The European Commission addendum: a clarification of banned claims in cosmetics for hand gels
In November, a sub-working group of the European Commission published an addendum to the Borderline Manual on cosmetic products that may be subject to other regulations.
This document presents a negative list of claims, references and images that are prohibited in the marketing of a cosmetic product, and would classify a leave-on cleanser as a biocidal product. Most of these elements refer to viruses and bacteria, and all of them could mislead the consumer into thinking that the gel they are about to buy is effective against bacteria and viruses when it is not necessarily the case. The classification of this type of product is done on a case-by-case basis (formula analysis, label, etc.).
Please note, however, that the list provided is not exhaustive, and this document is not legally binding. The (re)qualification of a product as a cosmetic or biocide is therefore not automatic.
Let's go back to the basics: biocidal products are substances or preparations designed to destroy, repel or render harmless organisms considered harmful. A cosmetic is "any substance or mixture intended to be placed in contact with the external parts of the human body [..] or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours�.
The purpose of the 2 products is therefore not the same. However, nothing prohibits a cosmetic product from containing alcohol: many hand cleansers contain alcohol to facilitate evaporation, just like perfumes.
The assessment of a product as a cosmetic or biocide is free to each Member State, when the rules are not clearly established (biocidal function, cosmetic function, specific labelling, etc.), which is why we recommend that you be cautious, depending on your target markets.
EcoMundo accompanies you in the marketing of your products, whether biocides or cosmetics. Don't hesitate to contact our experts for more information!
The interest of marketing a cosmetic product vs. biocides
Cosmetic products are quicker and cheaper to market. This is the main advantage of marketing a leave-on cleansing gel rather than a hand disinfectant.
However, in the midst of a health crisis, hand disinfectants are increasingly useful and in demand by consumers, who want to be reassured about Coronavirus. To do this, having the words "Virucide", "Effective against Coronavirus" or "Kills 99% of bacteria" can be a major advantage. This is why considering the biocidal product option before marketing can also prove to be very profitable.
Wish to know more about the European compliance of your cosmetic and biocidal products?
For more information, do not hesitate to contact Sylvain de Backer or one of our experts!
The European Commission addendum: a clarification of banned claims in cosmetics for hand gels
In November, a sub-working group of the European Commission published an addendum to the Borderline Manual on cosmetic products that may be subject to other regulations.
This document presents a negative list of claims, references and images that are prohibited in the marketing of a cosmetic product, and would classify a leave-on cleanser as a biocidal product. Most of these elements refer to viruses and bacteria, and all of them could mislead the consumer into thinking that the gel they are about to buy is effective against bacteria and viruses when it is not necessarily the case. The classification of this type of product is done on a case-by-case basis (formula analysis, label, etc.).
Please note, however, that the list provided is not exhaustive, and this document is not legally binding. The (re)qualification of a product as a cosmetic or biocide is therefore not automatic.
Let's go back to the basics: biocidal products are substances or preparations designed to destroy, repel or render harmless organisms considered harmful. A cosmetic is "any substance or mixture intended to be placed in contact with the external parts of the human body [..] or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours�.
The purpose of the 2 products is therefore not the same. However, nothing prohibits a cosmetic product from containing alcohol: many hand cleansers contain alcohol to facilitate evaporation, just like perfumes.
The assessment of a product as a cosmetic or biocide is free to each Member State, when the rules are not clearly established (biocidal function, cosmetic function, specific labelling, etc.), which is why we recommend that you be cautious, depending on your target markets.
EcoMundo accompanies you in the marketing of your products, whether biocides or cosmetics. Don't hesitate to contact our experts for more information!
The interest of marketing a cosmetic product vs. biocides
Cosmetic products are quicker and cheaper to market. This is the main advantage of marketing a leave-on cleansing gel rather than a hand disinfectant.
However, in the midst of a health crisis, hand disinfectants are increasingly useful and in demand by consumers, who want to be reassured about Coronavirus. To do this, having the words "Virucide", "Effective against Coronavirus" or "Kills 99% of bacteria" can be a major advantage. This is why considering the biocidal product option before marketing can also prove to be very profitable.
Wish to know more about the European compliance of your cosmetic and biocidal products?
For more information, do not hesitate to contact Sylvain de Backer or one of our experts!
