Cosmetics Compliance Summit 2013
November 28th, 2013
October 2013 saw the Cosmetics Compliance Summit, held at Pestana Chelsea Bridge Hotel and Spa, London. PFA attended, together with representatives of trading standards authorities, the Cosmetic, Toiletry & Perfumery Association (CTPA), cosmetics manufacturers and suppliers, and regulatory consultants.
The intention of the summit was to discuss the EU Cosmetics Regulation (Regulation (EC) No. 1223/2009), which was fully implemented 11th July 2013.
The summit discussions focussed on the requirements for the Cosmetic Product Safety Report (CPSR) and Product Information File (PIF), along with labelling requirements, ‘responsible person’ obligations, and use of the Cosmetic Product Notification Portal (CPNP).
In general, these aspects were well understood by all parties. The challenges of compliance with the Regulation may be greatest for some SMEs, whose documentation under the previous legislation may not have been very comprehensive.
However, there were some learning points and advice to share. For example, it was noted that certain substances used in cosmetic products that are within the scope of the Cosmetic Regulation would be exempted from authorisation under REACH. This is relevant for substances subject to authorisation meeting the criteria for carcinogenic, mutagenic or reprotoxic (or identified as equivalent concern only because of human health hazard). Substances used in cosmetic products within the scope of the Cosmetic Regulation, would also not be subject to REACH restrictions if the restriction is addressing the risks to human health.
The Summit highlighted the need for improvement in communication within the supply chain, from the Responsible Person to the Distributor.
Enforcement of the Cosmetic Regulation is by in-market control. There is no central registration and evaluation system. It is therefore important to ensure that the PIF and CPSR are fully compliant with requirements, and are transparent and scientifically robust.