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Review of the Year
Related Chemicals Legislation
The Cosmetics Regulation specifies how and what ingredients can be used in cosmetic products through both annexes
and articles. Restrictions can include concentration limits, types of product and labelling requirements, to name a few.
In addition to the Cosmetics Regulation, there are other pieces of chemical legislation that should also be taken into
account when considering what ingredients to use. CTPA follows all regulations that may affect both cosmetic ingredients
and products and ensures its members are alerted accordingly.
REACH
The European Registration, Evaluation and Authorisation
of Chemicals (REACH) Regulation requires that all chemical
substances manufactured or imported into the European
Economic Area, in a quantity between 1 and 100 tonnes
per year, are registered by 31 May 2018.
In order to be able to continue to use substances that fall
into this category in cosmetic products from 1 June 2018,
companies must ensure that registration takes place prior to
the deadline and that the cosmetic use of the substance is
covered in the registration dossier. The European Chemicals
Agency (ECHA) has advised that companies start to prepare
for the 2018 REACH registration deadline. ECHA has
developed a REACH portal, titled “Know your portfolio and
start preparations for REACH 2018”, which offers relevant
tips and links.
CTPA continues to work with its scientific, regulatory and raw
material supplier committees to ensure that all members are
fully informed and compliant ahead of the 2018 deadline.
CTPA will be holding a seminar on REACH in 2016
(open to members and non-members) to help all companies
along the supply chain be aware of the implications of the
2018 requirements.
Access and Benefit Sharing (ABS) Regulation
Commission Regulation (EU) No 511/2014 on compliance
measures for users of the Nagoya Protocol on Access to
Genetic Resources and the Fair and Equitable Sharing of
Benefits Arising from their Utilisation came into force on
16 April 2014. The main requirements relevant to the
cosmetics industry (user obligations, due diligence, monitoring
user compliance and best practices) became applicable on
12 October 2015.
To ensure better understanding of the ABS Regulation,
Cosmetics Europe, the International Fragrance Association
(IFRA), EFfCI and the European Organization of Cosmetic
Ingredients Industries and Services (UNITIS) have together
developed a best practice document for the cosmetics
industry. In addition, the four associations held a ‘train the
trainers’ workshop to train the national associations on
the intricacies of the ABS Regulation. In November 2015,
CTPA ran a seminar to share that information with members.
Classification, Labelling and Packaging (CLP) Regulation
In 2009, the European Parliament and Council adopted a
Regulation on the Classification, Labelling and Packaging
of Substances and Mixtures (CLP), based on the Globally
Harmonised System of Classification and Labelling of
Chemicals (UN GHS), which became fully applicable to
mixtures on 1 July 2015.
All finished cosmetic products (as defined in the Cosmetics
Regulation), including those in aerosol packaging, are exempt
from the CLP Regulation. However, Commission Directive
2013/10/EU, which amends the Aerosol Dispenser Directive
(ADD), 75/324/EEC, refers to the CLP logos and hazard
warnings under the labelling requirement of the CLP
Regulation. Therefore, although cosmetic products are
excluded from the CLP Regulation, cosmetic products in
aerosol packaging must bear the CLP labelling in order to
comply with the ADD. The labelling requirements were
applicable from 1 July 2015. The notification part of the
CLP is not included in the ADD and therefore is not
applicable to cosmetic products in aerosol packaging.
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