May Butylphenyl Methylpropional be used in Cosmetic Products?
Butylphenyl Methylpropional, also known as Lilial, is a fragrance ingredient that has been used for years in several cosmetic and non-cosmetic products. Nevertheless, some concerns have been expressed regarding the use of this ingredient and its risk to consumers. According to an amendment to the CLP Regulation, the use of Butylphenyl Methylpropional will be prohibited in cosmetic products from 1st March 2022.

BUTYLPHENYL METHYLPROPIONAL AS A COSMETIC INGREDIENT

Butylphenyl Methylpropional, commonly known as Lilial (main trade name) or p-BMHCA, is an aromatic aldehyde, a synthetic fragrance ingredient widely used in different types of cosmetics. Butylphenyl Methylpropional is also used in several non-cosmetic products, like household cleaners and detergents.

According to the European Cosmetics Regulation No. 1223/2009, Butylphenyl Methylpropional is included in the list of substances that cosmetic products must not contain except subject to the restrictions laid down (Annex III, entry 83). This meant that its presence in the finished product must be indicated in the list of ingredients on the label when its concentration exceeded 0.01% in rinse-off products and 0.001% in leave-on products.

The Research Institute for Fragrance Materials Expert Panel (REXPAN) has evaluated the safety of this fragrance ingredient and an International Fragrance Association (IFRA) Standard has been established. Due to its potential for sensitization, the use of Butylphenyl Methylpropional is restricted in fragrances. IFRA recommends a safe concentration limit for Butylphenyl Methylpropional when it is used in the specific categories of cosmetic products (as developed by IFRA).

THE SAFETY OF BUTYLPHENYL METHLYPROPIONAL

Opinions issued by the European Commission’s Scientific Committee on Consumer Safety (SCCS) have expressed concern about this ingredient (risk of skin sensitization, aggregate exposure). Butylphenyl Methylpropional as a net compound revealed to be irritating to the skin and eyes of rabbits. Moreover, this ingredient poses a risk of inducing skin sensitization in humans.

On its last opinion (SCCS/1591/17, issued in 2019), the SCCS concluded that “on individual product basis, Butylphenyl Methylpropional with alpha-tocopherol at 200 ppm, can be considered safe when used as fragrance ingredient in different cosmetic leave-on and rinse-off type products”. Nevertheless, the SCCS considered the aggregate exposure, arising from the use of different product types together, and concluded that Butylphenyl Methylpropional at the proposed concentrations cannot be considered safe. The Scientific Committee also expressed concern regarding the presence of this ingredient in non-cosmetic products (e.g. household cleaners and detergents) and consequent higher exposure scenario.

The European Chemicals Agency Risk Assessment Committee (RAC) evaluated a classification proposal on Butylphenyl Methylpropional to be considered as Toxic to Reproduction (Repr. 2 – Reproductive Toxicity class 2). RAC concluded that this fragrance ingredient should be rather categorized as Repr. 1B. So, according to an amendment to the CLP Regulation (Commission Delegated Regulation No. 2020/1182) published in May 2020 by the Commission, Butylphenyl Methylpropional is now classified as toxic to reproduction (Repr. 1B – CMR 1B).

By default, the use of substances classified as CMR (carcinogenic, mutagenic or toxic to reproduction, under the CLP Regulation) is banned (European Cosmetics Regulation). Consequently, Butylphenyl Methylpropional shall be banned from cosmetic products from 1st March 2022 and the ingredient will be included in the Annex II (list of substances prohibited in cosmetic products) of the European Cosmetics Regulation.

All products containing Butylphenyl Methylpropional must be off the shelf by this date. Cosmetic products containing this ingredient can be reformulated, which means that new product safety evaluations must be performed and labels may need to be corrected.

References:

  1. Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products.
  2. Commission Delegated Regulation (EU) No. 2020/1182 of 19 May 2020 amending, for the purposes of its adaptation to technical and scientific progress, Part 3 of Annex VI to Regulation (EC) No. 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures.
  3. Scientific Committee on Consumer Safety (SCCS) – Opinion on the safety of Butylphenyl Methylpropional (p-BMHCA) in cosmetic products – Submission II – 2017

further
reading

cosmetic products

Citral under review: SCCS Preliminary Opinion

The SCCS was tasked by the European Commission to evaluate if the safety levels for Citral, determined through QRA2 based on skin sensitization induction, are sufficient to safeguard consumers. A preliminary opinion was released.

