New regulations, specifically in the cosmetics sector, introduce the concept of the ‘Responsible Person’ having ultimate legal obligation for all aspects of cosmetic safety - from raw material specification, the manufacturing process, product labelling and claims to the monitoring and resolution of adverse findings related to product use.
The EU Cosmetic Regulation, following the principle established with the REACH Regulation, enables these legal obligations to be transferred by written mandate to a third party organisation or person.
Article 4 of the Regulation states that ‘only a cosmetic product for which a legal or natural person is designated within the community as a Responsible Person shall be placed on the market’ and further that the Responsible Person ‘shall ensure compliance with the relevant obligations set out in the Regulation’.
The Responsible Person therefore plays the key role in ensuring that the cosmetic product put onto the market is safe for human health when used under normal or reasonably foreseeable conditions of use. In order to be able to fulfil these obligations the Responsible Person will need to be able to work with all aspects of the product supply chain; from the marketing department, the raw materials supplier through to the manufacturing plant.
Figure one gives a representation of a cosmetic product supply chain highlighting the way that all elements need to work together in order to legally bring a product to market. It can be seen that the activity of the Responsible Person touches all aspects of the product process from development through production to placing the product on the market. There are numerous challenges that arise when considering the obligations the Responsible Person is required to fulfil under the terms of the Regulation; perhaps one of the principle issues is one of knowledge and authority. The practical aspects of managing the volume of data, maintaining and verifying the information are also important considerations that need to be taken into account.
Delphic HSE offer a service to act as your appointed third party Responsible Person which will ensure:
Your responsibility to ensure human health is not at risk from your cosmetic product.
Ensure the description of your product tells an accurate and verifiable story.
Close examination of cosmetics and their raw properties to ensure consumer safety.
We are excited to announce that Tom Garner will be joining the Board of Directors as a Non-Executive Director of Delphic HSE.
| by Cliff Betton |
Posted 14th January 2018
This article considers that False eyelash adhesives are not classified as cosmetics in the EU, but should instead follow the General Product Safety Directive and the CLP.
| by James Wakefield |
Posted 18th December 2017
Dr Lin Yang, Delphic HSE Toxicologist will be speaking at in-cosmetics Asia held in Bangkok from 31 October to 2 November 2017.
Posted 22nd October 2017