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The Modernization of Cosmetics Regulation Act (MoCRA) is here to stay. Not all requirements are fully defined yet, but you need to prepare to ensure your cosmetic products will be compliant under each new requirements once it become effective.
The best approach to avoid rushing from one deadline to another is to understand the requirements; AND to take 10 key steps to manage product information and to assess and monitor product compliance and safety.
We foresee the proposed ban to be approved, and consumer attention to microplastics to grow. There are still uncertainties and changes expected in the proposed ban. Nevertheless, it is important to start evaluating your formulations and ingredients against the microplastic definition short term.
The Brexit transition period will end by December 31st 2020. Time is running out, particularly for a UK > EU Responsible Person transfer. You have to act now to save costs, prevent supply chain disruptions and corrective actions
It is a strategic decision to market a product as a cosmetic or as a biocide. For cosmetic products compliance and market access can be achieved short term and at limited costs. However, these cannot have a primary biocidal claim and additional requirements apply. Once notified, cosmetic products can be marketed on the entire EU market, while ethanol-based biocides have to be authorised in each EU member state.
Food supplements claiming to be organic need to comply with Regulation (EU) 848/2018 on a number of aspects. To claim cosmetic products to be organic or natural it is best to follow to follow ISO 16128-2:2017.
The Brexit transition period is likely to end by December 31st 2020. There will be considerable impact. It is important to timely prepare and provide reassurance to importers and retailers in both the UK and the EU.
Based on the currently available data and our assessment, it can be concluded that CBD is safe for use in cosmetic products, respecting the advised maximum acceptable quantities in finished products.