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  • Writer's pictureDaniel Jiménez

Understanding REACH: Its Impact on Cosmetic Products

Discussions around the Regulation (EC) 1907/2006, widely known as REACH, resurfaced. Initiated in 2007, REACH revolutionized the regulation framework for chemicals within the EU, focusing on the registration, evaluation, authorization, and restriction of chemicals. Its primary mission is to safeguard human health and environmental integrity while fostering the EU's competitive edge and innovative capabilities.


The Role of the European Chemicals Agency


The enactment of REACH led to the establishment of the European Chemicals Agency (ECHA) in Helsinki, Finland. This EU agency is pivotal in executing REACH and other chemical-related legislations, such as the Classification, Labelling, and Packaging (CLP) Regulation. ECHA's responsibilities include:

 

  • Administering the chemical registration database

  • Coordinating the appraisal of registration dossier data

  • Supervising the identification and restriction process for substances of very high concern (SVHC)

  • Providing independent scientific counsel and recommendations to the European Commission

Key Components of REACH


Under REACH, entities that manufacture or import over one ton of a chemical annually are mandated to register it with ECHA. This registration encapsulates comprehensive details on the substance's characteristics, applications, hazards, and risk management strategies. It's incumbent upon companies to maintain current registration dossiers. ECHA, in turn, validates these submissions to ensure regulatory adherence and assess substance safety.

 

Furthermore, any member state or the European Commission can suggest EU-wide restrictions on certain chemicals, like France's proposal regarding Octocrylene. These proposals are subject to public scrutiny, followed by assessments from ECHA's Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) Committees. The European Commission contemplates these evaluations before finalizing restrictions, which are then cataloged in Annex XVII to REACH.

 

Moreover, REACH delineates an authorization protocol for SVHCs, listed in Annex XIV. Post the sunset date, these substances require European Commission approval for specific uses under designated conditions to remain in the EU market.

 

REACH's Influence on Cosmetic Regulations


REACH's broad legislative scope covers chemicals in their isolated form, within mixtures, and as product components, thereby impacting sector-specific regulations, including those governing cosmetics under Regulation 1223/2009.

This interaction manifests in various forms:

 

  • Direct restrictions by REACH on specific substances in cosmetics that are not addressed by the EU Cosmetics Regulation, such as D4, D5, D6, and intentionally added microplastics.

  • Automatic bans on substances classified as carcinogenic, mutagenic, or toxic for reproduction (CMR) in cosmetics, implemented through Omnibus Acts.

  • Potential supply chain disruptions for cosmetic chemicals due to REACH-imposed bans or authorization necessities.


An additional consideration is the testing of multiuse substances on animals under REACH, which may apply to ingredients potentially utilized in cosmetics.

 

REACH's comprehensive framework underscores a balanced approach to chemical management, prioritizing safety and innovation while influencing the cosmetics industry through its regulatory measures.




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