The European Commission has published a draft for the 23rd Adaptation to Technical Progress (ATP) of the CLP Regulation (Regulation (EC) No. 1272/2008). This update, essential to the cosmetic industry, introduces new and revised entries for classifying and labeling 32 substances, including eight relevant cosmetics.
Essential Cosmetic Substances Under Review
- Ozone
- Function: Oral care
- Classification: Carcinogenic, Mutagenic, and Toxic for various organs
- Nitrous Oxide (Dinitrogen Oxide)
- Function: Propellant, Fragrance
- Classification: Reproductive toxins, may damage organs
- Tetrahydrofurfuryl Methacrylate
- Function: Film forming
- Classification: Reproductive toxin and skin sensitizer
- Chrysanthemum Cinerariaefolium Flower Extract
- Function: Fragrance
- Classification: Toxic if inhaled and allergenic
- Methyl Oct-2-innate
- Function: Fragrance
- Classification: Skin sensitizer
- Isophorone Diisocyanate
- Function: Film forming
- Classification: Acute toxicity, respiratory sensitizer
- 3-Iodo-2-propynyl Butylcarbamate
- Function: Preservative
- Classification: Toxic if inhaled and severe eye damage
- Tetrahydrofurfuryl Methacrylate
- Function: Film forming
- Classification: Reproductive toxicity
These substances are listed in CosIng, a database of cosmetic ingredients, but are not currently banned under Annex II of the Cosmetics Regulation. However, their classification as CMR could lead to bans unless exempted by the SCCS, the Scientific Committee on Consumer Safety. This means that while these substances are not prohibited for use in cosmetics now, their classification as CMR could lead to regulatory changes in the future.
Timeline and Compliance
- Adoption: Q4 2024
- Implementation: 18 months post-adoption
Implications for Brands
- Review Formulations: Assess and adjust formulations containing these substances.
- Monitor SCCS Opinions: Exemptions may apply; stay updated.
- Prioritize Sustainability: Align product strategies with regulatory and environmental expectations.
Next Steps
Cosmetic companies must adapt proactively by revising product formulations and ensuring compliance before the regulation takes effect. This proactive approach will ensure you are prepared and in control of the changes. Engaging with regulatory experts and staying informed will be vital to navigating these new requirements.
Stay Compliant, Stay Ahead!