2018 is not that far. And the last step of the chemicals registration process provided for in the REACH regulation is likely to impact many cosmetic ingredients, along with their users and importers. At the 13th edition of the regulatory congress held last November 18-19 in Chartres, France, Marie Kennedy, International Compliance Director at Elizabeth Arden, gave a reminder of the rules and a few tips to be best prepared.
After evoking the group therapy sessions that might be needed to approach the next REACH milestone confidently, Marie Kennedy first focused on the 2018 issue. All pre-registered substances (in 2008, or later by means of late pre-registration) manufactured or imported in quantities between one and 100 tons (per legal entity and per year) must be registered (unless exempt) before May 31, 2018. If not, their manufacturing, import, and placing on the European market will be illegal and will have to cease.
What is the risk? Possibly a break in supply for certain key ingredients specific to the cosmetics industry as from June 1, 2018. The thing is, as the speaker highlighted, ‘low-tonnage substances are more “vulnerable” than those with a high tonnage, because certain suppliers (manufacturers or importers), in particular SMEs, might not be able to register all the cosmetic ingredients concerned in time, and thoroughly’.
The REACH principles
As a reminder, we are dealing with the ‘existing’ or ‘phase-in’ substances (which benefit from a transitional regime) that were pre-registered between June 1 and December 1, 2008. Then there are those whose pre-registration was late, that is, the ‘existing’ substances imported or produced in quantities higher than one ton per …
