On 30 November 2009, the new Cosmetic Products Regulation EU Regulation 1223/2009 replaced the Cosmetics Directive, before coming into force fully last year.
The principal aim of the Regulation was to protect public health by harmonising the previously laws and regulations concerning cosmetic products in the European Union.
The Regulation lays down rules on the composition, labelling and packaging of cosmetic products that are to be adopted thoughout the EU member states.
Challenges
According to a study carried out by IQPC, the number one challenge since the regulation came into play has been what preservatives you can use, with a third of respondents raising concern.
Next, was the definition of ‘second use’ followed by alternatives to animal testing, with the full ban coming into play last year too.
Initial confusion over what/ who is the responsible person seems to have been resolved, as one year on; it is fairly low down on the IQPC list.
The majority of respondents (62%) to the IQPC survey were from manufacturers, whilst 19% were formulators or designers, 13% represented a brand, and 6% were from distributors.
When it comes to compliance it appears time is a big challenge as many said they struggle with getting detailed information rapidly on the full constituents/ contaminants of cosmetics ingredients, whilst meeting new labeling requirements, the changes in rules for some ingredients, and understanding the whole regulation itself were also mentioned.
Worldwide compliance was also highlighted as a key challenge to the industry, particularly compliance with Chinese regulations as more brands look East for growth.
Investment
All of these challenges have led to companies investing in various resources and product testers seems to be the preferred choice as half of respondents said they had invested here.
Regulatory consultants and association memberships also saw investment from companies looking to cope with the new regulation challenges, with improving regulatory compliance, protecting their brand, and improving operational efficiency as the key drivers for this investment.
There will be further discussion on these topics at the upcoming Cosmetic Compliance Summit 2014 taking place in London on October 14-16.