Regulatory issues of personalised cosmetics in the EU
Placing personalised cosmetics on the EU market poses several regulatory challenges in relation to the EU Cosmetics Regulation. Not all product commercialisation formats ensure compliance with mandatory legal and consumer safety requirements. This article will review and analyse some of the personalised cosmetics available on the market and their compliance with key provisions of the EU Cosmetics Regulation.
Personalisation of cosmetic products is a popular trend whereby consumers can change ingredients in the product to suit their specific needs. Despite bespoke changes to products being a widely established practice, reaching full regulatory compliance poses several challenges in the EU, where cosmetic products must comply with the requirements listed in Regulation 1223/2009 (1) (the Regulation).
WHAT ARE THE REGULATORY REQUIREMENTS IN THE EU?
The Responsible Person1 (RP) placing a cosmetic product in the EU market must ensure the product is compliant with the relevant obligations set out in the Regulation. Compliance with the following Articles in the Regulation can be easily achieved and will therefore not be reviewed in-depth in this article: Articles 14 to 17 (ingredient restrictions); Article 18 (animal testing ban); Article 20 (claims compliance with Regulation 655/2013 (2)); Articles 21 and 24 (access to information on the product).
Unlike the Articles cited above, those listed below may pose significant challenges if legal requirements are to be fulfilled before placing ...