TESTING PACKAGING VS FORMULA
Cosmet’in Lyon (formerly CED), which was then joined by major international cosmetics brands and industrial partners. It aims to provide the entire cosmetics industry with protocols that are specific to cosmetics, as well as simple, economical and accessible to all. The non-profit project is funded by its 14 partners – Berry Bramlage, Eastman, Equitox, Laboratoires Expanscience, LVMH Recherche- Parfums & Cosmétiques, MS BEAUTiLAB, PRP Création, Texen, Groupe Treffert, Itech, Université Lyon 1, Allizé-Plasturgie, Cosmet’in Lyon and Plastipolis – and the group is open to the entry of new members. Dominique Bouvier, previously President of Strand Cosmetics Europe, explains the genesis of the project: “As a manufacturer and subcontractor for the cosmetics industry, we were simultaneously faced with demand from brands for a turnkey product offer and, on the other hand, with the health safety regulatory requirements of cosmetic products in their entirety, encompassing both packaging and the formula.
“However, while we could provide exhaustive information on the cosmetic formula that we produced, this was not the case for packaging, supplied by external suppliers. It therefore seemed essential to us to provide transparency on this point. And if Cosmetics Europe gave a guideline and recommendations, we wanted to go further by offering a common and concrete methodology and benchmarks for assessing migration hazards that could be used by as many stakeholders as possible. This is how CosmetoPack was initiated and then joined by players involved in the value chain.”
WHAT ARE COSMETOPACK’S GOALS? The primary aims of CosmetoPack are to: 1. Manage toxicological risks relative to packaging/formula interactions; 2. Establish tolerance thresholds to guarantee product health and safety; 3. Develop safety assessment methods in order to benefit from new knowledge about products; 4. Anticipate potential new regulation, in particular: •The goal of sustainable
consumption and production through the Sustainable Development Goals (SDGs), encouraging states to develop strategies like the French National Roadmap for the Circular Economy (FREC) for the reduction, reuse and recycling of plastic packaging; •The European directive intending to increase the share of reused packaging on the market instead of single-use packaging; and
5. Match international societal demand. 54 December 2020
The key point is to create a toxicological hazards management protocol specific to cosmetics
The key point is to create a toxicological hazards management protocol specific to cosmetics, intended to assess and model packaging/formula interactions, in a similar vein to 1935/2004/CE and 10/2011/CE, named CPML (Cosmetic Packaging Migration Limit) vs SML (Specific Migration Limit).
ANTICIPATED REGULATORY CHANGE The priorities of health, safety and sustainability will drive regulatory change as things progress. CosmetoPack’s goal is to anticipate potential new regulation that will especially impact packaging/formula interaction and provide industrial partners with a common guideline and an operational tool to optimise all areas of the value chain. CosmetoPack’s protocol is not just a scientific project, but a CSR project that involves science.
“There is no qualification of packaging for cosmetic use,” specifies Bouvier. “And that of the food [industry] is not suitable, relative to the conditions of use and storage and the ingredients that enter the composition of the formula on the one hand, and that of the container on the other hand. Decoration and aesthetics play a key role and result in mass tinted and/or decorated packaging. Finally, the plastic regulations that revolve around the ‘5Rs’ are leading to the emergence of new materials, the risks of which will have to be assessed. This is what led us to develop this specific protocol that CosmetoPack named CPML (Cosmetic Packaging Migration Limit) vs the SML (Specific Migration Limit) protocol for food.”
“Joining this working group means contributing to the process of harmonising the assessment of the packaging/formula interaction hazard,” says Laurent Nogueira, LVMH Research – Perfumes & Cosmetics. “Joining together has also the advantage of pooling costs.
“This subject will become unavoidable from a regulatory point of view. Today, it is simply mentioned in the European regulation. Tomorrow, the authorities will demand much more than a simple declaration of no hazardous molecules in the primary packaging.
“It is therefore necessary to develop a scientific approach based on tests, as we do for food. Mastering the
packaging/formula interactions means anticipating the future regulatory
cosmeticsbusiness.com
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