Cosmetic Product Notification

Report
Cosmetic Product Notification
in the EU
R. MONTIGNY
Regulatory Advisor –
International Scientific Regulatory Affairs , L’OREAL
2012 International cosmetic PIF, Notification and GMP practices management training - TAIPEI 4th
December 2012
Cosmetic Product Notification
The Cosmetic Product Notification is a
procedure which exists since the time when the
EU Cosmetic Directive 76/768 ECC started its
first implementation in the year 1976.
Notification allows member states authority to
become aware of the placing on the market of
a new cosmetic product by its marketer (i.e. its
manufacturer, distributor or importer).
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Cosmetic Product Notification
The manufacturer or his agent, or the person to
whose order a cosmetic product is manufactured,
or the person responsible for placing imported
cosmetic products on the Community market, shall
notify the competent authority of the Member State
of the place of manufacture or of the initial
importation, of the address of the place of
manufacture, or of initial importation into the
Community, of the cosmetic products before the
latter are placed on the Community market.
(EU Cosmetic Directive 76/768 EEC Art. 7-2)
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Cosmetic Product Notification
If we look at the EU Cosmetic regulation as the
rules which governs the mechanism involving
the 3 actors: Consumers, Regulators, Industry,
REGULATORS
CONSUMERS
INDUSTRY
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Cosmetic Product Notification
Notification will trigger the Post Marketing
Surveillance process leading to inspection and inmarket control from the authorities side. It is
therefore an important step in the process.
-------EU Cosmetic Directive 76/768 had to be
transposed into each member state national law
apparatus and as a result, the way notification is
conducted in each countries came to be very
different from one place to another.
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Cosmetic Product Notification
For this reason the reform brought in by the
new regulation EC 1223/2009 changed this
situation entirely and set up a modernized
process common to all the member states
which put away all the existing discrepancies.
This process is based on a online registration
through Internet at one common portal: the
Cosmetic Product Notification Portal (CPNP)
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Cosmetic Product Notification
What is the Cosmetic Products Notification
Portal (CPNP)?
The CPNP is the online notification system
created for the implementation of Regulation
(EC) N° 1223/2009 of the European
Parliament and of the Council on cosmetic
products.
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Cosmetic Product Notification
What information needs to be entered into the
CPNP?
Article 13 of Regulation (EC) N° 1223/2009
lists the information that the responsible
persons and, under certain circumstances, the
distributors of cosmetic products shall notify
through the CPNP about the products they
place or make available on the European
market.
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Cosmetic Product Notification
Article 13 Notification
1. Prior to placing the cosmetic product on the
market the responsible person shall submit, by
electronic means, the following information to
the Commission:
(a) the category of cosmetic product and its
name or names, enabling its specific
identification;
Regulation (EC) No 1223/2009 Art. 13 - 1
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Cosmetic Product Notification
(b) the name and address of the responsible
person where the product information file is
made readily accessible;
(c) the country of origin in the case of import;
(d) the Member State in which the cosmetic
product is to be placed on the market;
Regulation (EC) No 1223/2009 Art. 13 - 1
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Cosmetic Product Notification
(e) the contact details of a physical person to
contact in the case of necessity;
(f) the presence of substances in the form of
nanomaterials and:
(i) their identification including the chemical name
(IUPAC) and other descriptors as specified in point 2
of the Preamble to Annexes II to VI to this
Regulation;
(ii) the reasonably foreseeable exposure conditions;
Regulation (EC) No 1223/2009 Art. 13 - 1
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Cosmetic Product Notification
(g) the name and the Chemicals Abstracts
Service (CAS) or EC number of substances
classified as carcinogenic, mutagenic or toxic
for reproduction (CMR), of category 1A or 1B,
under Part 3 of Annex VI to Regulation (EC) No
1272/2008;
(h) the frame formulation allowing for prompt
and appropriate medical treatment in the event
of difficulties.
Regulation (EC) No 1223/2009 Art. 13 - 1
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Cosmetic Product Notification
2. When the cosmetic product is placed on the
market, the responsible person shall notify to
the Commission the original labeling, and,
where reasonably legible, a photograph of the
corresponding packaging.
Regulation (EC) No 1223/2009 Art. 13 - 2
In the new regulation this notification duty is
extended to distributor under certain conditions.
