62 ANTI-POLLUTION
jurisdiction, the majority of ingredients in this area will focus data on the kill itself and therefore fall under Biocidal regulations and the Biocidal Products Regulation (BPR) (unless they try to use some creative marketing to avoid falling under the regulations). Going back to the ingredient, Citriodiol,
mentioned earlier, it could be incorporated into cosmetics for a different purpose (for example fragrance / antioxidant etc.) with no need for external regulatory approval. However, if the product claims anything about antiviral effects, MHRA would need to be consulted, and if they want to make a formal claim about insect repellancy etc.,
would need BPR approval. Marketing departments are renowned for
nuisance insects and ticks. It is derived from the oil of the Eucalyptus citriodora tree (Corymbia citriodora).
The view from the beauty magazines Publications such as ‘Glamour’ have talked about “safety being the new luxury”,4 which has brought antimicrobial protection into a new and more positive spotlight. Highlighted in their focus on ‘post-Covid’ beauty were makeup brushes impregnated with an antimicrobial and nail polish from Dr Remedy with tea tree oil to offer antiviral and antifungal protection. Nail colour cosmetics are perhaps a logical focus area for these types of claims with hand hygiene very much the centre of attention. Over the next few months we are likely to see more and more treatments for hand and nail care as continued sanitiser use takes its toll. The use of antimicrobial ingredients in
these types of products illustrates a renewed awareness that products and utensils can harbour pathogens, and this is precisely why preservatives are included in formulations. As mentioned previously, it did seem that consumers, while almost certainly aware of this fact, did not want to accept it. But now, as Glamour suggest, antimicrobial safety is a priority and this may impact some aspects of the free-from movement, though will still require more effort to educate consumers on how preservatives work and why they are there. As with all products that fall into ‘Skin
Protection’ and ‘Anti-Pollution’, the consumer wants to be protected against an unclean/unsafe world, and the products are there to provide an invisible shield. While some types of pollution that are being claimed against have health impacts that are still being debated (blue light, etc), others (most notably UV) need to be able to be properly tested, measured and stand up to scrutiny. Certainly, antiviral claims must follow suit.
PERSONAL CARE EUROPE
What the regulations say The UK-based Cosmetic, Toiletry and Perfumery Association (CTPA) has offered guidance on making antiviral claims following consultation with the government body, The Medicines and Healthcare products Regulatory Agency.5 The CTPA say that: “Hand sanitisers which
make general, broad spectrum anti-viral claims are not necessarily regarded to be medicinal but they would otherwise be classed as biocides. However, assessment will be made on a case-by-case basis considering the overall context and presentation for the product and the understanding of the averagely well- informed consumer.” This means that claim of “antiviral” could
still be considered a medical claim if accompanied by pictures of a specific virus. The feeling is that the averagely well- informed consumer will likely link a claim of “antiviral” to meaning that a product is effective against COVID-19, so in the case of the MHRA, they will assess the broad presentation and how a typical consumer will interpret it to decide whether a claim is medicinal or not. The CTPA update added: “Specific claims
on viruses, like ‘kills/protects against -virus name” will be instead deemed as medicinal. It is MHRA’s position that any claim that a product can be used to treat or prevent a virus or an infection associated with specifically named pathogens, will be deemed as medicinal. The MHRA focus is particularly on specifically named pathogens such as MRSA, E. coli and now Covid-19.” The CTPA gave an example of a claim
that would definitely be considered medicinal: “Kills/effective against Covid- 19/SARS-CoV-2” as it is an implied medicinal claim against infections caused by a specific virus.
The European Biocidal Products Regulation (EU) 528/2012 As the CTPA comment that ‘anti-viral’ is a medical claim and therefore under MHRA
pushing the limits of what is allowable when it comes to claims of efficacy, but it would be very unwise to give any undue sense of efficacy against potential deadly viruses. Beyond hand sanitisers and other specific hand care products, the potential for antiviral efficacy of cosmetics in terms of protecting the consumer against possible infection is limited.
Skin issues related to the pandemic Another factor of the pandemic has been the additional stress on the skin as a result of increased mask-wearing. At the time of writing, they are worn so frequently by people, and for such prolonged periods they can be considered part of the ‘exposome’. To find out more, Personal Care spoke with Greentech’s Edith Filaire ahead of her presentation at in-cosmetics Virtual: “Pollution is included in the concept of “exposome”, which refers to the total sum of the multiple exposure factors humans face throughout their lives. This includes exposure to chemical substances, radiation, alimentation, stress and pollution. This concept was described in 2005 by Dr. Christopher P. Wild. Since the publication of this idea, there has been a growing interest in the investigation of the exposome. “The universal use of face masks as a
means of source control in public places during the COVID-19 pandemic is advocated by all health agencies. It is now well established by recent scientific publications that masks induce deleterious effects on the skin. This is another form of exposome. “To limit this, Greentech develops
several solutions for sensitive skin (Expozen), dyed skin (Biotilys) and oily skin (Acnilys). Theses actives were developed using a systemic approach, focusing on key biological target and microbiota.” In addition to protection from
pathogens and wearing of masks, consumers will also want their skin protected from the harsh new cleansing regimes resulting from
November 2020
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