When alcohol is an ingredient in products not intended for consumption, it must be adjusted so that it is has a recognizable smell and an analytical marker that can be used to trace it to the supplier.
No more methanol
The commission’s first recommendation regarding alcohol as a cosmetic ingredient is that methanol should not be used as a denaturant any longer. According to the recommendation methanol poses too high a health risk and is quite easily removed by individuals looking to revert a cosmetic, like perfume, back to consumable alcohol.
When consumed, methanol can lead to death. And the percentage of alcohol, sold worldwide for consumption, that was originally a non-consumable product and may therefore contain a denaturant is too high for the commission to condone the use of methanol any longer.
Twice the assurance
Cosmetic products and perfumes with an alcohol content above 20% should now include two or more chemical denaturants, according to the DG TAXUD recommendations.
The intent here is that with more analytical markers in the product, EU customs labs will be able to determine more accurately if a drinking alcohol is actually a reverted perfume or cosmetic.
A matter of taxation
The European Union taxes alcohol that is intended for consumption. “Alcohol which is not intended for human consumption (e.g. in cosmetics, cleaning products, biofuels etc) is exempt from excise duties. However, in order to benefit from this exemption, the alcohol must be denatured in accordance to required methods laid down at national level (Directive 92/83/EEC, Article 27),” clarifies spirits.eu in a recent article on the rule change.
No industry hardship
Chemical markers IPA and TBA have been suggested as alternative denaturants by the commission for use by cosmetics manufactures.
The commission is confident that, “There is no evidence to suggest that the denaturants IPA and TBA will have any effect on the smell or flavour of cosmetic products,” according to a Q&A the group published regarding the new recommendations. “These denaturants are already widely used in the cosmetic industry, without any negative impact.”
Additionally, any financial effect the new recommendation will have on the beauty industry is expected to be “extremely limited.”
Compliance optional
The excise duty exemption, which the commission extends to the cosmetics industry, is an incentive rather than an enforcement tool (as a fine would be). Companies have the choice of not denaturing the alcohol used in their product formulations and simply paying the tax.