CTPA welcomes the Science and Technology Committee’s Report which focusses on our safety when using cosmetic products, aesthetic products or undergoing aesthetic treatments. We are though disappointed that the accompanying press release did not reflect this clear conclusion from the Report and has resulted in alarming headlines. The safety of those who use our products is the cosmetics and personal care industry’s number one priority.
Following the Report, we believe it is vital that consumers are not left with the impression that everyday cosmetics and personal care products are largely unregulated. They are, in fact, highly regulated, and the UK Cosmetics Regulation is, along with the EU regulation it is based on, seen as the gold standard. CTPA is pleased that the Report recognises the strict safety standards of the UK Cosmetics Regulation.
Cosmetics and personal care products, such as shampoos, moisturisers, make-up, hair colorants, nail products and hair relaxers, placed on the UK market are already subject to a comprehensive and strict safety framework under the UK Cosmetics Regulation (UKCR). The Committee considered a much wider range of beauty and aesthetic treatments which are not cosmetic products within the scope of that Regulation and have distinct legal frameworks governing their safety. Aesthetic treatments and injectable products are not classed as cosmetic products and are therefore outside of CTPA’s remit.
Dr Emma Meredith OBE, CTPA Director-General, says “CTPA agrees with the Science and Technology Committee on the fundamental point that science and consumer safety must remain at the heart of regulation. I am also pleased that the Report recognises that the UK Cosmetics Regulation, which ensures the safety of cosmetics and personal care products, is ‘gold standard’ and robust.
“It is important to distinguish between cosmetic products and the wider range of beauty and aesthetic treatments considered in the Report, which have different safety legislation. The UK Cosmetics Regulation already sets out an extremely strict safety framework, specifically designed to ensure that cosmetics and personal care products are safe before they reach consumers and salon professionals.”
How the UK Cosmetics Regulation protects consumers
Safety is the cornerstone of cosmetics legislation.
The UK Cosmetics Regulation (UKCR) covers cosmetic products (as defined within the law) used in both the consumer and professional setting, such as hair, beauty and nail salons, barbers and spas.
Before a cosmetic product can be placed on the UK market, whether via a high street retail outlet or online, it must undergo a detailed safety assessment carried out by a qualified, professional safety assessor. The assessment considers every ingredient in the formulation, how consumers will be exposed to those ingredients during normal use and how often and where on the body the product will be used. For products used in salons, the safety of both clients and professionals is paramount, with robust product safety requirements and appropriate workplace measures working together to support safe use.
The cosmetic product is only allowed to be sold if the safety assessor signs the assessment confirming that the product and its ingredients do not present a risk. This assessment considers potential effects relevant to both short and long-term use. The safety assessment assumes someone would use large amounts of the product frequently, and it incorporates substantial safety margins which take into account individual diversity between people who might use the product, such as age, ethnicity, skin type or sensitivity. Therefore, the safety assessment is based on a ‘worst-case’ scenario to ensure there are no risks.
As well as the safety assessment, cosmetics and personal care products must comply with many ingredient bans and restrictions, instructions for manufacturing and labelling, and companies must hold a Product Information File containing the information required to demonstrate compliance and safety. Enforcement authorities, including Trading Standards and the Office for Product Safety and Standards (OPSS), are able to investigate products and access the complete Product Information File if concerns arise.
The Science and Technology Committee Report notes the importance of ingredient transparency to help consumers make informed decisions. A very important aspect of the UKCR is the requirement to display a full list of cosmetic ingredients on product packaging using the internationally recognised INCI (International Nomenclature of Cosmetic Ingredients) naming system, helping consumers, including people with diagnosed allergies, to identify ingredients they may need to avoid. The law also says product claims must be supported by evidence and must not mislead consumers.
Why different products need their own specific safety frameworks
The UKCR has been developed and refined over more than five decades to provide bespoke safety standards for cosmetics and personal care products which are applied to external parts of the human body. These products are clearly defined within the law, and beauty treatments which are injected, eaten or breathed in will interact very differently with the body and so they need to be addressed by a different, purpose-built framework. For example, one which contains a safety assessment procedure specific to this route of exposure, different sterility considerations for manufacturing controls, detailed considerations for the professional applying the treatment, and more.
