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Critical Catalyst ensures your company meets all the regulatory requirements posed by the EU Cosmetics Regulation 1223/2009. Within the shortest time, we can make your products go through the whole registration process and allow them to be sold in the 31 countries of the European Economic Area (EU + EFTA).

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FREQUENTLY ASKED QUESTIONS

Since July 11th, 2013, cosmetics are regulated in the European Union by Regulation (EC) No 1223/2009.

The Cosmetics Regulation No. 1223/2009/EC aims at the free movement of cosmetic products within the EEA market but also at ensuring the safety of the users of cosmetic products in Europe.

According to the Cosmetics Regulation (EC) No. 1223/2009, “cosmetic product” means any substance or mixture intended to be placed in contact with external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity, with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odors.

The assessment of whether a product is a cosmetic product has to be made on a case-by-case assessment, taking into account all characteristics of the product, its intended purpose and label.

Since products have to be placed in contact with the external parts of the human body or with the teeth and the mucous membranes of the oral cavity, any product intended to be ingested, inhaled, injected or implanted into the human body would also not be considered a cosmetic product in the EU.

A Responsible Person (RP) is an EU based cosmetic product manufacturer, importer, distributor, or another person established within the EU who has to accept this role in writing. A RP must be designated for each cosmetic product placed on the EU market, which bears its name and address on the label.

The role of the RP is to ensure that the cosmetic products placed on the EU market are safe for use and compliant with the EU Cosmetics Regulation.

One of the requirements of EU Cosmetics Regulation is that prior to placing the product on the market a safety assessment is carried out. The Regulation specifies that this safety assessment should be in the form of a Cosmetic Product Safety Report.

It is the responsibility of the Responsible Person to ensure that the product undergoes a safety assessment and that a cosmetic product safety report is produced and maintained up-to-date.

The Cosmetic Product Safety Report is the Safety Assessor’s opinion that the product is safe in normal and foreseeable conditions of use and complies with the requirements on safety of the EU Cosmetics Regulation.

The Cosmetic Product Safety Report is composed of two parts:

  • Part A – Cosmetic product safety information (gather all the data necessary for the safety assessment)
  • Part B – Cosmetic product safety assessment (cosmetic Safety Assessor’s opinion on the safety of the product)

 

The Cosmetic Product Safety Report must be prepared and signed by a qualified Safety Assessor, a person in possession of a diploma or other evidence of formal qualifications awarded on completion of a university course of theoretical and practical study in pharmacy, toxicology, medicine or a similar discipline, or a course recognized as equivalent by a Member State.

The Cosmetic Products Notification Portal (CPNP) is an online notification platform used to submit technical information related to cosmetic products to be marketed in the European Union (EU).

From July 11, 2013 the notification of cosmetics in the CPNP portal became mandatory for all brand owners wishing to legally make their products available on the EU Market.

When a product has been notified in the CPNP, there is no need for any further notification at national level within the EU.

The CPNP is accessible to the following entities:

  • Health Authorities
  • European Poison Centers
  • EU Responsible Persons for Cosmetic Products
  • EU Cosmetic Product Distributors
INDUSTRY NEWS & UPDATES

United Kingdom Restricts the Use of BHT in Cosmetic Products

The United Kingdom has taken a significant step in regulating the use of Butylated Hydroxytoluene (BHT) in cosmetic products. This move is crucial for distributors, manufacturers, and importers to ensure compliance and maintain the safety of their products in the UK market.

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Great Britain Mandatory Classification List (MCL): cosmetic ingredients added.

On March 12, 2024, the Health and Safety Executive (HSE) updated the GB Mandatory Classification List (MCL) by adding 25 new chemical substances, as mandated by Article 37 of the GB Classification, Labelling and Packaging (CLP) Regulation. This update impacts substances identified as cosmetic ingredients with proposed Carcinogen, Mutagen, or Reprotoxic (CMR) classifications under Article 15 of the UK Cosmetics Regulation (UKCR). Notably, 2-ethylhexanoic acid and its zinc salt, along with Dimethyltolylamine, are among those facing potential bans and additions to the UK Cosmetics Regulation’s Annex II. These changes will come into effect on September 2, 2025.

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New coating for TiO2 (nano) – is it safe?

The Scientific Committee on Consumer Safety (SCCS) published the Preliminary Opinion on new coating for Titanium Dioxide (nano). It declared the data was not enough to draw conclusions regarding the safety of this alternative coating, as more evidence of similarity to other nanomaterials is necessary.

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New EU cosmetic restrictions on Cyclic Volatile Methyl Siloxanes (cVMS)

Cyclic volatile methyl siloxanes (cVMS) have raised environmental concerns because of their persistence and bioaccumulative properties. In light of these concerns, the European Union has extended restrictions on substances like D4, D5, and D6 in cosmetic products. New regulations will further limit the concentration of these compounds in both rinse-off and leave-on products, with compliance deadlines set for 2026 and 2027.

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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.

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