The glossary of common ingredient names for use in the labelling of cosmetic products has just been published in European Commission Decision 2019/701. It includes 26491 names of cosmetic ingredients under their INCI denominations but no CAS numbers or other means of identifying them, does not constitute a list of authorized substances and indeed includes some that are prohibited, and becomes the new mandatory reference… even if it is not easily usable.
Article 33 of Cosmetics Regulation 1223/2009 has given the European Commission the task of establishing and updating a glossary of common ingredient names.
First of all, it should be noted that it does not constitute a list of substances authorised for use in cosmetic products. In fact, it contains some substances that have been banned, sometimes for several years, such as Isobutylparaben and Isopropylparaben, 3-Benzylidene camphor, Diethylene glycol, PABA…
The identification of substances at the trapdoor
More disturbing, unlike the equivalent of Article 5bis of the former Cosmetics Directive, which stated that the inventory should contain information concerning the identity of the ingredient, its function(s) and any restrictions, Article 33 of the Regulation only stipulates that the Commission must take into account internationally recognised classifications, and in particular the INCI classification.
In the text of its Decision, the Commission notes that the requirements of Article 5bis of the old Directive go beyond those set out in Article 33 of the Regulation. Exit thus the information for identifying ingredients, only a raw list of 26491 INCI names remains. Is it to simplify the work to the extreme, or a lack of interest on the subject by the Commission? What tools are …
