On November 12, 2020, the European Commission released a technical guidance document that provides a non-exhaustive list of product claims that do not support the classification of leave-on hydro alcoholic hand gels as cosmetic products due to perception.
The document was published following the findings of the Sub-Group on Borderline Products on October 8, 2020, which were endorsed by the Working Group on Cosmetic Products via written procedure on October 23, 2020 and at its meeting on 12 November 2020.
The technical document complements the latest borderline manual and the guidance on the applicable legislation for leave-on hand cleaners and hand disinfectants.
Labeling elements that would not support a main cosmetic function of leave-on hydro alcoholic hand gels (not to be used on cosmetic products):
• Antibacterial, antimicrobial, antiviral, virucide, antifungal (and their attributes, such as ‘antiviral properties’, ‘antibacterial ingredients’, ‘inhibits bacterial growth’)
• Disinfecting, disinfectant, disinfection, sanitizer, sanitizing
• Kills X% bacteria/viruses/microbes
• Formulation recommended by the World Health Organisation (WHO)
• Anti-COVID-19, anti-coronavirus, anti-SARS
References or allusions to:
• Infection, pandemic, diseases
• COVID-19, coronavirus, SARS-CoV-2
• Microorganisms, bacteria, viruses, pathogens, germs, fungi
• Medical use
• Percentage of alcohol in the product
• Safe hands
Pictures or graphical elements of:
• (Corona)virus, bacteria, microbes
• (Red) cross (when suggesting a medical connotation)
• Shield (when indicating protection against microorganisms)
• STOP sign (when indicating preventing/controlling the spread of a disease or infection or microbes)
• Any sign related to hospital, pharmacy, ambulance, first aid, etc.
• CLP pictograms
SGS Hand Sanitizer and Disinfectant Services
SGS offers a comprehensive range of testing and compliance solutions to help manufacturers and suppliers deliver safe and compliant products to their target markets. Learn more about SGS’s Hand Sanitizer and Disinfectant Services. [www.sgs.co.uk/en-gb/consumer-goods-retail/cosmetics-personal-care-and-household/hand-sanitizers-and-disinfectants]
SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full EU Commission Publishes Borderline Working Document on Leave-On Hand Gels SafeGuardS. [www.sgs.com/en/news/2020/12/safeguards-18620-eu-commission-publishes-borderline-working-document-on-leave-on-hand-gels]
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For further information contact:
Queenie Ho-yan TSE
Assistant Technical Service Manager
Tel: +852 2765 3672
Email: [email protected]
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