Watch-out database → Detailed ingredient information:

Cosmetics Borderline Manual Updates


”Cosmetic kits” and Dual function soap entries added + (clerical changes)

Restricted as per EC regulation 1223/2009?


Other observations

Date of update Deadline Content of update Reference Source Obelis articles
04/05/2020 N/A Massage products - intended to have an effect on muscles (relief, warming or cooling) not classified as cosmetics products. Nail products with cosmetic function may be considered as cosmetics if they do not “restore, correct or modify physiological functions[…] by exerting a pharmacological, immunological or metabolic action”. Pure essential oils for aromatherapy/to be inhaled or ingested not as cosmetics. If on contact with skin, with a cosmetic purpose, it may be covered by the Regulation.  Cosmetics Borderline Manual February 2020 Working Group on Cosmetic Products (Sub-group of Borderline Products) 24/03/2020 - The Cosmetics Borderline with 3 new entries
01/09/2020 N/A Cosmetic kits are defined as cosmetic products consisting of components to be mixed require some form of manipulation by the end-user. They are to be notified as multi-component cosmetic product Dual use soaps can fall under the Cosmetics Regulation, when the main claim is related to a cosmetic purpose. If a soap claims dual function as a cosmetic product and a detergent, provided it falls under the scope of both Regulations, it has to comply with both regimes.   Borderline Manual September 2020 update Working Group on Cosmetic Products (Sub-group of Borderline Products)