Cosmetics & Safety.
Do you market or want to market cosmetic products? Then you have to deal with laws and regulations. This applies not only to cosmetic products you bring out under your own brand name, but also to distributors. Find below the most important rules and your obligations. Précon is happy to help you.

What is cosmetics?
First, it is important to know exactly what cosmetics are. Cosmetics is defined as any substance or mixture intended to be brought into contact with the human body surface. These include epidermis, hair, hair, nails, lips, external genitalia, teeth, molars and oral mucous membranes.
The substances or mixtures must have at least one of the following purposes:
- Cleaning
- Take care of
- Perfume
- Protect
- Change appearance
- Body odor masking
What can we help our clients with?
- Preparation and review of labels according to the Cosmetics Regulation.
- Training your employees on all labeling requirements.
- notification of products in the Cosmetic Product Notification Portal (CPNP).

Cosmetics Regulation.
When you market cosmetic products, you have to deal with various laws and regulations. In Europe, for example, the Cosmetics Regulation 1223/2009 applies. The essential requirement of this regulation is:
Cosmetic products should not harm human health when used under normal or reasonably foreseeable conditions of use.
This essential requirement is explained in detail by main line in the Cosmetics Regulation:
1. Product Information
2. Product Safety
3. Notification
4. Labeling
5. Inventory of cosmetic ingredients.
6. Good Manufacturing Practice (GMP).
7. Animal testing alternatives.

More European legislation.
Once you place a claim on the product or packaging, the European Claims Regulation 655/2013 and the Dutch Advertising Code for Cosmetic Products apply.
You may also encounter when manufacturing, importing or trading cosmetic products:
a. European Aerosol Directive 2013/10
b. General Product Safety Directive 2001/95
c. Good Manufacturing Practice guidelines NEN-EN-ISO 22716:2007
d. Reach regulation 1907/2006
e. European Packaging Directive 2004/12
Responsible person or distrubutor?
The obligations depend greatly on the role you perform. Do you produce, import or sell a cosmetic product under your own brand name? Or do you change the composition of an offered product? Then you have the responsibilities of a responsible person, as defined in the Cosmetics Regulation.
Do you supply cosmetics in original condition without putting your brand name on the product and are not an importer or manufacturer? Then you have the obligations of a distributor.
Below is an explanation of the responsibilities and obligations for each role.
Responsible Person Obligations.
Without this dossier, a cosmetic product may not be sold. A product information file consists of 3 parts:
1. General information about the product and manufacturing methods.
2. Part A : product safety information.
3. Part B : product safety assessment
Part A collects all the information that substantiates that the cosmetic product is safe and meets regulatory requirements. Here you consider, among other things, the properties of individual ingredients, the general toxicological profile, the chemical structure and the exposure level of the ingredients.
Part B assesses the data from Part A of the dossier. The product safety assessment should only be done by someone with enough knowledge to do it properly. You can think of a toxicologist or a chemist.
The direct packaging and any repackaging of cosmetics must contain the information described in Article 19 of the Cosmetics Regulation. As the responsible person, you must also check that specific information is present on the label in the languages of the member states where you sell the product.
Is the packaging of a cosmetic product too small to include all the mandatory information? Then the ingredients, directions for use and warnings may be listed in an insert, on an attached sheet, on a separate card or on a leaflet.
All cosmetic products must be notified in the CPNP prior to marketing. A CPNP notification contains specific information about the product, its owner and composition. The notification must also include a copy of the label.
From the portal, information is transmitted to authorities and national poisoning information centers in the member states. In the Netherlands, these are the Dutch Food and Consumer Product Safety Authority and the National Poisons Information Center.
As the responsible person, you must be able to identify all your customers. You must keep this information for at least 3 years after the last purchase.
Distributor obligations.
As a distributor, you are obliged to check that the label of the product you sell is prepared according to the Cosmetics Regulation. You must also check that the information (for which this is mandatory) is listed in the correct languages.
If you have made changes to a label, you need to re-register the product in the CPNP. You do this before you sell the product. Adding a sticker with a translation is also considered an adjustment that you must submit through CPNP.
As a distributor, you must be able to identify your supplier or the responsible person by whom the product was supplied. This also applies to your customers. You must keep this information for at least 3 years after the last delivery.

Need help with safe & fair products?
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