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2022
*CONFIDENTIAL* Newsletter No. 2 August 2022


sectoral legislation | taxation
Public consultation on the draft law amending the Law on Value Added Tax and certain other laws (Slim VAT 3)
 
On the website of the Public Information Bulletin of the Government Legislation Centre, the draft law amending the Law on Goods and Services Tax and certain other laws, the Slim VAT 3 package (No. UD411 in the list of legislative and programme work of the Council of Ministers) has been posted.
The Lewiatan Confederation is analysing the draft and plans to make comments during the consultation. We provide you with the main changes that the draft envisages. In cooperation with the Lewiatan Confederation, we have the opportunity to provide our comments. Please take note and send them by 22nd August to: mturowska@kosmetyczni.pl. »

 

China | Microbiology
Testing of microbiological limits according to Chinese regulations

According to Chinese cosmetics legislation, microbiological limit testing methods that differ from the Chinese Safety and Technical Standard for Cosmetics (STSC) methods are required to demonstrate equivalence to STSC methods in order to be accepted. Demonstrating such equivalence is not easy, which is why Cosmetics Europe, as part of the work of the ET China working group, engaged experts to develop a document with the relevant arguments. The attached document [annex 7] illustrates why international methods can meet STSC requirements. The document can be used according to your needs, e.g. in the product registration process.

Indonesia | Certificates
Certificates accepted in Indonesia

Cosmetics Europe has informed us that Indonesia now accepts apostilled FSC and GMP certificates from countries that are members of the Convention, abolishing the requirement for legalisation of foreign public documents (instead of legalisation).
Apostille (from French, pronounced [apostil]) - an attestation of a document drawn up in one country (e.g. a notarial deed, a sworn translation or a copy of a civil status certificate) enabling it to be used legally in another country). This certification is issued by the competent authority of the country from which the document originates. What exactly does it consist of? »

Trade fairs | Middle East
Promotion of the Polish cosmetics sector at Beautyworld Middle East 2022

We would like to remind you that from 31st October to 2nd November this year, the Polish cosmetics sector faces another opportunity to promote itself in the Middle East before and during the BEAUTYWORLD MIDDLE EAST 2022 fair.
In addition to Blanka Chmurzyńska-Brown, General Directorof the Polish Union of the Cosmetics Industry, the event's experts will include a representative of the Embassy of the Republic of Poland, a representative of the Polish Investment and Trade Agency, representatives of the Ministry of Economic Development, Labour and Technology and Maciej Białko - Market Expert for the United Arab Emirates, Gulf Business Link LLC.
BERM is planning to create a Polish pavilion where only companies from our country will be exhibiting and a number of other promotional activities will be coordinated for participants. What will it look like? What logistical and technical support can participants count on? What does the programme of the economic mission include this time and what is its sample programme? What packages does BERM offer? You will find this information in the attached documents, prepared by the organiser.

Promotion of companies from the Łódź region

The Regional Centre for Economic Activity and the Bełchatów-Kleszczów Industrial and Technological Park invite entrepreneurs from the region of Łódź to participate in the project of export promotion. The project offers the possibility to obtain support for foreign trips in order to gain new sales markets. Within the framework of economic missions, selected entrepreneurs take part in trade fairs and business meetings. Already after the holidays we are planning, among others, a trip for the cosmetics and beauty industry to the cosmetics fair in Dubai - Beautyworld Middle East (31.10-2.11). Here are the details!

Invitation to the BEAUTYISTANBUL Exhibition

The 3rd edition of the 'International Exhibition for Cosmetics Beauty, Hair, Home Care, Private Label Packaging and Ingrediens’ event will be held from 13th to 15th October at the ICC-Istanbul Congress Center, Taksim, Istanbul.
The organisers encourage participation and point out that this is the most international exhibition in the world, hosting 600 exhibitors from 50 countries, traders from as many as 160 countries and more than 12,000 participants.
Take a look at the event's programme on the website, which also describes detailed meeting options and the advantages of participating in the fair.

 

nanomaterials | definition | consultation
ATTENTION: CosEur consultation on nanomaterials - until 31st August this year

Cosmetics Europe has launched the first phase of the Cosmetic nano scoping exercise and impact assessment project on assessing the impact of changing the definition of nanomaterial. The project aims to identify (in advance) cosmetic ingredients affected by the new horizontal definition of nanomaterial. This is important so that cosmetic manufacturers can already pre-identify and know the list of 'new' nanomaterials at this stage, in order to increase the industry's internal preparedness for the changes under way.
The survey (project) is aimed at raw material suppliers (annexes 1,2). The aim of the survey is to develop a list of cosmetic ingredients (with associated trade names) covered by the horizontal definition of nanomaterial in the 2011 Commission Recommendation.
We are asking for your help to disseminate the survey to your suppliers through your B2B contacts. How can this support us? »

Fragrance ingredients | Methyl 2-Octinoate
Proposal for classification as Skin Sens. 1A for methylheptine carbonate

On 5th July this year, it submitted a proposal to ECHA for the harmonised classification of Methyl 2-Octynoate (CAS: 111-12-6) as a substance that may cause an allergic skin reaction (Skin Sens. 1A, H317). The application will be subject to a compliance check at ECHA. Methyl 2-Octynoate is regulated by Annex III, item 89 of Regulation 1223/2009/EC. The ingredient is present in fragrance compositions. Its presence in a cosmetic product must be included in the ingredient list on the cosmetic label when the concentration exceeds 0.001 % in the no-rinse product and 0.01 % in the rinse-off product. You can follow the progress of the process on the ECHA website: link

CMR substances | UV filters | titanium dioxide
SCCS will evaluate the safety of titanium dioxide

As a reminder, on 21st June this year, the Commission sent a mandate to the Scientific Committee on Consumer Safety (SCCS) requesting a safety assessment of Titanium dioxide (CAS: 13463-67-7/1317-70-0/1317-80-2). The mandate to the SCCS focuses on the genotoxicity aspect and will take into account oral and inhalation routes of exposure (lip care products, lipsticks, toothpastes, loose powders, hairsprays).
The Commission, in light of the recent scientific opinion on E171 (TiO2) by EFSA (in May 2021), decided to mandate the SCCS Committee to evaluate the ingredient.