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Cosmetic Product Notification
For purposes of clarification, a definition of
distributor is provided in the regulation:
‘distributor’ means any natural or legal person
in the supply chain, other than the
manufacturer or the importer, who makes a
cosmetic product available on the Community
market;
Regulation (EC) No 1223/2009 Art. 2 – 1,(e)
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Cosmetic Product Notification
As from 11 July 2013, a distributor who makes
available in a Member State a cosmetic product
already placed on the market in another Member
State and translates, on his own initiative, any
element of the labeling of that product in order
to comply with national law, shall submit, by
electronic means, the following information to
the Commission:
…/…
Regulation (EC) No 1223/2009 Art. 13 – 3
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Cosmetic Product Notification
(a) the category of cosmetic product, its name in
the Member State of dispatch and its name in
the Member State in which it is made
available, enabling its specific identification;
(b) the Member State in which the cosmetic
product is made available;
(c) his name and address;
(d) the name and address of the responsible
person where the product information file is
made readily accessible. …/…
Regulation (EC) No 1223/2009 Art. 13 – 3
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Cosmetic Product Notification
Similar disposition exists for product which has
been placed on the market before 11 July
2013 but is no longer placed on the market as
from that date, but introduced in a Member
State after that date, by a distributor.
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Cosmetic Product Notification
5. The Commission shall, without delay, make the
information referred to in points (a) to (g) of
paragraph 1, and in paragraphs 2 and 3 available
electronically to all competent authorities.
That information may be used by competent
authorities only for the purposes of market
surveillance, market analysis, evaluation and
consumer information in the context of Articles 25,
26 and 27.
(Regulation (EC) No 1223/2009 Art. 14 – 5)
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Cosmetic Product Notification
information referred to in paragraphs 1, 2 and 3 will
be made available electronically to poison centers or
similar bodies, where such centers or bodies have
been established by Member States. These
information may be used by those bodies only for the
purposes of medical treatment.
Regulation (EC) No 1223/2009 Art. 13 - 6
Where any of the information set out in paragraphs 1,
3 and 4 changes, the responsible person or the
distributor shall provide an update without delay.
Regulation (EC) No 1223/2009 Art. 13 - 7
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Cosmetic Product Notification
What the CPNP does with the information
entered?
The CPNP makes some of this information
available electronically to the competent
authorities (for the purposes of market
surveillance, market analysis, evaluation and
consumer information) and to the poison
centers, or similar bodies established by
Member States (for the purposes of medical
treatment)
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Cosmetic Product Notification
When does information have to be entered into
CPNP?
As from 11 January 2012, a responsible
person will have the possibility to notify through
CPNP, by way of derogation from Directive
76/768/EEC, the information referred to in
Article 13(1) and (2) of Regulation (EC) No
1223/2009. As from 11 July 2013, the use of
CPNP will become mandatory.
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Cosmetic Product Notification
Two systems are needed:
- The European Commission Authentication Service
(ECAS).
This system provides the user with a login and
password to connect to multiple European
Commission applications.
- The SANCO Authentication and Authorization System
(SAAS).
This system provides the user with a profile and
access rights for a specific European Commission
application, in this case the CPNP.
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Cosmetic Product Notification
All CPNP users should be part of what is called an
'organization'. An organization means either a
'responsible person' (or its sub-organizations), a
'distributor', a 'competent authority' or a 'poison
center'.
Confidentiality aspects
Some of the data contained in CPNP are business
confidential information thus a warning message
is displayed on the home page for the competent
authorities and for the poison centers, when they
connect to the CPNP for enhancing this point.
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Cosmetic Product Notification
A responsible person or a distributor can search for
and display only the products it (or a user acting on
its behalf) has entered into the system.
Products of one responsible person or of one
distributor are not accessible to another
responsible person or distributor. A responsible
person or a distributor can search for its draft and
submitted notifications.
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Cosmetic Product Notification
Product Category and Frame formula.
Frame formulation
‘Frame formulation’ means a formulation which lists the
category or function of ingredients and their maximum
concentration in the cosmetic product or gives relevant
quantitative and qualitative information whenever a
cosmetic product is not covered or only partially covered
by such a formulation. The Commission shall provide
indication for the establishment of frame formulation and
adapt them regularly to scientific and technical progress.
Regulation (EC) No 1223/2009 Art. 2 – 1 - (s)
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Cosmetic Product Notification
Category of cosmetic product
The responsible person has to select three
category levels, starting by the level 1, followed
subsequently by level 2 and 3.
In some rare cases, products may have several
'functions' that may make them fall under
different categories. In these cases, it is the
primary function that has to be considered for
the categorization of the cosmetic product.
