EnviroLink Forum

http://ec.europa.eu/consumers/cosmetics/cosing/index.cfm?fuseaction=ref_data.annexes

Ok this lists restricted substances, provisionally allowed substances, allowed preservatives, UV filters, and coloring agents. That leaves some 260,000 + known chemical compounds which could be used, but may require testing .... right?

List of substances which cosmetic products must not contain except subject to the restrictions and conditions laid down

List of substances provisionally allowed

List of colouring agents allowed for use in cosmetic products (1)

List of colouring agents provisionally allowed for use in cosmetic products

List of preservatives allowed

List of preservatives provisionally allowed

List of permitted UV filters which cosmetic products may contain

List of UV filters which cosmetic products may provisionally contain

Sure ... but why should it be necessary if you know it all and I do not?

http://ec.europa.eu/health/ph_risk/comm ... _o_03j.pdf

As already mentioned, for repeated-dose toxicity testing, currently no validated or
generally accepted alternative method is available for replacing animal testing. There
have been some serious efforts in the domains of e.g. neurotoxicity and nephrotoxicity,
but to date, no method or screening battery has been formally (pre-)validated
[SCCNFP/0546/02].

In the notification process of dangerous substances, repeated dose toxicity studies are
required when the substance under consideration is produced or imported in amounts
exceeding 1 tonne/year [92/32/EEC].

In the case of the development of cosmetic ingredients which have specific biological
properties and which will come into contact with human skin for a long period of time,
the SCCP is convinced that evaluation of the systemic risk is a key element in
evaluating the safety of these new ingredients, irrespective of the tonnage-linked and
possibly limited requirements imposed by the Dangerous Substances Directive
[67/548/EEC].

Therefore the SCCP considers that in certain cases the use of animal long-term
experiments to study one or more potential toxic effects remains a scientific necessity.
It is self-evident that animal use should be limited to a minimum, but never at the
expense of consumer safety. The "7th Amendment" [2003/15/EC] to the Cosmetic
Directive 76/768/EEC allows up to 11 March 2013 for the development of validated
alternative tests for repeated exposure.

Sure ... but why should it be necessary if you know it all and I do not?

http://ec.europa.eu/health/ph_risk/comm ... _o_03j.pdf

As already mentioned, for repeated-dose toxicity testing, currently no validated or
generally accepted alternative method is available for replacing animal testing. There
have been some serious efforts in the domains of e.g. neurotoxicity and nephrotoxicity,
but to date, no method or screening battery has been formally (pre-)validated
[SCCNFP/0546/02].

In the notification process of dangerous substances, repeated dose toxicity studies are
required when the substance under consideration is produced or imported in amounts
exceeding 1 tonne/year [92/32/EEC].

In the case of the development of cosmetic ingredients which have specific biological
properties and which will come into contact with human skin for a long period of time,
the SCCP is convinced that evaluation of the systemic risk is a key element in
evaluating the safety of these new ingredients, irrespective of the tonnage-linked and
possibly limited requirements imposed by the Dangerous Substances Directive
[67/548/EEC].

Therefore the SCCP considers that in certain cases the use of animal long-term
experiments to study one or more potential toxic effects remains a scientific necessity.
It is self-evident that animal use should be limited to a minimum, but never at the
expense of consumer safety. The "7th Amendment" [2003/15/EC] to the Cosmetic
Directive 76/768/EEC allows up to 11 March 2013 for the development of validated
alternative tests for repeated exposure.

Moved on since the sixth amendment

Like i have said, you are a fool.

Ok this lists restricted substances, provisionally allowed substances, allowed preservatives, UV filters, and coloring agents. That leaves some 260,000 + known chemical compounds which could be used, but may require testing .... right?

List of substances which cosmetic products must not contain except subject to the restrictions and conditions laid down

List of substances provisionally allowed

List of colouring agents allowed for use in cosmetic products (1)

List of colouring agents provisionally allowed for use in cosmetic products

List of preservatives allowed

List of preservatives provisionally allowed

List of permitted UV filters which cosmetic products may contain

List of UV filters which cosmetic products may provisionally contain

You are a fool.

Because I understand what you do not? There are some 265,000 compounds in the database for GC/MS analysis comparison. Out of those you have a list of compounds which are not allowed in cosmetics under any circumstances, a list of compounds allowed with specific restrictions, and a list of provisionally allowed compounds. This does not cover all of the compounds which may be used since there are supposedly many compounds which should have no restrictions on use in cosmetics according to your references.

Because I understand what you do not? There are some 265,000 compounds in the database for GC/MS analysis comparison. Out of those you have a list of compounds which are not allowed in cosmetics under any circumstances, a list of compounds allowed with specific restrictions, and a list of provisionally allowed compounds. This does not cover all of the compounds which may be used since there are supposedly many compounds which should have no restrictions on use in cosmetics according to your references.

No because you don't understand the transition from one law to the other and quote directives that are out of date. Mixing it up because you think I'm an idiot.

Come back when you have an idea.

http://www.efma.org/PRODUCT-STEWARDSHIP-PROGRAM-10/images/1992-32EC.pdf

Article 8 section 4 gives the 1 tonne limit which triggers the requirements of Article 7 and which are specified in Annex VII.

I find no caveat related to or replacement of these requirements.

The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.

1992, moved on since.

Would help if you knew what you were talking about.

Where? According to the information I have found that was the seventh and last amendment to the 1967 base regulation. There seem to have been some annex additions, but I have found nothing that superceded the requirements of the articles referenced. Now if you can provide some link to such a change as has been asked prior, we can see what the current regulation is.

Sure ... but why should it be necessary if you know it all and I do not?

http://ec.europa.eu/health/ph_risk/comm ... _o_03j.pdf

As already mentioned, for repeated-dose toxicity testing, currently no validated or
generally accepted alternative method is available for replacing animal testing. There
have been some serious efforts in the domains of e.g. neurotoxicity and nephrotoxicity,
but to date, no method or screening battery has been formally (pre-)validated
[SCCNFP/0546/02].

In the notification process of dangerous substances, repeated dose toxicity studies are
required when the substance under consideration is produced or imported in amounts
exceeding 1 tonne/year [92/32/EEC].

In the case of the development of cosmetic ingredients which have specific biological
properties and which will come into contact with human skin for a long period of time,
the SCCP is convinced that evaluation of the systemic risk is a key element in
evaluating the safety of these new ingredients, irrespective of the tonnage-linked and
possibly limited requirements imposed by the Dangerous Substances Directive
[67/548/EEC].

Therefore the SCCP considers that in certain cases the use of animal long-term
experiments to study one or more potential toxic effects remains a scientific necessity.
It is self-evident that animal use should be limited to a minimum, but never at the
expense of consumer safety. The "7th Amendment" [2003/15/EC] to the Cosmetic
Directive 76/768/EEC allows up to 11 March 2013 for the development of validated
alternative tests for repeated exposure.

The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.

Production volumes of 1 to 10 tonne requires toxicology test for carcinogenic, mutagenic or reproductive effect, the test required a mutagenicity test in bacteria....

Any thing else you require?

Would help if you knew what you were talking about

Where is the change to OR instead of and for this requirement? Annex VII clearly states all are required in the report.

4.1 Acute toxicity - two routes of exposure
4.3.1 Mutagencity - two tests one of which is bacteriolical for reverse mutation
4.3.2 screening for toxicity related to reproduction
5.1.1 Acute toxicity for fish
5.1.2 Acute toxicity for daphnia