According to McMahon, a QPPV expert at Panacea consultants, implementing the legislation has been a considerable undertaking for cosmetic companies, and some are still trying to get to grips with ensuring consumers are well informed by monitoring the composition and labelling of products.
Regulation (EC) No 1223/2009 replaced the 'Cosmetics Directive' which up until 2013 ensured that products circulated freely whilst guaranteeing a high level of protection for consumers
Suddenly companies were required to be competent in areas like GMP, registration of cosmetic products, product labelling and customer liaison to cosmetovigilance.
Getting to grips..
McMahon says industry veterans like Johnson & Johnson were amongst brands attempting to lead the way in terms of compliance.
The personal care player announced in September 2013 that it would be removing the preservative methylisothiazolinone (MI) from its Piz Buin 1 Day Long Suncream from 2014. The move came following 150 reports of allergic reactions to the sun cream.
By December, Cosmetics Europe had issued an industry-wide recommendation to discontinue the use of MI in leave-on skin cosmetics and personal care products.
"That this was an example of a shift in mindset, acting now rather than waiting for regulatory intervention," she tells CosmeticsDesign-Europe.com.
New Regulation, new expectations
To ensure compliance with the new Regulation, companies must now select a suitable responsible person.
The nominated responsible person’s role is to ensure compliance with regulation. Responsibility covers a range of areas including manufacturing, animal testing, consumer liaison and consumer safety.
A product cannot be placed on the EU market without the assignment of a responsible person. One of the main achievements with the new Regulation is harmonisation across the EU.
Once a cosmetic product conforms with the requirements laid out in the Regulation then each Member State must accept the cosmetic product onto its market without any additional requirements or restrictions at a national level.