Traceability of cosmetics for the safety of companies and consumers

Rintracciabilità cosmetici

Cosmetic products include a wide range of items (creams, shampoos, body care and hygiene products, but also make-up and sun care products), therefore, their use is extremely widespread and involves different types of consumers.

However, not all stakeholders are aware of the legal obligations and rules that have to be respected in order to market a cosmetic in a manner that complies with industry regulations.
The current reference text is Regulation (EC) No 1223/2009 of November 30th 2009, which is applicable from July 11th 2013; in addition, there are also other official documents and guidelines that help the different actors (manufacturers, cosmetic companies, distributors, etc.) in the sector to follow the legislation properly.

For each cosmetic product, a responsible person must be identified who ensures compliance with the relevant obligations under the Regulation. Of course, the first requirement is that the cosmetic must be safe under normal or reasonably foreseeable conditions of use.

This means that, starting with the production process, cosmetic products placed on the market must be manufactured in accordance with good manufacturing practices in order to ensure their safety. In the composition of a cosmetic product, not all ingredients are allowed since there are restrictions to be respected: both in terms of the ingredient used, the concentration of a given ingredient, but also specific warnings to be reported on the label.

Before placing a cosmetic product on the market, the responsible person should carry out a safety assessment of the cosmetic product (or may either entrust this task to an expert in the field). In order to carry out this analysis, a dossier, the PIF (Product Information File), is prepared which includes all the information about the product and proves its safety.
Nevertheless, even if cosmetics placed on the market have been assessed as safe by the safety assessor and even if they are used correctly by the consumer, it is still possible that undesirable effects may occur after using the cosmetic product.

In many cases these are minor effects, perhaps related to particular consumer sensitivities, but sometimes they can be more serious. This is why it is essential that the responsible person has an effective cosmetovigilance system in place to properly handle reports and, if necessary, take action promptly.

Traceability of cosmetic products

In this respect, it is crucial to ensure the traceability of a cosmetic product throughout the supply chain to help simplify market surveillance and improve market efficiency. An effective traceability system also facilitates the task of market surveillance authorities to trace economic operators (in case the authorities become aware of problems related to a particular cosmetic).
One of the obligations of the responsible person is in fact the traceability of the entire production and distribution chain of each single product.

This obligation can also be fulfilled by providing the batch number. The batch number is one of the mandatory information that must be shown on the label of each individual cosmetic and allows the product to be identified.

Furthermore, in order to ensure product traceability, the responsible person must be able to identify the distributors to whom he supplies the cosmetic product for a period of three years after the date on which the batch of the cosmetic product was made available to the distributor. The same applies to all other operators in the supply chain.

The traceability of a cosmetic product throughout the supply chain contributes to simplifying market surveillance and improving its efficiency. An efficient traceability system facilitates market surveillance authorities’ controls and the task of tracing economic operators while also ensuring increased transparency for citizens.

Written by: Federica Montozzi