On 7 October 2024, the French government opened a public consultation on a draft RMOA (Regulatory Management Options Analysis) drawn up by Anses. After an initial proposal for the CLH classification of lithium salts, notably as reprotoxic substances, it is now also a question of a classification as endocrine disrupters.
Although lithium itself is not used in cosmetics, three of its salts have INCI names and are listed in the CosIng:
• Lithium Carbonate (No.CAS: 554-13-2; No.CE: 209-062-5; CosIng functions: Buffering / Hair waving or straightening);
• Lithium Chloride (No.CAS: 7447-41-8; No.CE: 231-212-3; CosIng functions: Not reported);
• Lithium Hydroxide (No.CAS: 1310-65-2; No.CE: 215-183-4; CosIng functions: Buffering / Hair waving or straightening).
Only Lithium Hydroxide is regulated by European Cosmetics Regulation 1223/2009. It is listed in Annex III / entry 15b. Its maximum concentration in hair straighteners for general use is limited to 2% (expressed as mass of sodium hydroxide) and to 4.5% in hair straightenersfor professional use. Its presence shall be accompanied by warnings: Contains alkali / Avoid contact with eyes / Can cause blindness / Keep out of reach of children.
None of the three substances are currently listed in Annex VI of the European CLP Regulation.
The work of the Anses
In 2020, the French ANSES proposed classifying them as Repr. 1A, H360Fd, May damage fertility, May damage the unborn child. This proposal was validated by the ECHA RAC (Risk Assessment Committee) in 2021 and RAC confirmed its relevance in 2024.
However, the Anses did not …
