Although it has no regulatory authority, the Council of Europe is often a precursor. From its headquarters in Strasbourg, the institution, which comprises 47 member countries, has been the first to define natural cosmetics, to recommend better consumer information on sun protection or to propose the generalization of cosmetovigilance. Inviting States Parties to the Convention on the Elaboration of an European Pharmacopoeia [1], to better protect children under three years against the risks caused by cosmetic products which would be unsuited for them, the Council of Europe echoed the concerns raised by health professionals, particularly in France.

Ingredients, impurities and packaging

On a number of points however, the recommendation of the Council of Europe mostly concerns non EU members and invites them to take over the provisions already included in the new Regulation (EC) No 1223/2009 on cosmetic products, in particular on the product safety assessment or the basic requirements for ingredients, or in other texts such as REACH.

But the Council of Europe also calls for particular attention to be paid to impurities and traces from raw materials, packaging materials, manufacturing processes, alterations or chemical interactions in the finished product, which should be evaluated, as well as to preservatives, the presence of which should be reduced to "the minimum effective concentration". It also urges to pay the greatest attention to the choice of packagings which "should provide appropriate protection to ensure the physicochemical stability and avoid microbial contamination during storage, distribution and use" and whose materials "should be inert and should not release any toxic substances in the product."

Specific risks

If young children have been for the past years the subject of a very special regulatory attention, this is due to important discoveries on their particular sensitivity to certain chemicals, especially concerning endocrine disruptors. Indeed, several organs and vital physiological functions do experience a significant development during childhood, particularly in young children under three years.

While recalling these points, the Council of Europe also calls to take into better account the relatively greater exposure of children, not only because of their low weight, but also because of their specific behaviour involving a higher risk of ingestion.

Despite its limited scope, both because of the number of states theoretically concerned and because of its non-binding character, this resolution should logically lead to a strengthening of the legislative framework on cosmetics intended for children under three years, a strengthening already well underway in the European Union.

Read the text of the Resolution CM/ResAP(2012)1