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GHS and Cosmetics

Posted Date:2022/11/30

GHS is an internationally recognized system for classifying and labeling chemical substances and mixtures. Since most cosmetics are mixtures, many have questioned whether GHS can also be applied to cosmetics. In this article, we will summarize the latest status of GHS adoption in the cosmetics industry and some of the main issues to consider.

United Nations GHS Purple book

The purple book of the United Nations Uniform System states that, when ingested deliberately, the uniform system does not cover drugs, food additives, cosmetics and pesticide residues in food. However, these types of chemicals will be covered where they may come into contact with workers and, where possible, should be covered during transport.

Given that most countries/territories have used GHS as a workplace, it is generally expected that bulk cosmetic ingredients and cosmetics will require GHS labels and safety data sheets due to possible worker exposure, whereas finished cosmetics do not require GHS labels. However, there may be some exceptions in some countries.

Eu CLP Regulations and cosmetics

In the European Union, GHS is implemented through CLP Regulation (EC) 1272/2008.

Regulation (EC) 1272/2008 states that the Regulation applies to all substances and mixtures placed on the EU market, unless other Community legislation "provides for more specific rules on classification and labelling". Cosmetic labelling is governed by Regulation (EC) No. 1223/2009 and therefore Regulation (EC) No. 1272/2008 does not apply to the labelling of most cosmetic products.

Some, including the German Federal Environment Agency (UBA) and the Swedish chemical agency Kemihave, have challenged the CLP label exemption for cosmetics, which can also contain environmentally harmful substances that can end up in the environment or in wastewater.

American Hazard Notification Standards and Cosmetics

In the United States, OSHA's Hazard Notification Standard 2012 clearly states that the GHS/HCS label does not apply to:

Cosmetics packaged for retail sale to consumers and for personal consumption by employees in the workplace;

Note that cosmetic manufacturers of bulk or premix still need to label their containers according to GHS as they are not packaged for sale to consumers.

GHS cosmetics in other countries

Most other countries/regions such as Japan, China, Canada, Australia and South Korea do not require GHS classification and labelling of cosmetics at the retail stage as they are subject to separate labelling requirements.