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Cosmetic Product Notification
The choice of a category at level 1 determines the
categories available at level 2; the choice of a category at
level 2 will determine the categories available at level 3.
Example:
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Cosmetic Product Notification
There are 4 level-one defined categories:
– Skin products (with 10 level-two categories )
– Hair and scalp products (with 4 level-two categories )
– Nails and Cuticle products (with 4 level-two categories )
– Oral hygiene products (with 4 level-two categories )
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Level 1
Level 2
Level 3
Face care products other than face mask
Face mask
Eye contour products
Lip care products
Hand care products
Skin care Products
Foot care products
Body care products
External intimate care products
Chemical exfoliation products
Mechanical exfoliation products
Skin Products
Skin lightening products
Other skin care products
Soap products
Bath / shower products
Skin Cleansing Products
Make-up remover products
External Intimate hygiene products
Other skin cleansing products
Chemical depilatories
Body Hair Removal Products
Physical epilation products
Other body hair removal products
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Cosmetic Product Notification
Level 1
Level 2
Bleach for Body hair products
Correction of body odour and/or
perspiration
Shaving and pre- / after- shaving
products
Skin products
(following)
Make-up products
Level 3
Bleach for body hair
Products with antiperspirant activity
Products without antiperspirant activity
Shaving products
Pre- / after-shaving products
Other shaving and pre- / after- shaving products
Foundation
Concealer
Other face make-up products
Mascara
Eye shadow
Eye pencil
Eye liner
Other eye make-up products
Lip stick
Lipstick sealer
Other lip make-up products
Body or face paint , including "carneval make-up"
Other make-up products
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Cosmetic Product Notification
Level 1
Level 2
Perfumes
Skin Products
(following)
Sun and self-tanning products
Other skin products
Hair and scalp
products
Level 3
Hydroalcoholic perfumes
Non Hydroalcoholic perfumes
Before and after sun products
Sun protection products Self-tanning products
Other sun and self-tanning products
Other skin products
Shampoo
Hair conditioner
Hair and scalp care and cleansing Scalp and hair roots care products
Antidandruff products
products
Antihairloss products
Other hair and scalp care and cleansing products
Oxidative hair colour products
Non-oxidative hair colour products
Hair coloring products
Hair bleaching and dye remover products
Other hair colouring products
Products for temporary hair styling
Permanent wave products
Hair styling products
Hair relaxer / straightener products
Other hair styling products
Hair sun protection products
Other hair and scalp products
Other hair and scalp products
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Cosmetic Product Notification
Level 1
Level 2
Nail varnish and remover
products
Nails and Cuticle
Products
Nail care/nail hardener products
Nail glue remover products
Other nail and cuticle products
Tooth care products
Oral Hygiene products Mouth wash/breath spray
Tooth whiteners
Other oral Hygiene products
Level 3
Nail varnish / Nail make-up
Nail varnish remover
Nail varnish thinner
Nail bleach
Other nail varnish and remover products
Nail care products
Nail hardener
Other nail care / nail hardener products
Nail glue remover
Cuticle remover / softener
Nail sculpting products
Other nail and cuticle products
Toothpaste
Tooth cleansing powder / salt
Other tooth care products
Mouth wash
Breath spray
Other mouth wash / breath spray products
Tooth whiteners
Other oral Hygiene products
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Cosmetic Product Notification
The total number of level-three categories is 82;
All existing categories can be found in Annex III of
the CPNP User Manual.
To complete the procedure, input of a Formulation
name is necessary. Depending on the category
selected, CPNP proposes a list of possible
formulation names in a dropdown menu. This
information provides a more detailed product
categorization and is made available to Poison
centers only.
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Cosmetic Product Notification
Once the formulation name is decided, 3 types of
formula notification are possible:
o Predefined frame formulation
o Exact concentration
o Concentration ranges
If the responsible person selects 'predefined frame
formulation', the CPNP will automatically propose the
corresponding predefined frame formulation on the
basis of the category and formulation name selected
by the responsible person.
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Cosmetic Product Notification
Categories, sub categories definitions as well as
predefined frame formulations were compiled by
the members of an expert group composed of
representatives from EU authorities and industry
association and Poison Centers.
Notification via predefined frame formulation can
be done only if composition falls completely within
the concentration ranges proposed in this frame.
