CosmeticsEnglish

Does REACH apply to cosmetic products?

The REACH Regulation (EC/1907/2006) concerns the Registration, Evaluation, Authorisation and Restriction of Chemicals. Contrary to the Cosmetics Regulation, REACH does not apply to products, but to individual chemical substances. As such, it applies to chemicals used in industrial processes as well as in our day-to-day lives: substances present in articles such as clothes, furniture and electrical appliances, and in cleaning products, paints and… cosmetics.

 

Does REACH affect your activities?

In the following scenarios, we assume you are located within the EU. To know whether you have REACH obligations, see what scenario describes your situation best:

 

  1. You formulate cosmetic products using ingredients purchased from an EU supplier

In this case, you are a REACH downstream user. Read more about your downstream user responsibilities.

 

  1. You formulate cosmetic products using ingredients you purchased from a non-EU supplier

You are a REACH importer. If you import the chemical in a quantity larger than 1000 kilos (1 tonne) per year, you must register this substance. If you import the chemical in a quantity larger than 10 tonnes per year, you must ensure that the REACH registration dossier contains a Chemical Safety Report (CSR). The risk to human health of end users caused by the use of the substance in your cosmetic product does not need to be addressed in the CSR, as this aspect is covered by the cosmetic Product Safety Report. It must, however, include the environmental and occupational aspects of this use.

The duty to register applies regardless of whether you subsequently sell the substance on the market or use it in your own processes. In the latter case, you must identify and apply the appropriate measures to control risks associated with the use of chemicals.

 

  1. You manufacture the ingredient(s) of your cosmetic product yourself

You are a REACH manufacturer. If you manufacture the chemical in a quantity larger than 1000 kilos (1 tonne) per year, you must register the substance. If you manufacture the chemical in a quantity larger than 10 tonnes per year, you must ensure that the REACH registration dossier contains a Chemical Safety Report (CSR). The risk to human health of end users caused by the use of the substance in your cosmetic product does not need to be addressed in the CSR, as this aspect is covered by the cosmetic Product Safety Report. It must, however, include the environmental and occupational aspects of this use.

The duty to register applies regardless of whether you subsequently sell the substance on the market or use it in your own processes. In the latter case, you must identify and apply the appropriate measures to control risks associated with the use of chemicals.

 

  1. You import a cosmetic end-product from outside the EU

If you import a cosmetic product from outside the EU, you are a REACH importer of each of the individual chemical substances in the product. The same is true for cosmetic articles (e.g. cleaning whipes). Based on the concentration of the substance in the imported product and the volume of product you import, you must calculate the total annual quantity of imported substance. Does this quantity exceed 1 tonne per year, you must register this substance. If you import the chemical in a quantity larger than 10 tonnes per year, you must ensure that the REACH registration dossier contains a Chemical Safety Report (CSR). The risk to human health of end users caused by the use of the substance in your cosmetic product does not need to be addressed in the CSR, as this aspect is covered by the cosmetic Product Safety Report. It must, however, include the environmental and occupational aspects of this use.

 
Please note: in any of the scenarios above you are exempted from the REACH obligation to compile SDSs, as downstream safety communication is covered by the Cosmetics Regulation instead.