CMR (Carcinogenic, Mutagenic, Reprotoxic substances) and new starting point


Giulio Pirotta
Neovita consulting, Uboldo (VA), Italy

It’s quite sure that none of formulators I know will add a renowned carcinogenic substance on a cosmetic product, but the actual system governing chemicals is rather more complex than the common simple perception based on the binary system YES/NO. 

This argument is quite sensitive also when we start to talk with chemo-phobic people with the more undefined assumption natural (what?)=safe chemical(again what?)=toxic.

Some of these issues have been addressed in the article 15 of the European cosmetic regulation 1223/09/CE (1), quite simple: CMR (Carcinogenic, Mutagenic, Reprotoxic substances) substances are forbidden, but with a caveat of some exceptions when evaluated from SCCS and included in the annexes of the regulation.

Writing the recast of the rules for cosmetics it has been a real hard work and some point missed, among these the automatic ban that the text included after a substance is included in the list of annex VI of Regulation (EC) 1272/2008. The fast-moving system of this classification is updated about one/two times a year and it’s not quite easy to stay updated (have you navigated through the ECHA website recently?).