Services

INCI Statements

The International Nomenclature of Cosmetic Ingredients, abbreviated INCI, are the unique identifiers for cosmetic ingredients such as waxes, oils, pigments, and other chemicals that are assigned in accordance with rules established by the Personal Care Products Council (PCPC), previously the Cosmetic, Toiletry, and Fragrance Association (CTFA). INCI names often differ greatly from systematic chemical nomenclature or from more common trivial names and are a mixture of conventional scientific names, Latin and English words. INCI nomenclature conventions “are continually reviewed and modified when necessary to reflect changes in the industry, technology, and new ingredient developments”.

Natural Science Consultants provides guidance on correct INCI terminology and labelling.

IFRA Standards – 51st Amendment

In 1973 the global fragrance industry came together to form a new international association. Its mission: to represent the collective interests of the industry and promote the safe use and enjoyment of fragrances around the world.

Nearly half a century later, The International Fragrance Association (IFRA) brings together seven multinational companies and 21 national associations in 23 countries across four regions.

The goal is unchanged – to create fragrances that bring joy, emotion and colour to people’s lives, to support prosperity through jobs and scientific advances, and to act responsibly – protecting consumers through its Code of Practice and IFRA Standards, and showing respect for the environment we all share.

The IFRA Standards exist to provide that same confidence when it comes to the safe use of fragrance ingredients.

For more than 40 years, the fragrance industry has carefully examined ingredients used in fine fragrance and in the household and personal care products everyone enjoys. The organisation sets rules that are recognised by government authorities and trade bodies around the world and which are compulsory for all IFRA members – who produce around 80 per cent of the global volume of fragrance. 

Whether ingredients are natural or synthetic, they are monitored, tested and assessed so that rules can be set for their safe use. Some ingredients are considered too harmful to be used safely, so they are banned. Others have limits placed on their use, ensuring they are only used in quantities that are safe for people and some have rules layed down that control the purity or origin of the ingredient.

These rules – the IFRA Standards – are revised on a regular basis. The current level reflects the introduction of several improvements to the risk assessment methodology. The 51st Amendment also includes a complete revision of product classes and types.

Natural Science Consultants provides guidance on the use of IFRA standards, categorisation of product types and certification.

Allergens

Fragrance allergens can be something of a quagmire, particularly now that the list of those that must be formally labelled has grown to 81. For the first time these include 27 essential oils, referred to in the regulations as Natural Complex Substancers (NCS).

Natural Science Consultants provides guidance on all aspects of fragrance allergenicity – what is, what isn’t and what maybe an allergen, together with the affects on your products.

Regulations

Regulation (EC) 1223/2009 on cosmetics set binding requirements for cosmetic products that had been made available on the market within the EU. Manufacturers of products that fell under the category of cosmetics were required to abide by this regulation as they prepared their initial release of products and while continuing to sell products within the Member States of the EU.

With effect from 1 January 2021 the EU regulation has been superceded in the UK by Schedule 34 to the Product Safety and Metrology etc (Amendment etc) (EU Exit) Regulations 2019. Very little has changed eg:

A safety assessment must be completed before a cosmetic product is placed on the GB market, in order to demonstrate that the product is safe for human health when used under normal or reasonably foreseeable circumstances. The safety assessor is still required to be suitably qualified.

However, the Responsible Person must now be based in the UK.

Natural Science Consultants can provide guidance on completing the safety assessment but is not a suitably qualified safety assessor.

Responsible Person

As has been pointed out above, the cosmetic regulations require a UK based Responsible Person. The responsibilities include ensuring the following:

• Product claims substantiation
• Correct labelling
• Safety assessment carried out
• Product Information File maintained
• Technical documentation complete and updated
• Compliance with national and international regulations
• National and international registrations in place
• The Submit Cosmetic Product Notification (SCPN) has been carried out

Natural Science Consultants can act as the Responsible Person.

Safety Issues

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals.

The EU REACH Regulation has been brought into UK law under the European Union (Withdrawal) Act 2018. REACH, and related legislation, has been replicated in the UK with the necessary changes to make it operable in a domestic context. The key principles of the EU REACH Regulation have been retained. This regime is now in operation and is known as UK REACH. UK REACH applies to the majority of chemical substances; those used in industrial processes and daily life, for example in cleaning products, paints as well as in articles such as clothes, furniture and electrical appliances.

UK REACH places the burden of proof on companies. Companies are required to identify and manage the risks present by substances they manufacture and market in GB. They must be able to demonstrate how the substance can be used safely and they must communicate the risk management measures to the users.

Safety Data Sheets (SDS) are required by the UK REACH Regulation.

SDS are important documents in the safe supply, handling and use of chemicals. They help ensure that those who use chemicals in the workplace use them safely without risk of harm to users or the environment.

The SDS will contain the information necessary to allow employers to do a risk assessment as required by the Control of Substances Hazardous to Health Regulations (COSHH). The SDS itself is not an assessment. However, it will describe the hazards helping employers assess the probability of those hazards arising in the workplace.

SDS are a must if a chemical is hazardous and is being supplied for use at work, whether in packages or not. SDS are also needed if your chemical is not classified as hazardous but contains small amounts of a hazardous substance. A safety data sheet is not a risk assessment.

Natural Science Consultants can provide guidance on REACH requirements and also completing safety data sheets.