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Cosmetics

The EAEU Cosmetics Approval System: Webinar Notes

Webinar slide listing the five EAEU member states and the two cosmetics approval forms

Almost every manufacturer entering the EAEU market has to assess the conformity of its products, in the form of a certificate or a declaration depending on the product type. This webinar worked through the cosmetics route end to end, from approval forms to the ingredient lists.

Why does conformity assessment come first?

Almost every manufacturer or importer entering the EAEU market has to assess the conformity of its products. Depending on the product type, that assessment produces either a certificate or a declaration of conformity.

For cosmetics the picture is more layered than that summary suggests, which is what this webinar set out to unpack. It was delivered by Amina Karim, team leader for EAEU / CIS.

What did the webinar cover?

  1. Eurasian Economic Union member states, and the main approval forms.
  2. Declaration of Conformity (DoC).
  3. State Registration Certificate (SRC).
  4. Requirements for obtaining the Declaration of Conformity.
  5. Requirements for obtaining the State Registration Certificate.
  6. Labelling and EAC marking requirements for cosmetics.
  7. Cosmetic ingredients: the prohibited list, the restricted list, the positive list.
  8. Requirements for physical and chemical indicators, microbiological safety, and toxicological clinical indicators.
  9. The main steps to register a product.
  10. Q&A.

The two agenda items that decide most projects

Item 7, the three ingredient lists. A formulation has to clear all three. An ingredient can be permitted in principle, restricted in concentration, and prohibited in a specific product category, so a single check against a prohibited list is not sufficient.

Item 8, the safety indicators. Physical and chemical, microbiological, and toxicological clinical. The composition determines which apply, which in turn determines the testing programme and its cost.

Between them, these two items explain why cosmetics quotations vary so widely between apparently similar products, and why an accurate composition in percentage is the first thing a certification body asks for.

What participants took from it

Feedback centred on the Q&A more than on the presentation, a reasonable signal that the value of a session like this lies in the specific edge cases.

Sources

  • TR CU 009/2011, On safety of perfumery and cosmetic products, Eurasian Economic Commission
  • Competent national authorities of the member states, state registration of products
  • EAEU lists of prohibited, restricted and permitted cosmetic ingredients

Frequently asked questions

What are the two approval forms for cosmetics?

A Declaration of Conformity under TR CU 009, and a State Registration Certificate for the product categories that require hygienic approval. Which applies depends on the product type, and some products need the SRC followed by the declaration.

What ingredient lists apply to cosmetics?

Three: the prohibited list, the restricted list, and the positive list. A formulation has to be checked against all three, because an ingredient can be permitted in principle and restricted in concentration or in a particular product type.

Which safety indicators are assessed?

Physical and chemical indicators, microbiological safety, and toxicological clinical indicators. Together these define the testing programme, and the composition determines which of them apply to a given product.

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