Ensuring companies monitor unwanted consumer reactions to products
The Report recommends streamlining the ‘cosmetovigilance’ system, which is a system enshrined within the UKCR for companies to record, monitor and assess any unwanted reactions reported by consumers after using the product. In some cases, reactions need to be reported by companies to the UK authorities.
Companies take their cosmetovigilance obligations very seriously and they work with CTPA to provide information to consumers explaining what to do if they have experienced a reaction, and why it is really important that companies hear about these reactions. CTPA provides regular training to companies to help them ensure they are fulfilling their obligations effectively. CTPA is looking forward to working with the Government and businesses to help ensure consumers can report reactions even more simply and quickly, and that the information generated by the cosmetovigilance system continues to provide valuable safety information.
Cosmetics law is constantly evolving to keep up with science
The Report discusses a number of cosmetic products, including acrylic nails, skin lighteners and hair relaxers, and it focusses on ensuring that cosmetics laws are the most up-to-date they can be for these, and all, cosmetic products. The Report calls for further research into chemical hair relaxers and related products by the UK Government’s independent scientific committee, the Scientific Advisory Group on Chemical Safety in Consumer Products (SAG-CS), and the commissioning of new UK research focussing on real-world exposure and reflecting the population groups most frequently using such products. CTPA supports the fact that the UKCR is not static and that new scientific evidence is considered by the UK Government and its independent scientific experts constantly.
For example, the UKCR contains extensive lists of banned and restricted ingredients and the UK cosmetics industry is very supportive of the independent, rigorous and scientific process undertaken by the UK Government and its independent scientific committee to regularly review and confirm the safety of cosmetic ingredients and implement new controls if required.
CTPA supports Government and regulators working together on new studies and sharing cutting-edge scientific research from the cosmetics industry to continue to support the scientific evidence base.
CTPA supports effective enforcement to support the strong UK Cosmetics Regulation
The importance of supporting effective enforcement to protect consumers from illegal products was a key outcome of the Report. CTPA has a longstanding relationship with Trading Standards and provides training and technical support to help officers identify non-compliant products and assess whether businesses are meeting their legal obligations. This includes training on cosmetic product safety assessments, Good Manufacturing Practice, key warning signs for potentially non-compliant products and involvement in consumer campaigns such as the “#Cost of Beauty” campaign raising awareness of the dangers of using specific illegal and unsafe cosmetic products. In turn, intelligence from Trading Standards about recurring problems in the marketplace helps CTPA and the wider industry identify and address areas of concern.
CTPA strongly agrees that enforcement authorities must have appropriate resources to remove illegal and unsafe products from the marketplace. CTPA also support measures that ensure online routes to market do not undermine the high level of consumer protection rightly expected of cosmetic products sold in the UK.
Hair relaxers: supporting further research and independent scientific scrutiny
CTPA recognises the Committee's concerns about gaps in the evidence base for products predominantly used by Black women and girls and supports the recommendation for further high-quality research to ensure that regulatory decisions continue to reflect the best available evidence.
Hair relaxers are cosmetic products and are therefore subject to the same strict safety requirements as other cosmetics. Their ingredients and finished formulations must be assessed for safety before products are placed on the UK market. Cosmetic safety assessment investigates all potential harms from a substance, including skin and eye irritation, allergy-causing potential, cancer-causing potential, endocrine disruption and much more. The scientific studies which investigate any negative effects on our bodies from cosmetic ingredients model chronic, or repeat, exposure. This means we can be sure that the ingredients are not going to cause us harm when used long-term.
CTPA also fully supports the UK Government asking the Scientific Advisory Group on Chemical Safety in Consumer Products (SAG-CS) to review new or emerging scientific evidence relating to cosmetic ingredients. The UKCR is considered a gold standard for the safety of cosmetics and personal care products. A very important aspect of the Regulation is the provision for the UK authorities to consult its committee, the SAG-CS, for an independent opinion on the safety of a cosmetic ingredient.
