Cosmetics & Personal Care | Monthly bulletin | August 2023
Notice of D4, D5, and D6 restrictions related to Cosmetic Products
Siloxanes (including D4, D5, and D6) are silicon-based synthetic ingredients, mainly found as oils and gels. Siloxanes have unique sensory benefits and properties, such as providing long-lasting effects in lipstick, or having softening, smoothing, and moistening properties, and as such are used in a number of cosmetic products.
In recent years, siloxanes have been increasingly monitored. In fact, to protect the environment from the very persistent and bioaccumulative (vPvB) properties of D4, D5 and D6 and the persistent, bioaccumulative and toxic (PBT) impacts of D4, the ECHA initially proposed a restriction on these substances in 2019.
Restrictions related to D4, D5, and D6 to date have included:
- Because of suspected carcinogenic, mutagenic or reprotoxic effets, cyclotetrasiloxane (D4) is listed in Annex II of Regulation (EC) No. 1223/2009 and has therefore been forbidden since 2019
- Cyclopentasiloxane (D5) is listed in Annex III Regulation (EC) No. 1223/2009, restricted to 0,1% in rinsed-off products
On 22 June 2023, the European Commission announced a draft amendment to Annex XVII of REACH Regulation. Related specifically to cosmetic products, the proposed measure aims to extend restrictions regarding the use of D5 and D6 in all type of cosmetic products: limiting use to 0,1% in rinsed-off and leave-on products.
This text is currently open for comment until 21 August 2023, with plans that it will be adopted by the end of 2023.
Eurofins Cosmetics & Personal Care supports partners to meet D4, D5, D6 regulatory requirements through:
- Analytical testing of D4, D5, D6 (limit of determination < 100 ppm) for all cosmetic products, such as hair products, body oils and other cosmetic products which offer softening, smoothing, and moistening properties.
- Assessing labels conformity with Cosmetic Regulation (EC) No. 1223/2009, by examining the absence or (restricted) presence of the regulated substances D4, D5 and D6.
- Testing cosmetic products for ready biodegradability according to OECD 301F, to determine environmental impact.
Eurofins Cosmetics & Personal Care offers a broad portfolio of testing and analysis services to support you to meet your regulatory requirements.
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Fragrance Allergens - Regulation (UE) 2023/1545 Published
Since the publication of the SCCS opinion regarding fragrance allergens in 2012, many discussions have taken place at EU level which have lead to the development of new regulation aimed at extending the list of allergens which should be specifically labelled on fragrance products.
After months of iterations, Regulation (UE) 2023/1545 was published by the European Commission on the 26th of July, 2023 in the Official Journal of the European Union, revising previous regulation on fragrance allergens. Regulation (UE) 2023/1545 modifies Annex III of the cosmetic Regulation with the addition of 57 substances supplementing the 24 allergens which have been required to be labelled in the past.
Labelling rules regarding the permitted concentration of allergens in finished product remain unchanged, i.e. 10 ppm for leave-on product and 100 ppm for rinsed-off products. Application dates are July 31st, 2026 for placing conforming products on market and July 31st, 2028 for withdrawal of non-compliant products.
The Eurofins Cosmetics & Personal Care network of laboratories is committed to offering a complete scope of allergen analysis. We carry out tests safely and cost-effectively, according to product type and individual analytical requirements, in compliance with applicable regulations, as well as providing expert consulting services.
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Several Eurofins Cosmetics & Personal Care Laboratories Awarded Ecovadis Certification
The EcoVadis certification enables companies to measure their environmental, social and ethical impact according to CSR guidelines.
Several of the laboratories within the Eurofins Cosmetics & Personal Care network have recently been awarded EcoVadis gold, silver or bronze medals, indicating their commitment to corporate social responsibility.
We are extremely proud that our commitments to the environment, sustainability, ethics and equality are recognised, as it is a consistent priority for all of our teams, as we work to achieve our ambitious sustainability goals and to contribute to the health and safety of our world.
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