Examples of some predefined frame formula …/…
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Frame formulation Number: 1.1 – 2011
SKIN CARE CREAM, LOTION, GEL
Ingredients
Maximum levels (% w/w)
Oils (e.g. vegetable and/or mineral), waxes and fats
(e.g. long chain alcohols)…………………………………………………………………………………..30
Silicones including volatile silicones (e.g. cyclopentasiloxane, dimethicone)………..20
Humectants (e.g. glycerin, propylene glycol, PEG) ………………………………………………20
Ethanol (alcohol, alcohol denat.) ……………………………………………………………………….10
Additional ingredients (e.g. vitamins, antioxidants, plant extracts) ………………………10
Bulking agents (e.g. talc, silica, nylon powder)………………………………………………………5
UV filters …………………………………………………………………………………………………………….5
Emulsifying agents, anionic / amphoteric / non-ionic surfactants
(e.g. PEG stearate, ceteareth) …………………………………………………………………………….5
Preservatives, antimicrobials………………………………………………………………………………2
Colorants …………………………………………………………………………………………………………..2
Perfume………………………………………………………………………………………………………………….1
Aqua…… …………………………………………………………………………………………………..…. to
100
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Frame formulation Number: 7.8 - 2011
LIP COLOUR and GLOSSER/BALM
Ingredients
Maximum levels (% w/w)
Oils (e.g. vegetable and/or mineral), waxes and fats(e.g. long chain alcohols)......................... 90
Film forming polymers (e.g. stearalkonium hectorite, polybutene) ………………………………… 80
Emollients (e.g. glycerin, propylene glycol) ……………………………………………………… 50
Silicones including volatile silicones (e.g. cyclopentasiloxane, dimethicone) ………………………… 50
Liquid paraffin and isoparaffin(e.g. branched-chain isoparaffin (C11-C16), isododecane, isohexadecane)….. 40
Aqua ………………………………………………………………………………………. 40
Colorants, colour additives (e.g. opacifying / pearlescent agents) ……………………………… 30
Bulking agents (e.g. talc, silica, nylon powder) ………………………………………………….. 20
Emulsifying agents (e.g. trioleyl phosphate) ……………………………………………………. 5
Photoprotective products contain UV filters (e.g. titanium dioxide, zinc oxide) ………………….. 10
Thickeners (e.g. carbomer, hydroxyethylcellulose) ………………………………………………… 10
Ethanol and/or isopropanol (alcohol, alcohol denat., isopropyl alcohol) ……………………………. 5
Additional ingredients (e.g. vitamins, proteins, antioxidants) ………………………………….. 5
Parfum ……………………………………………………………………………………… 2
Preservatives, antimicrobials ……………………………………………………………….. 1
Flavouring agents …………………………………………………………………………… 1
Oral care-sweetening agents (e.g. saccharin) ……………………………………………………0.02
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Frame formulation Number: 7.22 - 2011
MASCARA - REGULAR
Ingredients
Maximum levels (% w/w)
Film forming polymers (e.g. ammonium acrylates copolymer,
cellulose derivatives, acetyl trihexyl citrate) ………………………………………………… 45
Oils (e.g. vegetable and/or mineral), waxes and fats (e.g. long chain alcohols)……………. 30
Colorants, colour additives (e.g. opacifying / pearlescent agents) ……………………….. 25
Emulsifying agents (e.g. TEA-stearate) …………………………………………………… 20
Silicones including volatile silicones (e.g. cyclopentasiloxane, dimethicone) …………………… 20
Humectants (e.g. propylene glycol, glycerin) ………………………………………………. 15
Thickeners (e.g. magnesium silicate, aluminum silicate, PEG derivatives) .....................................15
Ethanol (alcohol, alcohol denat.) …………………………………………………………. 11
Fibres (e.g. cellulose, nylon fibres) ………………………………………………………… 10
Emollients (e.g. isopropyl myristate) ……………………………………………………… 5
Additional ingredients (e.g. vitamins, plant extracts) ……………………………………. 5
Preservatives, antimicrobials …………………………………………………………… 2.5
Parfum…………………………………………………………………………………. 1
Aqua …………………………………………………………………………………. to 100
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Cosmetic Product Notification
Depending on the product categories, the
physical form and the formulation frame name
selected, additional information may be asked by
CPNP on specific ingredients of concern.
