NEWSLETTER

Brazil's Ban on Animal Testing, Updates on REACH Document Codes, and Expert Reviews on Propolis Extract

Ed-Alun Jones

Brazil Prohibits Animal Testing

Brazil's National Council for the Control of Animal Experimentation has announced measures prohibiting animal testing for cosmetic products. The measure encourages Brazilian cosmetic manufacturers or those importing cosmetics into Brazil to adopt alternative methods.

The Humane Society International which helped push the bill through in Brazil states the measure is only a partial ban:

"This new Brazilian norm is a welcome next step in the right direction and something for which we have long advocated. However, a domestic testing ban on its own will not prevent the import and sale of newly animal-tested cosmetics from other countries. This will put our personal care industry at a competitive disadvantage and fall short of the cruelty-free beauty sector that Brazilian consumers have made clear that they want. For this reason, our work to secure a federal law must continue.. "

Animal testing on cosmetics is currently banned in the EU and several states across the US. It is worth noting animal testing is a requirement for certain cosmetic products placed on the Chinese market.

New REACH Document Codes

Custom officials have begun to ask for evidence of REACH compliance for EU imports. The ECHA has issued updates to the document coding system, a summary of which is provided below.

Document code	Import/Export/Both	Description and Usage of Code	Details to be entered on the declaration Y106	Import	Compliance with the REACH restrictions defined in Column 2 of Annex XVII of Regulation (EC) No 1907/2006	 Complete statement “REACH Compliant”. Use of this document code constitutes a legal declaration of compliance with the REACH restrictions defined in Column 2 of Annex XVII of Regulation (EC) No 1907/2006.    Sufficient evidence must be held in records to demonstrate eligibility for this exemption and must be produced on demand.  Y110	Import	Exemption from REACH restrictions by virtue of Article 67(1) and 67(2) of Regulation (EC) No 1907/2006	Complete statement “Reg. 1907/2006 Exempt”. Use of this code constitutes a legal declaration that the goods are covered by the exemptions in Article 67(1) and 67(2) of Regulation (EU) No 1907/2006. Sufficient evidence must be held in records to demonstrate eligibility for this exemption and must be produced on demand. Y113	Import	Product not subjected to the provisions of Regulation (EC) No 1907/2006	Complete statement “Reg. 1907/2006 Exempt”. Use of this code constitutes a legal declaration that the goods are exempt from the provisions of Regulation (EU) No 1907/2006. Sufficient evidence must be held in records to demonstrate eligibility for this exemption and must be produced on demand.

CIR Expert Panel Reviews Propolis Extract

The Cosmetic Ingredient Reviews independent expert panel has finalised the assessment of seven ingredients, advanced two tentative safety assessments and issued three insufficient data announcements.

The CIR issued the following final safety assessments:

  • Basic Yellow 87: Safe for use as a hair dye
  • Mallow: Safe with qualifications
  • Naturally-sourced Clays: Split (1 safe and 7 mixed safe/insufficient)
  • Octyldodecyl Stearoyl Stearate: Safe with qualifications
  • Polyhydroxystearic Acid: Safe
  • Rosa centifolia: Split (9 safe with qualifications and 3 insufficient)
  • Trisodium Ethylenediamine Disuccinate: Safe

The two tentative safety reports address 5-Amino-4-Chloro-o-Cresol

and Hyaluronates and include discussions on the toxicological profile of each chemical and a conclusive statement on their safe use.

The panel announced insufficient data announcements on the following substances:

  • 5-Amino-4-Chloro-o-Cresol
  • Basic Blue 99
  • Phenyl-Substituted Methicones

Insufficient data announcements are an opportunity for interested persons to comment or provide information before the panel as to the safety of the substance in cosmetic products. Any information relating to the substances above should be submitted to the CIR no later than May 9 2023 for full consideration.

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