One of the factors that differentiates cosmetic products like a strong marketing component, is the packaging. However, it is necessary to ensure that, as well as being attractive, they are safe to use on the cosmetic product and consequently to consumers.
By packaging is implied the container (or primary packaging) that is in direct contact with the formulation.
In accordance with the European Union (EU) Cosmetics Regulation (EC) No. 1223/2009, a cosmetic product made available on the market must be safe for human health when used under normal or reasonably foreseeable conditions of use.
The combination of packaging material, formulation of the cosmetic product and contact with the external environment may have an impact on the safety of the finished product, due to the following factors:
(a) interaction between the product and the packaging material;
(b) barrier properties of the packaging material;
(c) substance migration from/to the packaging material.
In Annex I, section 4 of the previously mentioned Regulation it is specified what must be included in the Cosmetic Product Safety Report (CPSR) regarding impurities, traces and information about the packaging material:
- The purity of the substances and mixtures;
- In the case of traces of prohibited substances, evidence for their technical unavoidability;
- The relevant characteristics of packaging material, in particular purity and stability.
Commission Implementing Decision 2013/674/EU establishes guidelines on the practical application of the above requirements.
The easiest way to ensure compatibility with the cosmetic product is to confirm that the packaging material is compatible with food, since the principle has been adopted that, in most cases, if the packaging is safe for a specific type of food, it must also be suitable for cosmetics that have similar physicochemical properties to this food. And materials that have been developed for food packaging have often already been tested, so relevant information on stability and migration may be available. Consequently, documentation provided by the packaging supplier is an important building block for the legally required safety assessment of the final cosmetic product by the responsible person’s safety assessor.
However, if the food compatibility of the packaging material cannot be proven, it is still possible to evaluate the packaging material by carrying out migration tests with the final packaging using specific simulants whose physicochemical properties are similar to those of the cosmetic product.
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