Home Cosmetic Science Talk Formulating About labeling Regulation (EC) No 648/2004, 1223/2009

  • About labeling Regulation (EC) No 648/2004, 1223/2009

    Posted by oldman20 on June 24, 2025 at 12:07 am

    Regulation (EC) No. 648/2004 requires labeling the EDTA content if it exceeds 0.2% in the product. So I understand that if EDTA is less than 0.2%, there is no need to labeling according to 648/2004?

    Mặt khác, theo EC 1223/2009 In cosmetics, all ingredients (except for some very small exceptions such as negligible impurities) must be listed on the label in the order of mass decreasing (the name of the INCI).

    I am really confused

    oldman20 replied 3 weeks, 4 days ago 2 Members · 5 Replies
  • 5 Replies
  • PhilGeis

    Member
    June 24, 2025 at 4:52 am

    <b style=”font-family: inherit; font-size: inherit;”>Regulation (EC) No 648/2004, 1223/2009 addresses household and industrial “detergents” NOT cosmetics.

    “Detergent” means any substance or preparation containing soaps and/or other surfactants intended for washing and cleaning processes. Detergents may be in any form (liquid, powder, paste, bar, cake, moulded piece, shape, etc.) and marketed for or used in household, or institutional or industrial purposes.

    - “Cleaning preparation”, intended for domestic all purposes cleaners and/or other cleaning of surfaces (e.g.: materials, products, machinery, mechanical appliances, means of transport and associated equipment, instruments, apparatus, etc.);

    . “Washing” means the cleaning of laundry, fabrics, dishes and other hard surfaces.

    • oldman20

      Member
      June 26, 2025 at 4:04 am

      Perhaps you do not understand my question, my idea is that EDTA needs to be written in the composition when the two rules I quote above seems to be confused?

      • PhilGeis

        Member
        June 26, 2025 at 4:52 am

        These are separate and independent regulations

        One regulates only household and industrial detergents products, NOT cosmetics . That is Regulation (EC) No 648/2004, 1223/2009 that only requires EDTA on ingredient labeling fs >0..2%.

        EU Cosmetic Directive that regulates cosmetics NOT household and industrial detergents requires EDTA on ingredient label if added at any level.

        If you question is why the difference? Who knows - there may be a record of consideration somewhere but the regulatory expectation is always that folks comply, not ask why.

        • oldman20

          Member
          June 26, 2025 at 8:46 pm

          many thank, so i understand that the detergent does not need to be labeling if Edta <2%?

          Just curious is the FS you wrote, what is it mean?

          • This reply was modified 3 weeks, 4 days ago by  oldman20.
        • oldman20

          Member
          June 26, 2025 at 8:57 pm

          For example, you can see it after you can help me? I asked who but not very sure

          Ingredients:

          Aqua,Sodium Laureth Sulfate, Linear Alkylbenzene Sulfonate, C12-14 Alcohol Ethoxylates, Parfum,** Alpha-Isomethyl Ionone, Coumarin, Benzyl salicylate, Galaxolide **, Cocamidopropyl Betaine, Sodium Hydroxide, Sodium chloride, Hydroxypropyl Methylcellulose, Methylchloroisothiazolinone & Methylisothiazolinone, DMDM Hydantoin, Ethylendiamine Tetraacetic Acid

          My Edta is 0.1%. Another type can be up to 0.2%

          And especially I wonder about labeling the irritating ingredient in the fragrance according to SDS and comparing the Regulation 1223/2009, there is Alpha-Isomethyl Ionone, Coumarin, Benzyl Salicylate, Galaxolidide

          Do I record the label as above? There is a labeling rule but there is no specific example, so I am not sure if I write it properly

          1st is …, Parfum,** Alpha-Isomethyl Ionone, Coumarin, Benzyl salicylate, Galaxolide **, …

          2nd is <i style=”font-family: inherit; font-size: inherit;”>…, Parfum, Alpha-Isomethyl Ionone, Coumarin, Benzyl salicylate, Galaxolide, …

          Sincere thanks for your help

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