The possible addition of tens of fragrance components to the current list of 26 allergens that must be labelled on cosmetic products is a source of concerns for the whole cosmetics industry and in particular for SMEs.
According to IFRA and the two other trade organisations, efficient and relevant information must be provided to people suffering from skin allergy, this information must be provided before choosing to use a cosmetic product containing certain skin sensitizers, it must be straightforward and easily accessible, as well as rigorously identical across the industry and proportionate, and manageable by all concerned in the supply chain.
“Given the intrinsic nature of elicitation thresholds to each individual, it is essential that the way in which the information is structured helps each individual tailor his management of the risk under consideration,” explain the three organisations.
According to the trade bodies, a hybrid informative approach combining “several tools such as pictograms, on-pack warnings, web sites and toll free access to consumer help centres,” would be the best way to address all the efficiency, proportionality and manageability pre-requisites.
They recommend adding 12 “allergens of concern” (as enumerated in table 13.5 of the Scientific Committee on Consumer Safety opinion ) to the list of substances that must be labelled on the external packaging of cosmetic products. “These substances are the ones frequently prevalent in the reported cases of skin allergies”, they say.
For all other substances, a pictogram could be used to draw consumers’ attention to a specific web based data bank disclosing the full list of skin sensitizers contained in the product. “This website will enable downstream consumer product companies to add any relevant information, notably the one relative to the presence of allergens and guidance on applications and warnings,” add IFRA, Cosmebio and UEAPME.
According to the three trade organisations, this hybrid approach could also offer additional advantages. For instance, the voluntary recommendations provided by the brands through their websites could generate a substantial benefit for allergic consumers. For the medical community, on-line consultation of information would even offer the option to analyse the patient’s extensive products usage without the burden of referring to the physical products.