Read More »
cosmetic products

Are sunscreens with Benzophenone-4 safe?

Benzophenone-4 is commonly known as a UV-filter in cosmetic products. Learn what the final opinion of SCCS states about Benzophenone’s safety profile as a UV-filter in cosmetic products.

Read More »
cosmetic products

Is Aluminium in cosmetics safe for human health?

The Scientific Committee on Consumer Safety (SCCS) published its Final Opinion on the safety of Aluminium in cosmetic products. This follows a lengthy review process that began in 2013 when the SCCS was first mandated to evaluate the potential health risks of Aluminium (Al) and its compounds in cosmetics.

Read More »
cosmetic products

Silver in Cosmetics: SCCS preliminary opinion.

Ingredients: SILVER

The recent preliminary opinion from the Scientific Committee on Consumer Safety (SCCS) regarding silver in cosmetics is crucial for consumers and manufacturers. This article breaks down the key points, making it easier to understand the implications and stay informed.

Read More »
news & updates

EU Ecolabel adoption and recognition are on the rise

The Ecolabel certification is a comprehensive program focused on fostering sustainable practices. It evaluates products based on life cycle assessments, where every phase of said life cycle must abide by strict standards to attain the Ecolabel certification. The overarching objective of this certification is minimizing environmental harm from production or consumption activities.

Read More »
cosmetic products

UK proposes ban of wet wipes containing plastic 

The UK has proposed, on April 24, 2024, a regulation titled The Environmental Protection (Wet Wipes Containing Plastic) (England) Regulations 2024, to the World Trade Organization (WTO). The regulation aims to eliminate the supply and sale of plastic-containing wet wipes, including cosmetic ones. The public can offer comments on the draft until June 23, 2024, with adoption expected in September of the same year.

Read More »
news & updates

SCCS preliminary opinion on Citral sensitization endpoint

Ingredients: CITRAL

Date of publication: 27/03/2024

On March 27 2024, the Scientific Committee on Consumer Safety (SCCS) published the Preliminary Opinion on the safety of Citral in cosmetic products. The deadline for comments is set to June 2, 2024.

Read More »
medical devices

Safety Reporting in Clinical Investigations: a Gap Analysis of Guidance Documents 

Safety reporting in clinical investigations of medical devices shall be performed in line with Article 80(2) of the EU MDR. On May 2020, it was published the MDCG 2020-10/1, outlining the procedures for safety reporting in clinical investigations of medical devices under the EU MDR. However, on October 2022 the Medical Device Coordination Group (MDCG) published an updated version of the MDCG 2020-10/1, the MDCG 2020-10/1 Rev 1. This article highlights the updates included in the new revision, analysing the gaps between both documents.

Read More »
medical devices

Roles and Responsibilities of an Authorised Representative under EU MDR and IVDR 

If a medical device manufacturer is not established in a Member State, the devices can only be placed on the Union market if the manufacturer designates an authorised representative. The authorised representative plays a pivotal role in ensuring the compliance of the devices with EU regulation, serving as point of contact. The obligations and responsibilities of authorised representative are outlined on Article 11 of both MDR and IVDR, but clarification of relevant requirements is described in MDCG 2022-16 of October 2022.

Read More »
medical devices

Understanding the ISO Standards Lifecycle

ISO Standards cover a huge range of activities, representing the distilled wisdom of people with expertise in their subject matter and providing the regulators with a sound basis to develop better legislation. ISO Standards are diverse, addressing from the shoe size we wear to the quality of air we breathe. The medical device sector is no exception. ISO has many International Standards and guidance documents aimed at helping the sector ensure safe and effective medical devices while meeting the multitude of national, regional and international regulatory requirements. But how exactly is a Standard developed, reviewed and withdraw?

Read More »