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VOCs, CBD, 1,4-dioxane, talc, inclusion, transparency, PFAs in cosmetics, formaldehyde, allergens and elements of the Safe Cosmetics Act are among the top current areas of focus for the Personal Care Products Council (PCPC) and the U.S. Food and Drug Administration’s (FDA’s) Center for Food Safety and Applied Nutrition (CFSAN). During the session, Tom Myers, executive vice president of legal and general counsel for the PCPC, emphasized the many challenges the personal care industry is facing.
Also, Myers described current initiatives including collaborations with the California Air Resources Board (CARB) to set emission level standards for products such as dry shampoos, fragrance and other sprays—which, for some companies, means reformulation.
In addition, listing of both cannabis (marijuana) smoke and delta-9-tetrahydrocannabinol (THC) as reproductive toxins requiring warning labels. “Cannabis smoke is not a concern to cosmetics,” he said, “but THC is, as it [may be present in] CBD, which is a potential ingredient for use in cosmetics.”
On the East Coast, Myers emphasized limits set by the state of New York for 1,4-dioxane levels due to concerns over human health and its persistence in the environment. On the environmental front, Myers see the next big area of concern being plastics and packaging.
PCPC/FDA Briefing: VOCs, CBD, PFAs, Talc and the Safe Cosmetics Act
VOCs, CBD, 1,4-dioxane, talc, inclusion, transparency, PFAs in cosmetics, formaldehyde, allergens and elements of the Safe Cosmetics Act are among the top current areas of focus for the Personal Care Products Council (PCPC) and the U.S. Food and Drug Administration’s (FDA’s) Center for Food Safety and Applied Nutrition (CFSAN).
Finally, Mayne outlined elements and challenges posed by the currently proposed Safe Cosmetics Modernization Act. The primary elements include:
Mandating the registration and listing of products and ingredients;
Giving explicit authority to establish GMPs by regulation;
Mandating serious adverse event reporting;
Mandating access to records including consumer complaints during routine or for-cause inspections;
Requiring the disclosure of known cosmetic allergens on product labels;
Requiring ingredient reviews; and
Requiring sufficient resources to implement these protections.
The challenges currently faced include the FDA’s limited legal authority, competing agency priorities, and the significant changes occurring over the past 15 or more years. Regarding the latter, Mayne points to companies manufacturing more globally; utilizing animal alternatives for testing; and developing increasingly sophisticated ingredients with the potential to cause structure and function effects in the body (i.e., nanotech, “active” ingredients, microbiome and probiotic products, CBD, etc.).
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