Ramzia Lefebvre, Intertek

Ramzia Lefebvre, Intertek

Premium Beauty News - The adoption by the Customs Union of Technical Regulations applicable to cosmetic products, it’s good news for manufacturers?

Ramzia Lefebvre - This is great news! With an annual growth rate that could exceed 8% until 2013, the Russian market of cosmetics is one of the most dynamic in the world. For cosmetic manufacturers, the Technical Regulation TR TC 009/2011 [1] has the double advantage of harmonizing the Russian regulation with the regulation in force in the European Union and to abolish the dual system for achieving compliance. Best of all, these technical regulations also include Belarus and Kazakhstan, the two other members of the Customs Union created in 2010.

Premium Beauty News - How does this Technical Regulation work exactly?

Ramzia Lefebvre - Its aim is to harmonize the requirements on cosmetic products for the member countries of the Customs Union and to get more in line with European rules. This ranges from the manufacturing process to product labelling.

Its structure and content are based on both the European Directive 76/768/EEC and the European Regulations 1223/2009 [2]. The definition of cosmetics and the lists of regulated ingredients are almost identical. The text of the Technical Regulations even includes a definition of nanomaterials which is very similar to the one found in the European Regulation and mentions for the first time the term GMP (Good Manufacturing Practice). Similarly, the definition of "manufacturer" is complemented by the notion of "responsible for placing on the market." There has been quite some progress as you can see!

Compared to the current regulation in Russia, this text also has the advantage of grouping all categories of cosmetic products in a single document.

However, the harmonization with the current EU rules is not total, particularly with regards to the maintenance of the obligation to establish the product compliance by a third party. Similarly for the labelling of products, the obligation for an expiration date is maintained, and all information must be written in the official language of the member state of the Customs Union in which the product will be marketed.

Mastering all these aspects, and anticipating changes and risks in connection with them, are key to the success of export operations. For this purpose, by relying on the services offered by a provider like Intertek who has a dual product and business expertise through its Health & Beauty division and its position as a key player in export certification, exporters are better equipped to face these risks and gain autonomy.

Premium Beauty News - And for the placing on the market? Will cosmetic manufacturers benefit from simplified procedures?

Ramzia Lefebvre - Yes, certainly. However, prudence is called for because experience has shown us that changes are not always synonymous with simplification, as was the case with the GOST R declaration of conformity in 2010.

Eurasian Conformity

Eurasian Conformity

In practice, from July 2012, only the Declaration of Conformity to the Technical Regulations will be required for most products. Only 13 product categories will continue to be subject to Registration as a single document: artificial tanning products, skin whitening, tattooing, personal hygiene; protection products against harmful manufacturing factors; cosmetics for children; hair dyes and lightening products; hair perms and relaxers; products containing nano-components, depilatory products; peelings; products for dental and oral hygiene containing fluorine (as of a certain percentage of fluorine) teeth whiteners (as of a certain percentage of hydrogen peroxide)

Both, the Declaration and the Registration documents will be valid indefinitely and on the whole territory of the Customs Union. Conversely, the conditions needed to obtain the two documents were brought into line with the most demanding conditions, those applying to existing Registrations.

To note that products which are certified according to the requirements of the Technical Regulations should bear the EAC conformity mark (for Eurasian Conformity) of the Customs Union, and no longer the Russian Gost-R mark.

Click on the image to download the original Russian text of the new Technical Regulation:

Technical Regulation No. TR TC 009/2011 (in Russian)