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mikej.1981  
#1 Posted : 13 July 2018 10:07:35(UTC)
Rank: Forum user
mikej.1981

I have come across a client using soaps obtained from their parent company outside the EU, there is no labelling / COSHH asssessments or SDS available. I have advised they need these but what about the CLP labelling on the bottles can anyone advise if they should obtain labels to attach or are these Hand soaps being inapropriately obtained.

Roundtuit  
#2 Posted : 13 July 2018 11:14:56(UTC)
Rank: Super forum user
Roundtuit

All materials supplied in the EU are covered by REACH which is referenced in other regulations such as Cosmetic Products and Biocidal Products (for contained preservatives)

Classification of substances and mixtuires supplied should be in accordance with CLP and information should be available for the end user either through appropriate product labelling or a Safety Data Sheet in accordance with the regulations

It should be noted that some substances are specifically excluded within Europe under the Cosmetic Products Regulation which may be normal in overseas formulations e.g. microbeads in wash off products

The manufacturer, importer or distributor is responsible under the regualtions and should never assume a product is safe e.g. from todays news - Johnson & Johnson to pay $4.7billion in punitive damages in a case relating to asbestos in baby talc.

Roundtuit  
#3 Posted : 13 July 2018 11:14:56(UTC)
Rank: Super forum user
Roundtuit

All materials supplied in the EU are covered by REACH which is referenced in other regulations such as Cosmetic Products and Biocidal Products (for contained preservatives)

Classification of substances and mixtuires supplied should be in accordance with CLP and information should be available for the end user either through appropriate product labelling or a Safety Data Sheet in accordance with the regulations

It should be noted that some substances are specifically excluded within Europe under the Cosmetic Products Regulation which may be normal in overseas formulations e.g. microbeads in wash off products

The manufacturer, importer or distributor is responsible under the regualtions and should never assume a product is safe e.g. from todays news - Johnson & Johnson to pay $4.7billion in punitive damages in a case relating to asbestos in baby talc.

Waz  
#4 Posted : 13 July 2018 12:50:35(UTC)
Rank: Forum user
Waz

The supplier is responsible for ensuring all the relevant EU regulatory elements are met.  Remember, not every substance will hold classification as being hazardous and therefore, will not fall under the remit of CLP etc.

Kate  
#5 Posted : 13 July 2018 13:43:45(UTC)
Rank: Super forum user
Kate

It's true that suppliers within the EU have responsibility, but when the supply is from outside the EU, the importer is responsible.  Normally this responsibility takes the form of requiring the supplier to provide all the require documentation and labelling, but the legal responsibility remains with the importer.

Roundtuit  
#6 Posted : 13 July 2018 14:21:32(UTC)
Rank: Super forum user
Roundtuit

from gov.uk

All cosmetic products supplied in the UK, whether for consumer or professional use, must comply with European Cosmetics Regulation 1223/2009, which came into force on 11 July 2013. It also requires safety assessments on the products, as listed in Annex I. The regulation requires you to notify the European Commission of every product, using the Cosmetic Product Notification Portal (CPNP).

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R1223-20160812&from=EN

Article 2 definitions

(a) ‘cosmetic product’ means any substance or mixture intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours;

(b) ‘substance’ means a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition;

(c) ‘mixture’ means a mixture or solution composed of two or more substances;

(d) ‘manufacturer’ means any natural or legal person who manufactures a cosmetic product or has such a product designed or manufactured, and markets that cosmetic product under his name or trademark;

(e) ‘distributor’ means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a cosmetic product available on the Community market;

(f) ‘end user’ means either a consumer or professional using the cosmetic product;

(g) ‘making available on the market’ means any supply of a cosmetic product for distribution, consumption or use on the Community market in the course of a commercial activity, whether in return for payment or free of charge;

(h) ‘placing on the market’ means the first making available of a cosmetic product on the Community market;

(i) ‘importer’ means any natural or legal person established within the Community, who places a cosmetic product from a third country on the Community market;

Roundtuit  
#7 Posted : 13 July 2018 14:21:32(UTC)
Rank: Super forum user
Roundtuit

from gov.uk

All cosmetic products supplied in the UK, whether for consumer or professional use, must comply with European Cosmetics Regulation 1223/2009, which came into force on 11 July 2013. It also requires safety assessments on the products, as listed in Annex I. The regulation requires you to notify the European Commission of every product, using the Cosmetic Product Notification Portal (CPNP).

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R1223-20160812&from=EN

Article 2 definitions

(a) ‘cosmetic product’ means any substance or mixture intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours;

(b) ‘substance’ means a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition;

(c) ‘mixture’ means a mixture or solution composed of two or more substances;

(d) ‘manufacturer’ means any natural or legal person who manufactures a cosmetic product or has such a product designed or manufactured, and markets that cosmetic product under his name or trademark;

(e) ‘distributor’ means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a cosmetic product available on the Community market;

(f) ‘end user’ means either a consumer or professional using the cosmetic product;

(g) ‘making available on the market’ means any supply of a cosmetic product for distribution, consumption or use on the Community market in the course of a commercial activity, whether in return for payment or free of charge;

(h) ‘placing on the market’ means the first making available of a cosmetic product on the Community market;

(i) ‘importer’ means any natural or legal person established within the Community, who places a cosmetic product from a third country on the Community market;

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