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Cosmetics and the microbiome: a regulatory framework... under construction!

Cosmétiques et microbiome : un cadre réglementaire… en construction !

Are living micro-organisms cosmetic ingredients? Do products designed to act on the skin microbiome fall within the scope of European Cosmetics Regulation 1223/2009? While the “microbiotic” trend is growing, the regulatory framework is still under discussion. At the JEST (Scientific and Technical Exchange Day) held on 5 October 2023, Sybille Millet, from Cosmed, provided an update on the subject.

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At European level, the debate on the regulatory status of “microbiotic” cosmetics was initiated in 2018, within the working group on “borderline” products, based on the observation that more and more products were already claiming actions on the microbiome or integrating micro-organisms into their formulas.
At the same time, discussions within the ICCR (International Cooperation on Cosmetics Regulation) led to a consensus on definitions relating to the microbiome and applicable to cosmetic products. In a document published in June 2022, the ICCR laid the foundations for the resumption of work (still ongoing) in Europe.

ICCR definitions

The microbiota is defined as the assemblage of microorganisms, such as bacteria, fungi, archaea, microalgae & protists present in a defined environment. This can be the human body or individual body sites, like the skin or the digestive tract.
The microbiome is a characteristic microbial community occupying a reasonably well-defined habitat which has distinct physio-chemical properties. The microbiome not only refers to the microorganisms involved but also encompasses their theatre of activity, which results in the formation of specific ecological niches. This includes their genetic material, and also structural molecules, like enzymes, membrane lipids or polysaccharides.
It should be noted that …

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