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EU: Clarification of relationship between Cosmetics Regulation and REACH

Since March 2013 there has been a ban in Europe on testing cosmetic ingredients in animals. However, some cosmetic in­gredients are also used for other purposes and must therefore be registered as chemicals under REACH, the European Regula­tion on chemicals. Registration under REACH can require ani­mal testing to fulfil the information requirements.


The relationship between the Cosmetics Regulation (Regula­tion (EC) No 1223/2009) and the REACH (Regulation (EC) No. 1907/2006) information requirements was clarified by ECHA in a Fact Sheet announced in the October 27, 2014 ECHA News alert, stating the following:

– Registrants of substances that are exclusively used in cosmet­ics may not perform animal testing to meet the information requirements of the REACH human health endpoints, with the exception of tests that are done to assess the risks to work­ers exposed to the substance. Workers in this context, refers to those involved in the production or handling of chemicals on an industrial site, not professional users using cosmetic products as part of their business (e.g., hairdressers).

– Registrants of substances that are used for a number of pur­poses, and not solely in cosmetics, are permitted to perform animal testing, as a last resort, for all human health end­points.

– Registrants are permitted to perform animal testing, as a last resort, for all environmental endpoints.

Therefore, the testing and marketing bans in the Cosmetics Regulation do not apply to testing required for environmental endpoints, exposure of workers and non-cosmetic uses of sub­stances under REACH.


Registrants of substances registered exclusively for cosmetic use will still have to provide the required information under REACH wherever possible, by using alternatives to animal test­ing (such as computer modelling, read-across, weight of evi­dence, etc.).




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