Table 1 ECHA recommended actions for RC and simplified comparison with current status in the EU and in SA

Step 1: Understand the issue

Detailed knowledge about ingredients obtained by standard laboratory tests or computational models is needed for sound hazard and risk assessments.

(Eco-)toxicological data on ingredients are available to the producer, the Competent Authorities and the informed public. Producers test their products and consider them as safe. Various stakeholders have different interests.

Actions rely on the industry to adhere to self regulation.

Step 2: Determine communication needs

The public should be able to make informed choices. This implies the need for comprehensible RC mechanisms to consumers. RC should help to reduce the risk for man and/or environment to the unavoidable minimum.

Many substances are banned or restricted according to the Cosmetics Regulation.

Follows EU regulations.

Step 3: Implement RC

Legal regulations should lead to a high level of consumer safety and environmental protection.

The ingredients must be listed on the PCPs. 26 potential allergenic fragrances must be listed by name on the PCPs. PCPs need not be classified and labelled according to the CLP Regulation. No exposure estimation to humans is needed according to REACH. Safety evaluation is performed according to the Cosmetics Regulation.

Follows EU labeling.

Step 4: Evaluate and review

Authorities should enforce and control the implementation of legal instruments. They should control whether the intended goals of risk reduction were reached and evaluate consumer comprehension of risk information. If necessary, new ways of RC should be developed and implemented.

There are product spot checks by authorities, but the control of consumer comprehension and protection is not integral part of the official RC process for PCPs. Only some independent research groups conducted surveys. The environmental concentrations are reason for concern for some cosmetic ingredients. The numbers of patients with contact allergy and other negative health effects caused by ingredients of cosmetic ingredients are high.

Consumer comprehension of label information is not evaluated. There is no research on improving RC mechanisms for PCPs.