I just arrived back from an exciting visit to Paris where Obelis visited Cosmetic 360! A lot of focus in this show was on innovations and solutions. Not just there, but on many more occasions, I have encountered the concept of personalization of cosmetic products. In this model, a manufacturer of cosmetic products offers a standard number of basic ingredients that can be mixed together to achieve a finished product that meets your individual needs. For example, five basic nail colors can be mixed together into thousands of different nail polishes to meet your personal taste; or you can even create your own facial cream from different components based on your personal preferences.
Personalization sounds like a wonderful novelty! What about the regulatory aspects of these personalized cosmetic products? To ensure compliance with Cosmetics Regulation EC 1223/2009 the following should be taken into account:
Any change to any of the following elements will constitute an individual product which will need to have a complete Product Information File (PIF) and CPNP number on its own:
1) The Product Full Name;
For example: “Christine’s Soft Hair Shampoo”.
This product description includes three sub-elements as illustrated below:
i. Brand name – Christine’s
ii. Commercial name- Soft Hair
iii. Function – Shampoo
2) The product’s intended purpose & claims;
3) The product’s formulation. Any variation in the 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.
So, how should we interpret the above? If you have the potential to mix hundreds of different formulas by providing a personalized approach, should all potential formulas be predetermined, have their own PIF and be all separately registered in the CPNP?
Senior Consultant, Sales department
31st October 2019
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