CLP product-based laws - how they are likely to affect you!

The reclassification of the old European Directive to the new GHS-based system in terms of labeling and packaging of cosmetics substances could change the downstream use of that substance for the industry.

According to global regulatory affairs experts, Wiebke Sossinka and Dr. Knoell, there have been some questions raised as to whether or not this Directive will affect ingredients in finished cosmetics when it comes to labelling recommendations.

News publication, 'Chemical Watch' reveals that the analysts find key effects of CLP on other EU Regulations will be related to the lowered concentration limits, especially for corrosion and irritation, including the newly assigned pictograms. Whilst minor changes or adoptions have to be made with respect to the changed toxicity levels.

Cosmetics (either raw materials or finished products) are impacted by EU cosmetics directive (Regulation EC 76/768/EEC and Regulation (EC) No 1223/2009), REACH Regulation (EC No 1907/2006) and CLP Regulation (EC No 1272/2008).

CLP ensures that the hazards presented by chemicals are clearly communicated to workers and consumers in the European Union through classification and labelling of chemicals.

What the experts say the re-classified directive will mean

EU Regulations on cosmetics (1223/2009) has its own assessment rules for the final product. Furthermore, finished cosmetics intended for the final user are explicitly exempted from the CLP Regulation.

Nevertheless, both the cosmetics and plastic materials Regulation refer to substances and mixtures classified as CMRs in accordance with CLP.

In general, CMRs are prohibited in cosmetic products. However, CMR 2 substances can be assessed by the Scientific Committee on Consumer Safety (SCCS), and if it reaches a positive conclusion, its use can be permitted. Even the use of a CMR 1A or 1B substance can be requested, but the requirements for permission include additional steps for SCCS assessment.

Thus, for cosmetics and plastic materials, the main significance of the Regulation is that companies should track upcoming harmonisations on classification and labelling, as these have a focus on CMR properties and might lead to a new CMR classification for a substance in use.