So, your product is compliant with all requirements of the regulation 1223/2009… Are you then ready to go on the market?
Well, that may not always be the case. Depending on your specific situation, other “safety-related” regulations may apply to your product as well, even if you intend to place the product on the market as “cosmetic”.
In some cases, especially if you are importer of cosmetic products manufactured outside the EU, REACH regulation may apply as well.
Depending on your products presentation and activity claims, and in some cases depending on composition and content of certain ingredients, your product may be regarded as biocide, drug/medicine or a medical device.
Which requirements apply and how do you ensure product compliance in that case? In some cases a product may just be disqualified as cosmetic because it does not have a clear cosmetic function (it does not meet the basic definition of a cosmetic product as defined in reg 1223/2009) such as in case of some “aroma-therpay” products. Which legislation and which requirements do then apply to this kind of products?
Zoran Gavric, The Regulatory Company, The Netherlands