF

      Built directly from your CPSR, so your safety data and PIF are consistent from day one no re-entering formulation data.

      GMP documentation reviewed against ISO 22716, the recognised UK/EU cosmetic manufacturing standard.

      Claims substantiation flagged and structured, so "proof of effect" is ready before an authority asks for it.

      Held to a single, consistent format your Responsible Person can present at inspection without last-minute assembly.

      Retained and managed for the full statutory 10-year period.

Your PIF Deliverables

      Product description name, category, function and any variant/shade codes, clearly linking the file to your product

      CPSR (Parts A & B) cross-referenced from your existing safety assessment

      Manufacturing method description and GMP statement structured to ISO 22716

      Claims substantiation file evidence behind any effect claimed on your label or marketing, where applicable

      Animal testing declaration confirming testing status for the product and its ingredients, as required under Article 18

      Delivered in a single, inspection-ready file, held at your Responsible Person's address

How It Works

1. Share your CPSR and formulation records if Spectra prepared your CPSR, this step is largely automatic.

2. We compile the manufacturing and GMP documentation working from your production records or manufacturer's GMP statement.

3. We structure your claims evidence matching each label or marketing claim to its supporting data.

4. We confirm your animal testing declaration checked against Article 18 requirements.

5. You receive your complete PIF ready to hold at your Responsible Person's address for inspection.

Because an unsubstantiated or overreaching claim here risks reclassifying your product as medicinal, so we document claims evidence carefully to keep your positioning defensible as a cosmetic.

Fluoride concentration is verified in your CPSR; the PIF simply cross-references that conclusion rather than duplicating it.

Yes any functional claim (e.g. "freshens breath," "reduces plaque") still needs proportionate substantiation regardless of fluoride content.

Yes mouthwash is typically a simpler liquid-mixing process, while toothpaste involves paste consistency and tube-filling records.

We flag this during PIF compilation so you can revise the wording before publishing, rather than discovering the issue at inspection.

Yes where alcohol is used as a carrier, its concentration should be documented alongside standard ingredient records.