Now that Cosmetics Regulation 1223/2009 has taken effect, the product safety report must include ‘the relevant characteristics of packaging material, in particular purity and stability’. The industry has taken action to comply with this new requirement. Guides, guidelines, Task Force: the resources for compliance were presented at the 12th regulatory congress in Chartres.
During the presentation, Catherine Bramaud of FEBEA (France’s Federation of Beauty Companies) first reviewed the regulatory framework governing packaging and packaging materials.
From a safety assessment point of view, she reminded us, the cosmetic product is an indivisible whole comprising the formula and its packaging. This packaging can be composed of a wide variety of materials, whether in terms of the container (tube, bottle, jar, case, aerosol, stick, etc.) or of its associated accessories (pump, valve, capsule, film, seal, label, applicator, etc.).
Applicable regulations
There are several laws, which vary in their specificity, which must be considered for cosmetics packaging.
• Directive 75/324 on aerosol dispensers: compliance with its provisions, in particular the container’s resistance to pressure, must be evaluated.
• Directive 94/62 on packaging and packaging waste: in particular, it establishes maximum concentration levels for heavy metals (lead, cadmium, mercury, hexavalent chromium, etc.).
• REACH regulation 1907/2006.
• Cosmetics Regulation 1223/2009.
The REACH regulation
Within the meaning of REACH, packaging is considered an article. This has implications for cosmetics packaging:
• A new obligation to submit information, since all suppliers of articles containing substances listed as Substances of Very High Concern (SVHC) for which authorization at a concentration of …