ALLERGENS in fragrances, NEW labeling for cosmetic products

There are likely to be many new developments, with a strong impact on the labelling of substances identified as contact allergens. In fact, another 62 substances that are part of the composition of fragrances and identified by SCCS (Scientific Committee on Consumer Safety) in its opinion of 27 June 2012 "OPINION on Fragrance allergens in cosmetic products" as potential allergens will probably be added to the current 26. Translated with www.DeepL.com/Translator (free version)

In 2019, the European Commission had requested an impact assessment study from a consulting firm to decide how to proceed with the labeling of these substances. In December 2020, the Final Report "The Impact Assessment study on fragrance labelling on cosmetic products (575/PP/2016/FC)" was published.

If on the one hand it is extremely important for the health of consumers to have an accurate indication of allergens, on the other hand an equally important aspect that must be considered is that related to the problems of legibility and transparency of the information that will have to appear in some way on the packaging, as well as the economic and environmental impact that the disposal of packs with labeling not complying with any new provisions could entail if a sufficiently long transition period is not chosen.

There are three possible scenarios for future labeling management

  1. maintain the current situation, i.e. only the indication of the current 26 allergens according to the Cosmetics Regulation 1223/2009;
  2. report all allergens on the label (26+62) according to the current rules established by the Cosmetics Regulation 1223/2009;
  3. use E-labelling (electronic labelling) in three possible ways: use of a reference on the label to a "dedicated" web address, use of a QR code, use of barcode

However, the position of the cosmetics industry is to have the choice of communicating allergens on the pack (on the label) or digitally, but using the same modality for both the current 26 allergens and the new 62.

In addition, a transition period of at least 3 years is required for the new labeling considering that industry estimates predict that the indication of allergens (current 26 + additional 62) will involve 80 - 90% of all cosmetics and that cosmetics already on the market can still be sold until exhausted, without any withdrawal.

The decision of the EU Commission is expected in the coming months.