In December 2018, the European Commission launched a study to assess the possible impacts of extending the obligation to label allergens on cosmetic products, in line with the CSSC Opinion published in 2012. Iwo years later, it has just published the report that was submitted to it. After a reminder of the options considered and the issues they raise, its authors make a few recommendations to the Commission.
As a reminder, with a view to translating the CSSC Opinion of 2012, which recommended the mandatory labelling of 62 additional perfume ingredients, in addition to the 26 already subject to this obligation, into regulations, the European Commission has put three options on the table:
• Option 1: No EU action
• Option 2: On-pack labelling according to the present rules of the Cosmetics Regulation • Option 3: E-labelling, with 3 sub-options:
-> By means of a website address
-> By means of QR codes
-> By means of extended barcodes
The report begins by pointing out that the consultations organised by the Commission centred around three main challenges:
• Need to ensure consumer access to information about additional fragrance allergens in cosmetic products
The 2012 Opinion recommending that the consumers should be informed about additional fragrance allergens still needs implementation, which might potentially cause harm to human health for sensitised consumers and deprive all the consumers of their right to information in this regard.
• Issues with listing fragrance allergens on the package of some cosmetic products
If additional allergens were to be labelled, ingredient lists in some cases could get longer depending on the number of allergens in …
