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It may sometimes be unclear or difficult to determine whether a product is a cosmetic and therefore fall under the scope of the cosmetic legislation. “Borderline” is a terminology frequently used to describe these products where their composition, overall presentation or claims may bring the classification into question. It is not uncommon for products to be incorrectly classified due to the presence of claims, whether explicit or implicit. Secondary functions and the consumer understanding of a claim may also affect how the authorities may ultimately classify products.
To guide companies through the classification process and the assessment of a product with specific relevance to claims, CTPA created the CTPA Decision Tree for Borderline Assessment. There are examples in different contexts to minimise the risk of an incorrect classification and how to ensure that your product remains within the definition and classification of a cosmetic.
In addition to the publication of the CTPA Decision Tree for Borderline Assessment, future training events will be announced giving an opportunity for industry to engage directly.
