Further to the recent Newsletter, it has been made apparent that further clarification is required regarding the EU CLP.
Does CLP Regulations apply to Cosmetic Products?
Firstly, what is the CLP Regulations – CLP means Classification, Labelling and Packaging (CLP) and this is a legislation that requires manufacturers, importers or downstream users of chemicals or mixtures to classify, label and package chemicals appropriately before placing them on the market. CLP applies to all Chemicals and Mixtures.
Is it relevant for Cosmetic Ingredients?
Finished cosmetic products (ready for sale to the consumer) are EXEMPT from the requirements of the CLP Regulations, however, cosmetic ingredients as raw materials or cosmetic mixtures (such as bulk of a cosmetic that is not in the finished state) fall under the remit of the CLP Regulation.
The European Chemical Agency – ECHA, regulates the EU CLP Regulation – the EU Member States authorities carry enforcement activities.
The Health and Safety Executive – HSE, regulates and enforces the GB CLP Regulation.
Under CLP, a chemical can be self-classified by the business manufacturer, or it can receive a harmonised classification by the Authorities.
A harmonised classification under CLP is legally binding, however a self-classification is not. Some cosmetic ingredients may receive a harmonised classification as a Carcinogenic, Mutagenic or Reprotoxic (CMR) substance which would impact their use in cosmetic products. However, under Article 15 of the Cosmetic Regulations, it prohibits substances classified as CMR under the CLP Regulations for use in cosmetic products, unless a specific exemption is granted. The exemption process ensures that the substance is safe when used in cosmetics under specific and controlled conditions.
Remember – Your Cosmetic RP Team are always at hand to help!
If you need any further information in regards to this article or help with your EU and/or UK Cosmetic registration, please feel free to reach out to Advena via either our website contact page, www.advenamedical.com, email (info@advena.com) or telephone (01926 800153).
