Borderline Manual of Cosmetic Products Updated
European Union Borderline Cosmetic Products Manual Adds Two New Titles: False Nails/Eyelash Adhesives and Magnetic Eyeliners
On February 20, 2024, the European Commission published an updated version of the Manual of the Working Group on Cosmetic Products (Sub-group on Borderline Products) on the Scope of Application of the Cosmetics Regulation (EC) No 1223/2009 Version 5.3 (November 2023). The latest version includes the following two new product groups:
- Glues/adhesives intended to fix articles like fake nails, false eyelashes, jewellery on teeth, etc.
- Magnetic eyeliners
The Borderline Manual is a guide created by the EC Working Group on cosmetic products. Its aim is to assist companies in determining whether their products fall within the scope of the EU Cosmetics Regulation.
Principles for the Classification of Cosmetics
The decision on whether a product should be considered as cosmetic should be made by collectively assessing the regulations applicable to the product groups it may fall into, based on the characteristics of the product. When making this decision, factors such as the composition of the products, their intended use, application area and method, presentation, mode of action, claims, and all other relevant factors should be considered together.
Adhesives and glues
Adhesives and glues used to secure items such as false nails and false eyelashes meet two elements of the cosmetic product definition: the composition of the product and the application area. However, the presence of a primary cosmetic function should be evaluated depending on the circumstances. In this regard, the Borderline Manual explains that if the adhesive can alter the appearance of the application area on its own, it can be considered a cosmetic product. Conversely, if the adhesive serves a specific function, such as attaching an item to the external part of the human body, it cannot be classified as cosmetic due to the lack of a cosmetic function. In this case, the product must comply with the requirements of the General Product Safety Regulation.
Magnetic eyeliners
A magnetic eyeliner, which also serves a secondary purpose such as allowing false eyelashes to be attached to the eyelid, is a regular eyeliner. According to the Borderline Cosmetic Products Manual, if the primary function of the product is the same as that of a regular eyeliner and the product's content is appropriate, it can be classified as "cosmetic." In this case, its other function can be evaluated as secondary.
You can review the manual for more details and contact us for support.
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