Article 33 of Cosmetics Regulation 1223/2009 has given the European Commission the task of establishing and updating a glossary of common ingredient names.
First of all, it should be noted that it does not constitute a list of substances authorised for use in cosmetic products. In fact, it contains some substances that have been banned, sometimes for several years, such as Isobutylparaben and Isopropylparaben, 3-Benzylidene camphor, Diethylene glycol, PABA…
The identification of substances at the trapdoor
More disturbing, unlike the equivalent of Article 5bis of the former Cosmetics Directive, which stated that the inventory should contain information concerning the identity of the ingredient, its function(s) and any restrictions, Article 33 of the Regulation only stipulates that the Commission must take into account internationally recognised classifications, and in particular the INCI classification.
In the text of its Decision, the Commission notes that the requirements of Article 5bis of the old Directive go beyond those set out in Article 33 of the Regulation. Exit thus the information for identifying ingredients, only a raw list of 26491 INCI names remains. Is it to simplify the work to the extreme, or a lack of interest on the subject by the Commission? What tools are left to accurately identify ingredients before labelling them? The CosIng? We know that this is not an official database and that it still contains errors. The PCPC Dictionary? It is not free and far from being within everyone’s reach…
Applicable in May 2020
Nevertheless, this glossary, however useless it may be, becomes the mandatory reference for the proper labelling of ingredient lists and is applicable from 8 May 2020.
To go further
• See the text of Commission Decision (EU) 2019/701 of 5 April 2019 eestablishing a glossary of common ingredient names for use in the labelling of cosmetic products, and its annex (the glossary), on the European Commission’s website