I wrote to the Cosmetic, Toiletry & Perfumery Association (CTPA) when a client wanted to use Naticide in a product I was writing a CPSR for. Due to the lack of information available, I advised my client to use a more established preservative. Because I felt we might see Naticide again, so I contacted CTPA. Below is the response.
"Thank you for taking the time to contact CTPA regarding this product.
As you may already know, the CTPA is the trade association for the UK cosmetic, toiletry and perfumery industry. The Association’s role is to advise our members about the strict legal framework for cosmetics, to represent industry views to UK Government, external stakeholders and help promote information to the media on issues relating to the safety of cosmetic products.
The company which sells the product in question is not a member of CTPA, and unfortunately we are unable to help with questions on individual products. However, thank you for bringing this matter to our attention and we will investigate it further. We are though happy to provide information on the strict legal requirements that cover cosmetic products and their ingredients.
As you may be aware, cosmetic products in the UK are regulated under the EU Cosmetic Products Regulation 1223/2009. Only cosmetic preservatives from a positive list (Annex V) may be used in cosmetic products, and preservatives are defined in the Regulation as “substances which are exclusively or mainly intended to inhibit the development of micro-organisms in the cosmetic product.” This confirms that a substance which is added to a cosmetic product and whose main or only function is to inhibit microbial growth must be listed on Annex V.
Preservatives are important ingredients that help keep the product, and so the user, safe throughout its intended use. All ingredients used in cosmetic products, including preservatives, must be safe to use. If an ingredient is not safe as used in cosmetic products it would be banned.
Of course, there are ingredients that can contribute to the preservative system of a product, even though they are not included for this purpose. We always give alcohol as the best example, and so it might be that products with a high alcohol content, in this example, do not require further preservation. This could be the case for a number of ingredients. However it is also the case that in the legally required Product Information File (PIF), as part of the Cosmetic Product Safety Report, the intended function of each ingredient must be listed. Therefore the primary function will be clear. Therefore if a ‘multifunctional’ ingredient is being used, i.e. a substance not on Annex V, then its primary function cannot be as a preservative. It must also be present in the formulation at a level to achieve its primary function as listed in the PIF.
CTPA also considers that intentionally adding a substance to a cosmetic product for its preservative properties, but is not listed on Annex V, in order to claim ‘preservative free’ is misleading to the consumer and perpetuates the myth that preservatives are somehow bad ingredients, which is not the case.
‘Free from’ claims are covered by the Common Criteria on Cosmetic Claims, which is part of the EU Cosmetic Products Regulation. The EU Commission has expressed concern about the use of ‘free from’ claims where the claim is considered to be denigrating authorised and scientifically proven safe ingredients, such as preservatives. Consequently the Commission updated its guidance and published its Technical Document on Cosmetic Claims in July 2017 to include Annexes which address claims of the ‘free from’ nature (Annex III)."
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