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This has generated a number of enquiries to CTPA on the use of hydroquinone in eyelash extension adhesive.
False eyelashes and lash extensions that are attached by glue are not classed as a cosmetic product under the EU Cosmetic Products Regulation (1223/2009), nor is the adhesive used to attach them. Such products fall under the General Product Safety Regulation under which the onus is on producers and distributors to supply or market only products that are safe in normal or reasonable foreseeable use.
CTPA advises that for General Products that are applied to the skin, they should contain ingredients that are allowed for use in cosmetic products and should be subject to a safety assessment. General Products will though have to comply with any labelling requirements under the Classification, Labelling and Packaging (CLP) Regulation.
The EU Cosmetics Regulation controls what may or may not be put in a cosmetic product. There is a list of substances that must not be present (list of banned substances, Annex II to the Cosmetics Regulation) and a list of substances that may be used as ingredients subject to particular restrictions (Annex III). Hydroquinone is banned from use in topical cosmetic creams and may only be used according to specific uses as restricted in Annex III. Under Annex III, hydroquinone is restricted to artificial nail systems (with a warning to 'avoid skin contact') and to help develop colour in hair colorants (with a warning 'do not use to dye eyelashes or eyebrows') where it is not in contact with large areas of the skin for any length of time. Our advice is to apply the same rules when looking into marketing General Products that are applied to the skin.
After discussions with the UK Competent Authorities, CTPA would like to reiterate that such adhesives should not contain hydroquinone and CTPA has been advised that if such products containing hydroquinone were identified by Market Surveillance Officers, they would be removed from the market and appropriate action taken.