Since the Brexit, Great Britain has regained control of the management of cosmetic ingredients. With its own CLP classifications, specific provisions for CMR substances or nanomaterials, its REACH Regulation… and its determination not to necessarily align itself with the European Union. At the 8th conference on cosmetics regulation and compliance organised by ERPA (European Cosmetics and Personal Care Association), Francesca Rapolla, from the CTPA (British Cosmetic, Toiletry and Perfumery Association) lifted the veil on the present and future of cosmetic ingredients in Great Britain.
The GB CLP
All existing classifications in Europe before 31 December 2020 have been transposed into the GB CLP (UK CLP Regulation) and are applicable unchanged in the UK. Annex VI of the European CLP Regulation has simply been renamed GB MCL for Mandatory Classification and Labelling.
However, since 1 January 2021, two processes have been introduced for classifying substances.
• The classification of European origin: On the basis of the ECHA’s ERC Opinion, the HSE (Health, Safety & Environment Department) takes a decision for Great Britain, validating (or not) the ERC’s decision. Companies wishing to comment on the proposal should do so as part of the ECHA consultation.
• Classification specific to Great Britain: The HSE itself proposes a classification and a specific consultation is open to companies.
In both cases, and even if the classification has a European origin, these processes can create divergences with Europe.
Francesca Rapolla gave the example of d-limonene. Classified as Aquatic chronic 3 in Europe, it was deemed to be classified as Aquatic chronic 1 in Great Britain.
And this is not without consequences, since the British authorities require that safety data sheets comply with the classifications in force in Great …
