On October 30, 2024, a pilot enforcement project completed by the European Chemicals Agency (ECHA) Enforcement Forum revealed that approximately 6% of cosmetic products in the markets of 13 countries in the European Economic Area (EEA) contain hazardous chemicals banned under the POPs (Persistent Organic Pollutants) Regulation and REACH Regulation.
The inspection covered nearly 4,500 cosmetic products. Enforcement agencies reviewed ingredient lists, focusing on perfluorooctanoic acid (PFOA), long-chain perfluorocarboxylic acids (PFCAs), and their related substances, as well as cyclic siloxanes D4 and D5. The results showed that 285 cosmetic products violated relevant regulations, with detected banned substances including:
- Perfluorononyl dimethicone;
- Perfluorooctylethyl triethoxysilane;
- Perfluorononylethyl carboxydecyl PEG-10 dimethicone; and
- Cyclopentasiloxane (D5), cyclomethicone (a blend of D4, D5 and D6), cyclotetrasiloxane (D4).
Due to their high persistence, bioaccumulation, and toxicity (PBT/vPvB), the use of these chemicals in cosmetics is explicitly banned under the POPs Regulation and REACH Regulation. Studies indicate that these substances are not easily degradable in the environment, which may accumulate in humans and other organisms, and may affect reproductive health and are suspected carcinogens.
Actions by Authorities
In response to this situation, enforcement authorities have taken measures to withdraw non-compliant cosmetics from the market. In most cases, they initially issue written guidance to suppliers to help them understand and comply with legal requirements. It is reported that approximately half of the cases are still under further investigation.
CIRS Group Reminder
This pilot enforcement project, running from November 2023 to April 2024, aims to enhance the regulation of chemical substances in cosmetics, ensuring product safety and protecting consumer health and environmental safety. CIRS Group advises relevant companies to stay updated with the latest regulations and guidelines issued by ECHA to maintain compliance and avoid legal risks and trade barriers.
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