International Cosmetics &
Regulatory Specialists, L.L.C.
 
   

Office: (310) 545-3223
Email: info@intlcosmetics.com
 
     
 

QUESTION OF THE MONTH


Answers:

Q: What happens under REACH if I am not a raw material supplier but import my products into Europe? Do I have any obligations?

A: Cosmetics companies outside of Europe that import products to Europe, are required to follow REACH.  This means that you must assure that all of the raw materials in products that are imported are registered under REACH as applicable.  If a raw material supplier doesn’t sell in Europe and has no interest in participating, it will be up to the Cosmetic companies to undertake those registrations to use that/those ingredient/ingredients legally in their product.  If registration is not done where applicable, a product containing the non-registered ingredient would be considered to be illegal.

Recent Questions of the Month:

Q: What chemicals are regulated under the California Senate Bill 484? Are they based on the Proposition 65 list?
A: The legislation shows multiple references for Chemicals that should be registered if they are contained in Cosmetic products. The Proposition 65 list is only one reference. While Industry continues to work with the State of California, at this time the multiple lists are the legal references.

Q: Since SB 484 (The "Safe Cosmetics Act of 2005") was signed by Gov. Schwarzenegger, what do I have to do now?
A: Companies who are selling product in California must notify the appropriate State agency  by January 1, 2007 when any product contains certain chemicals that are known or are potential carcinogens, reproductive toxins, or other "ingredients of concern", not yet specified.

Q: What happens if I didn't know that I needed to register a product?
A: The terms of the Bill have categorized any violations as Criminal (not Civil) and companies are subject to Criminal penalties and prosecution in a Criminal court.  There is no allowance or exemption for oversight.

Q: Will the information we file be treated as confidential?
A: No, California Public Records Act allows for this information to be publicly accessible.

Q: Are there any exceptions to the Bill's requirements?
A: The only exceptions are given for companies whose total sales (in the U.S. and worldwide) are under $1 million, based on the company's most recent tax filing.

Q: What should I do? 
A: Begin immediately to compile the necessary information in preparation for filing. 

 

Consulting for the FDA-regulated industries
     
"We're at home everywhere"™
 
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
     
 
 
KEYWORDS-KEYWORDS1
KEYWORDS-KEYWORDS2
KEYWORDS-KEYWORDS3
 
Site Designed and Hosted By: 8 Cubed Consulting Services
Send website comments/questions to webmaster@intlcosmetics.com
 
Copyright © 1995-2007, International Cosmetics and 8 Cubed Consulting Services. All Rights Reserved