On October 28th, 2015, the European Chemical Agency (ECHA) has published its proposal to update the Community Rolling Action Plan (CoRAP) for 2016-2018. The final plan will be adopted in March next year, and it is expected that the Member States will evaluate 138 substances, 53 of which are newly selected.
What is CoRAP?
Articles 44 to 48 of the REACH Regulation 1907/2006/EC provide for the process of substance evaluation, which allows for clarification of potential health or environmental risks. The CoRAP is the document, in which Member States, in cooperation with ECHA, list the substances of concern to be evaluated. The evaluation process runs in the following way:
- The Member State responsible for evaluating a substance may draft a decision, requesting further information by the registrants of the said substances.
- After the submission of the draft decision, the registrants may submit comments or update their dossiers with relevant information regarding the pending concern.
- The comments and updated dossier will be taken into account by the evaluating Member State.
- If the Member State decides to proceed with the decision, it has to be reviewed with the comments made by the registrants by the other evaluating Member States and ECHA.
- The final decision, requiring the registrants to submit the requested information, will be adopted by ECHA after the approval of the Member State Committee.
The outcome may be twofold: the Member States may decide that the current regulatory framework is effectively addressing the posed risks to human health or the environment, or that further steps need to be taken at EU level, such as restrictions, identification of substances of very high concern, or others.
CoRAP 2016-2018
The current update of the CoRAP divides the substances to be evaluated in the next three years. There are 138 substances in total: 53 newly added substances, and 85 substances already present in the last year’s CoRAP update (17 March 2015). It includes the names, CAS and EC numbers, the initial grounds for concern, and the contact information of the Member State who will evaluate the substance.
Some of the newly added substances, which are used in beauty products, include: Methylene di-t-butylcresol, Dioxolane, Dichloromethane, Cyclohexanone and Benzaldehyde. Many of the already existing substances are also frequently used by makeup manufacturers.
Conclusion
Even though the evaluation process is not performed under the EU Cosmetics Regulation, it may have direct impact on the beauty products market. This is because many of the evaluated substances are used in health and beauty products. In case some of these substances are considered as unsafe, the cosmetics regulatory compliance requirements will be changed.
This process has to be followed by the cosmetic industry and their designated European Responsible Person in order to ensure their product regulatory compliance with product safety regulations.