Little Pro on 2017-04-27
GHS is an internationally agreed system to classify and label chemical substances and mixtures. Many people have questioned whether GHS also applies to cosmetics since most of cosmetic products are mixtures. In this article, we will summarize the latest situation of GHS adoption for cosmetics sector and some main issues to consider.
The UN GHS purple book states that pharmaceuticals, food additives, cosmetics, and pesticide residues in food will not be covered by the GHS in terms of labelling at the point of intentional intake. However, these types of chemicals would be covered where workers may be exposed, and, in transport if potential exposure warrants.
Considering that most of countries have adopted GHS for workplace chemicals, it is generally expected that cosmetic ingredients and cosmetics in bulk form will require GHS labelling and safety data sheets due to likely worker exposure while finished cosmetic products do not require GHS labelling. However, there might be some exceptions in some countries.
In EU, GHS is implemented via CLP Regulation (EC) No 1272/2008. Dr Martin Perry has analyzed the impact of the CLP regulation on cosmetics in EU in this article. The conclusion is that finished cosmetics do not require GHS labelling. However, personal aerosol products cannot be excluded.
Regulation (EC) No 1272/2008 states that it applies to all substances and mixtures placed on the EU market except where other community legislation “lays down more specific rules on classification and labelling”. The labelling of cosmetics is regulated by Regulation (EC) No 1223/2009 and therefore Regulation (EC) No 1272/2008 does not apply to the labelling of most cosmetic products.
Some agencies including Germany's federal environment agency(UBA) and Sweden's chemicals agency Kemihave questioned above CLP labelling exemption for cosmetics since cosmetics might also contain environmentally hazardous substances that may end up in the environment or in wastewater.
In the US, OSHA's hazard communication standard 2012 clearly states that GHS/HCS labelling does not apply to:
(viii) Cosmetics which are packaged for sale to consumers in a retail establishment, and cosmetics intended for personal consumption by employees while in the workplace;
Please note that manufacturers of cosmetics in bulk form or premixes still need to label their containers according to GHS since they are not packaged for sale to consumers.
Most of other countries such as Japan, China, Canada, Australia and Korea do not require GHS classification and labeling for cosmetics at retail stage since they are subject to separate labelling requirements.
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