Amongst the obligations set forth in the Cosmetics Regulation: the collection of packaging data. A difficult task in the eyes of cosmetic product manufacturers, who complain that they cannot obtain this information from their suppliers. But what do the suppliers have to say? Two suppliers presented their points of view at Cosmetic Valley’s 11th Perfumes & Cosmetics Congress.
Contrary to the former Directive, Cosmetics Regulation 1223/2009, in force since 11 July 2013, considers packaging to be one of the factors influencing the safety of the cosmetic product. In keeping with this view, the product information file must contain, in the ‘product safety report’ section, a host of information about packaging. Annex I of the Regulation stipulates, in section 4 on ‘Impurities, traces, information about the packaging material’, that the responsible person must supply information on:
• The purity of the substances and mixtures.
• In the case of traces of prohibited substances, evidence for their technical unavoidability.
• The relevant characteristics of packaging material, in particular purity and stability.
The question for the responsible person is this: where can such information be found? The logical conclusion: ask the manufacturer of the packaging materials. That’s where the difficulty resides. We’ve stopped counting the difficulties, reluctant attitudes, confidentiality issues, and other numerous obstacles that keep the information from getting through or from being complete. This provision is new in the Regulation. Until now, the issue of packaging was not seen from this point of view. And packaging suppliers, as of this writing, do not seem to be very enthusiastic about …
