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EU cosmetics regulation: what the safety report says about packaging

The European cosmetics regulation is usually thought of as a text about ingredients. It is, but not only: the report that proves a cream is safe must also deal with the jar that holds it. For a packaging manufacturer, that is where its share of the dossier begins.

By Tecmom editorial team · 2 min read

Open translucent white cosmetic jar, its lid lying beside it, with a white tube and a small bottle
Illustration — A cosmetic's safety report also covers its packaging.

A safety report for every product

Regulation (EC) No 1223/2009 governs cosmetic products sold in the European Union. Before it is placed on the market, every product undergoes a safety assessment, recorded in a cosmetic product safety report whose content is set by Annex I.

Part A gathers the data: composition, physico-chemical characteristics, stability, microbiological quality, toxicology. Part B is the assessment itself, signed by a qualified assessor.

Packaging, a heading in its own right

Part A's data include a heading entitled "impurities, traces, information about the packaging material". It calls for the relevant characteristics of the packaging material, in particular its purity and stability. The Commission's guidelines, published in 2013, detail what the assessor should examine.

The reason is the same as for a medicine or a food: packaging touches the product. It may release substances into it, absorb some, or let oxygen and light through. See essential oils and plastic and permeability.

PAO, the period after opening

Article 19 requires an indication of how long the product remains safe. For a cosmetic whose minimum durability exceeds 30 months, this date is not mandatory: the period after opening (PAO) is given instead, as the small open jar followed by a number of months, defined in Annex VII.

This period depends partly on the packaging. A pump bottle or a tube protects the formula better than a jar opened at every use, where air and fingers get in each time.

What the packaging manufacturer provides

The assessor can judge packaging only with data: material, additives and colourants, suitability for contact, results of compatibility tests with the formula. The packaging manufacturer supplies them, and reports any change. For packaging sold in Europe, REACH obligations apply too.

In cosmetics, appearance matters, but it does not replace compatibility; see variants of a single shape.

A safe cosmetic is a safe formula in a pack that keeps it as it is. The regulation has written it down in black and white.

Glossary

Safety report
The file demonstrating a cosmetic's safety, defined in Annex I of Regulation 1223/2009.
Safety assessor
The qualified person who signs the Part B assessment of the report.
PAO
Period after opening: how long a cosmetic can be used safely once opened.
Compatibility
The absence of harmful interaction between the formula and its packaging.

Further reading