Published: 02 March 2020  (Updated: 02 March 2020)

Updated EU Borderline Manual for Cosmetics

The EU Commission published in February 2020 an updated version of its Borderline Manual, produced by the EU Working Group on Cosmetic Products, on the scope of the application of the EU Cosmetic Products Regulation (CPR).

The updates included are as below.

  • Nail care products: products that do not meet the cosmetic functions under Article 2 of the EU CPR cannot be classed as cosmetics (e.g. treatment or prevention of fungal infections or other diseases, or products against nail biting).
  • Massage products: a product, such as an oil, that is aimed to help the act of massage cannot be classed as a cosmetic; however, a product which moisturises skin and protects it during the massage may fall in scope of the CPR.
  • Essential oils: essential oils that do not have a clear cosmetic function and are only intended for use under aromatherapy are not considered cosmetic products; essential oils of this kind are usually classed as general products.  Depending on their main function, essential oils may also be classed as medicines.
  • Several minor changes.

For CTPA advice on borderline products, please consult the CTPA Borderline Reference Zone.  For any further questions, please contact Francesca Rapolla.

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