These ingredients are for example:
• Ethanol/ isopropanol (%W/W)
• Antidandruff products active agents (INCI,%)
• Skin lightening products active agents (INCI,%)
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Cosmetic Product Notification
•
•
•
•
Chemical exfoliating agents (INCI+ %)
Vitamin A or its derivatives (% as retinol if >0,2%)
Xanthine derivatives (INCI + % if >0,5%)
Cationic surfactants with 2 or + chains <C12
•
(INCI name to be specified if non preservative function)
•
•
•
•
Products containing propellants (INCI + %)
Products containing H2O2 (% or INCI for H2O2 releasers)
Products containing reducing agents (INCI + %)
Product containing persulfates (INCI + %)
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Cosmetic Product Notification
•
•
•
•
•
Products containing hair straightening
agents (INCI, % active agent)
Bath salt cubes with inorganic sodium
salts (Total salt % )
Toothpastes and mouthwashes with
Fluoride compounds (% as Fluorine)
Product with pH <3or >10
Etc…
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Cosmetic Product Notification
In addition to the rules above, a number of
substances have been identified by European
Poison Control Centers as posing a particular
concern with regard to an acute poisoning
emergency.
The concentration, above the indicated threshold,
of any of these ingredients in a formulation must
be specified. If no threshold is indicated, the
concentration must always be specified
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Cosmetic Product Notification
These ingredients are:
Glycols and Glycol
ethers:
BUTETH-2 ACETATE (above 1%)
BUTOXYDIGLYCOL (above 1%)
BUTOXYETHANOL (above 1%)
BUTOXYETHYL ACETATE (above 1%)
DIETHOXYDIGLYCOL (above 1%)
DIPROPYLENE GLYCOL (above 10%)
DIPROPYLENE GLYCOL DIMETHYL
ETHER (above 10%)
DIPROPYLENE GLYCOL ISOBORNYL
ETHER (above 10%)
ETHOXYDIGLYCOL (above 1%)
ETHOXYDIGLYCOL ACETATE (above 1%)
GLYCOL (above 1%)
GLYCOL ETHERS (not polymers) (above
1%)
METHOXYISOPROPANOL (above 10%)
METHOXYISOPROPYL ACETATE (above
10%)
PPG-2 METHYL ETHER (above 10%)
PPG-2 METHYL ETHER ACETATE (above
10%)
PROPYLENE GLYCOL (above 10%)
PROPYLENE GLYCOL BUTYL ETHER
(above 10%)
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Cosmetic Product Notification
•Hydrocarbons solvents
CYCLOHEXANE (above 5%)
HYDROGENATED DIDODECENE (above 5%)
ISOPENTANE (above 5%)
PENTANE (above 5%)
TOLUENE (above 5%)
TURPENTINE (above 5%)
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Cosmetic Product Notification
•Alcohols other than ethanol and isopropanol
BENZYL ALCOHOL (above 1%)
FURFURYL ALCOHOL (above 1%)
HEXYL ALCOHOL (above 5%)
N-BUTYL ALCOHOL (above 1%)
PROPYL ALCOHOL (above 1%)
T-BUTYL ALCOHOL (above 1%)
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Cosmetic Product Notification
Following Other ingredients:
ACETONE (above 5%)
BENZYL BENZOATE (above 1%)
BRUCINE SULFATE
BUTYL ACETATE (above 1%)
BUTYROLACTONE (above 0,1%)
BUTOXYETHYL ACETATE (above 1%)
CHLOROPLATINIC ACID (above 0,1%)
COPPER SULFATE (above 0,1%)
CYCLOHEXANONE (above 5%)
DIMETHYLTOLYLAMINE (above 0,1%)
…/…
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Cosmetic Product Notification
…/…
ETHYL ACETATE (above 1%)
ETHYL ETHER (above 5%)
FORMALDEHYDE (above 0,2%)
HYDROXYLAMINE HCL; HYDROXYLAMINE SULFATE(above 1%)
M-CRESOL, O-CRESOL, P-CRESOL, MIXED CRESOLS (above
0,1%)
MEK (above 5%)
METHYL ACETATE (above 0,1%)
METHYL PYRROLIDONE (above 5%)
MIBK (above 5%)
POTASSIUM CHLORATE (above 0,1%)
SODIUM CHLORATE (above 0,1%)
TRIETHYL PHOSPHATE (above 0,1%).
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Cosmetic Product Notification
If Exact concentration declaration is selected by
the responsible persons, a pfd file can be
uploaded. All ingredients are to be expressed in
INCI names, by decreasing order of %.
If Concentration range declaration is selected, a
pdf file can also be uploaded, no hand-written
document is allowed.
To facilitate the reading of Poison Centers, one
should start by mentioning the ingredients of
concern and their exact % .
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Cosmetic Product Notification
Another mandatory information that must be
declared is the original labeling and packaging
Original means here the labeling of the first
placing on the market in the EU. A photograph
of the original packaging can be upload as a
PDF format or JPG or JPEG.
