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Recent ATPs and the 8th Amendment
By: David Steinberg, Steinberg & Associates
Posted: January 29, 2010, from the February 2010 issue of Cosmetics & Toiletries.
- Table 2. (continued) (PDF 115 KB)
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Although the recast of the EU Cosmetic Regulations is intended to simplify the regulations, the recent ATPs confirm that the regulation will continue to be confusing and user-unfriendly. The EU Commission continues to add ingredients to its prohibited list in the order in which they are prohibited, which makes them difficult to search for and thus, comply with. One solution might be to place them in alphabetical order and rewrite the regulation each time there is a change. In this author’s opinion, the EU should always list the prohibited ingredients by INCI name; if the prohibited ingredients have no INCI name, they should not be on the list since they are not used in cosmetics.
The new warnings and pictogram for hair dyes will cause more clutter on packaging with no proof that the user will read or follow them. Further, all warnings must be in all 22 official languages, which will require the packaging to be much larger.
Finally, this author fully supports the banning of phytonadione or vitamin K1 since it has caused deaths in France from minuscule use levels in cosmetics. It also serves no function except for labeling claims.