In order to ensure a product is indeed a cosmetic product, the product formulation, characteristics, sites of application and intended functions must match the definition of a cosmetic product as defined in the scope of Cosmetic Regulation EC 1223/2009, which came into effect in 2013.
Once the product has been found to match the definition of a cosmetic product (as per Art. 2 p.1a) the cosmetic product categories listed in Regulation EC/1223/2009 (in preamble 7) need to be considered. The next step is then to outline how products can be grouped together as product families, thus determining the creation of the respective PIF.
How to differentiate between products?
Regulations governing the differentiation between products under EU regulations state the following:
“Any change to any of the following elements will constitute an individual product which will need to have a complete Product Information File (PIF) of its own.” This includes:
- The product’s full commercial name. For example: “Christine’s Soft Hair Shampoo”. This product description includes three sub-elements as illustrated below:
a) Brand name – Christine’s
b) Commercial name – Soft Hair
c) Function – Shampoo
2. The product’s intended purpose and claims
3. The product’s formulation
Furthermore, any change in the product’s formulation (qualitative or quantitative) is considered to be a significant change in the relations between the chemicals and these exact changes need to be assessed:
Only color variants may be grouped as a single family of products; i.e., all products should share the exact same formula with the only difference between them being the color.
Based on the above information you can now more easily determine how many products you have.
If you find yourself unable to make distinctions in your range of cosmetic products then a professional company with experience in cosmetics – offering Responsible Person services (like Obelis) – will be able to advise you on the number of product families you have. For more information and unlock support, please contact us.