Cosmetic Ingredient and Regulatory Update: The Ugly, the Good and the Bad

May 1, 2012 | Contact Author | By: David C. Steinberg, Steinberg Consultants
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Title: Cosmetic Ingredient and Regulatory Update: The Ugly, the Good and the Bad
D5x methanolx REACHx Proposition 65x Health Canadax
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Keywords: D5 | methanol | REACH | Proposition 65 | Health Canada

Abstract: This review takes a look at updates to ingredient regulations as of the first quarter in 2012. While “the ugly” refers to the EU Chemical Agency’s (ECHA’s) release of the first ingredients to be evaluated under REACH, the good news relates to the battle in Canada to save D5. “The bad” are the state of California’s addition of three ingredients to the Proposition 65 list, as well as Health Canada’s caution against labeling using generic terms.

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So far, 2012 has been a busy year for cosmetic ingredient regulations. On February 29, the ECHA released its list of the first 90 ingredients to be evaluated under REACH. Included were cosmetic ingredients as well as starting materials for other ingredients. Those used by the personal care industry are listed in Table 1 (in the full article), along with the concerns for each. Considering this list, the European personal care industry is in trouble if these ingredients are restricted or even worse, phased out because the manufacturing of them as well as products containing them would be forced out of the EU. Also considering the current economic environment, this is not a good political move since cosmetic companies and chemical suppliers are already under pressure from foreign imports, and this would be another reason to move everything offshore, which would destroy local manufacturing bases and related jobs.

Starting ingredients—methanol: First, consider the impact of potential restrictions on starting ingredients. Methanol is rarely used as a denaturant in alcohol and it is prohibited in Japan, so limiting it as a cosmetic ingredient will not concern the industry. However, methanol is the preferred solvent to separate unsaturated fatty acids from saturated fatty acids. So if there are users of this starting material in the EU, they might be compelled, like their competitors, to move operations to Southeast Asia. Another major use of methanol is to transesterify coconut oil to methyl cocoate, which is the major starting material for producing coco-based amides. Methyl cocoate can be fractionally distilled to form the pure methyl esters of C6 to C18 fatty acids.

Of importance to personal care is the fact that methyl laurate is used to make lauramides, methyl myristate is used to produce isopropyl myrsitate, and methyl palmitate is used to make retinyl palmitate. Finally, the methyl esters of coconut oil can be hydrogenated to form the so-called natural fatty alcohols, which find use both as cosmetic ingredients and as starting materials for many emollients, surfactants and emulsifiers. If they cannot be produced in the EU, they must be produced elsewhere.

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Table 1. Personal care-related ingredients to be evaluated under REACH

Table 1. Personal care-related ingredients to be evaluated under REACH

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