The SCCS Committee was asked to address the following questions:

  1. In light of the EFSA Opinion on genotoxicity concerns for E171, does the SCCS consider Titanium dioxide safe in oral cosmetic products?
  2. In light of the EFSA Opinion, does the SCCS consider that previous Opinions issued by the SCCS on inhalation and dermal exposure to Titanium dioxide need to be revised?
  3. In the event that the estimated exposure to Titanium dioxide from cosmetic products is found to be of concern, SCCS is asked to recommend safe concentration limits for each category of products and types of use.
  4. In light of the potential removal of the E 171 purity specification from the food additives Regulation. The SCCS is requested to review and indicate the respective specifications for Titanium dioxide when used in cosmetics.
  5. Does the SCCS have any further scientific concerns regarding the use of Titanium dioxide in cosmetic products?

The SCCS has 9 months to prepare an opinion. Link to mandate: link

UV filters | resorcinol | BHT
Draft regulation for 5 cosmetic ingredients

We would like to remind you of the upcoming publication of the draft regulation which concerns five cosmetic ingredients: BHT, Acid Yellow 3, Homosalate, Bis-(Diethylaminohydroxybenzoyl Benzoyl) Piperazine, HAA299) and Resorcinol (change in label warning content). The expected date of publication of the regulation is Q3/Q4 2022. The Union consulted this translation among member companies, no company commented. The draft translation can be found in the attachment.

The draft regulation provides for the following changes:

BHT (CAS: 128-37-0) is currently not regulated by the Annexes of Regulation 1223/2009. The Commission proposes to introduce restrictions on its use in mouthwash (0.001%), toothpaste (0.1%) and other cosmetic products (0.8%), in line with the opinion of the SCCS Committee (SCCS/1636/21). The transitional deadlines foreseen for BHT are:

  • 6 months for placing products on the market
  • 12 months for making non-compliant products available on the market after the entry into force of the Regulation.

Acid Yellow 3 (CAS: 8004-92-0) is currently regulated under Annex IV, item 82 of Regulation 1223/2009. The draft provides for restrictions on the use of the dye in non-oxidative hair dye products up to a maximum concentration of 0.5 % via Annex III, in accordance with the opinion of the SCCS (SCCS/1631/21). The envisaged transitional periods for Acid Yellow are:

  • 6 months for placing products on the market
  • 12 months for making non-compliant products available on the market after the entry into force of the Regulation.

HAA299 (CAS: 919803-06-8) is not included in the Annexes to Cosmetics Regulation 1223/2009/EC. The regulation under procedure aims to add HAA299 as a new UV filter to Annex VI - in both nano and non-nano forms. The proposed maximum concentration is 10% for both forms. For the nano form, an additional restriction: it will not be allowed to be used in products that may lead to inhalation. For the nano form, purity requirements are indicated (≥ 97 %) and 50 % of the particles in the particle size distribution must have a diameter ≥ 50 nm. The use of the nano and non-nano form of the HAA299 filter in the product at the same time should not exceed a total of 10%.

Homosalate (CAS: 118-56-9) is currently regulated by Annex VI, item 3 of Regulation 1223/2009 (maximum concentration in the finished product equal to 10%). The EC proposes to lower the allowed concentration of the ingredient in cosmetic products, in line with the SCCS opinion (SCCS/1638/21). The draft introduces a restriction for Homosalate in face products with the exception of propellent spray products at a maximum concentration of 7.34%. The transitional periods foreseen for Homosalate are:

  • 24 months to market the products
  • 30 months for making non-compliant products available on the market after the entry into force of the Regulation.

Resorcinol (CAS: 108-46-3) is included in Annex III, item 22 of Regulation 1223/2009/EC. The amendment concerns a correction to the existing entries by changing the warning in consumer products: "do not use to dye eyebrows and eyelashes" to "do not use to dye eyelashes".

 

Anniversary conference of Kosmetyczni.pl just around the corner!

Already more than 150 people have registered for our anniversary conference, organised on the occasion of the 20th anniversary of the Polish Union of the Cosmetics Industry. In total, including speakers, experts, guests of honour, there will be more than 200 of us. But there can never be too many guests!
Registration is still open. We would be honoured if - despite your busy autumn calendars - you can find time to meet us on 5th September at the Holiday Inn in Józefów.

 

One member company is interested in buying back raw material:

  • 1 kg Vanzan NFC (xanthan gum)
  • 0.5 kg Aurafilm S
  • 1kg ViscoOptima SE-LQ-RB
  • 1kg Amaze Nordic Barley

Contact in this case: Monika Świt-Popławska (mswit@kosmetyczni.pl).

 

 

 

 

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