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Cosmetic Product Notification
The labeling shall include any text, symbols,
pictures etc (e.g. art work). It shall cover notably
all the mandatory elements mentioned in Article
19 of Regulation (EC) N°1223/2009. In cases
where, in accordance with Article 19(2), some
mandatory information is mentioned on an
enclosed or attached leaflet, label, tag or card,
this leaflet, label, tag or card shall also be
included in the notification.
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Cosmetic Product Notification
A notification that relates to products composed
of several components (e.g. hair dye sets,
makeup sets) that are not marketed separately
will be different from that of a single component
product.
Sets do not need to be notified as multicomponent products provided that all
components that compose this set have been
notified individually.
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Cosmetic Product Notification
The component name is a crucial element of
the notification as it might be used by
competent authorities or by poison centers to
search for a specific component in the
database.
The component name must be detailed enough
to enable its specific identification.
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Cosmetic Product Notification
Notification by distributor:
A distributor who makes available in a Member
State a cosmetic product already marketed in
another Member State and translates, on his
own initiative, any element of the labeling of
that product in order to comply with national
law must notify some information in the CPNP.
To enter a distribution notification the
distributor has to select 'notify a product' in the
'Distributors‘ tab proposed on the Portal
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Cosmetic Product Notification
The CPNP will first ask the distributor to provide the
name of the responsible person of the product that
the distributor wants to distribute.
On the basis of the information entered by the
distributor, the CPNP will display a limited list of
result of matching responsible person names.
The distributor has to select one of the proposed
results. The system will then display (in read only
mode) the address associated to this responsible
person.
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Cosmetic Product Notification
The CPNP will then ask the distributor to enter
the product name in the Member State of
dispatch.
On the basis of the information entered by the
distributor, the CPNP will display a limited list of
result of product names matching.
The distributor has to select one of the
proposed results.
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Cosmetic Product Notification
The CPNP will display (in read only mode) the
category of the cosmetic product
associated to this product in the CPNP.
Then it will ask the distributor to select in the drop
down menu the Member State in which he makes
the product available.
The distributor has to enter the product name in
the Member States in which the distributor makes
the product available and to select the
corresponding language in the drop down menu.
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Cosmetic Product Notification
Search tools
CNPN proposes also a convenient search tool for
its users.
A responsible person can search only for the
notifications it (or users acting on its behalf) has
entered into the system. A responsible person that
has given access to several users to act on his
behalf can see all notifications entered by these
users. A responsible person can search for draft
and submitted notifications.
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Cosmetic Product Notification
Search tools
Competent authorities and poison centers can
search for all submitted notifications contained in
the system. Draft notifications are not accessible
to competent authorities and poison centers.
The 'Advanced search' is intended for the
responsible persons, the competent authorities
and the poison centers.
It allows these users to search a product into the
CPNP using cumulative search criteria.
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Cosmetic Product Notification
View product
The accessible information depends on the user profile:
The responsible person and the poison centers can see
all the information contained in the notification.
The competent authorities do not have access to
information related to the formulation name, frame
formulation number and qualitative and quantitative
composition information, except the information
concerning the presence of CMR substances of category
1A or 1B and of substances in the form of
nanomaterials.
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Cosmetic Product Notification
CNPN started its function since almost one
year (11 January 2012 by derogation of the
Directive 76/768). It will become mandatory
from July 11th next year.
It is too early yet to provide information on
whether the functioning of this complex tool
developed with the collaboration of the EU
administration, Industry and Poison Centers is
running smoothly or not.
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Cosmetic Product Notification
For multinational companies launching
hundreds of products every year in the 27
member states and its 23 official languages,
notification represents a complex challenge.
One issue of concern is the management of
Information System and its adaptation to a
massive notification. Naming of product in
each language, date of placing product on the
market will help for their identification
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Cosmetic Product Notification
Another challenge is the upload of the packaging
photos provided they remain documents
sufficiently legible. Heavy documents may slow
considerably processes.
How good will the categorization proposed in the
present system prove adapted to the variety of
products, and what will be the consequences of
their update on the already registered records?
Same question regarding update of Frame
formulation.
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Cosmetic Product Notification
Notification on-line is in deed a challenging
objective and the tool developed is essentially
aimed at fitting the provisions of the EC
Regulation 1223/2009.
Let’s hope that the proposed result of this
pragmatic approach will not reveal as a huge
labyrinthine system in the reality…
Thank you
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