The safety evaluation of cosmetics in Europe is based on the
evaluation of each individual ingredient. Article 3 of the European
Cosmetics Regulations specifies that a cosmetic product made
available on the market is to be safe for human health when used
normally or under reasonably foreseeable conditions. Cosmetics
products have rarely been associated with serious health hazards;
however, this does not mean that the use of cosmetics per se is
safe. Particular attention needs to be paid to long-term safety
aspects, since cosmetics products may be used extensively over a
large part of the human lifespan and sensitive groups of the population
such as children, old people, pregnant women, etc., may be
affected. Therefore, safety-in-use for cosmetics products has been
established in Europe by controlling the ingredients via their
chemical structures, toxicity profiles, and patterns of exposure.
The safety of those substances that cause some concern with
respect to human health (e.g., colourants, preservatives, UV-filters,
etc.) is evaluated at the Commission level by a scientific committee,
presently called the Scientific Committee on Consumer Safety (SCCS). The substances are detailed in the Annexes of Regulation
(EC) No. 1223/2009, which replaced the previous Directive from
11 July 2013 onwards (European Commission, 2009).
The SCCS was established in 2008 to substitute the former
Scientific Committee of Consumer Products (SCCP). Before 1997,
the recommendations proposed by the Scientific Committee on
Cosmetology at the Commission’s request were included in EC
Reports. Between 1997 and 2004, all Scientific Committee opinions
were published on the internet and can be accessed through the
Committee’s website. All SCCS opinions can easily be located
through the substance category of the ingredient involved and
the adoption date.
One of the responsibilities of the SCCS is to recommend guidelines
for the cosmetics and raw materials industries to develop
adequate studies for the safety evaluation of cosmetics. The SCCS
evaluates the dossiers submitted by industry through the Directorate
General of Health and Consumers (DG SANCO). The cosmetics
ingredients evaluated by the SCCS correspond to those in the
Annexes of the Regulations and to substances forbidden in Annex
II, restricted substances in Annex II, and colourants, preservatives
and UV-filters in Annexes IV, V and VI respectively.
Determination of the toxic potential of a cosmetics product is
based on a series of toxicity studies and forms part of the hazard
identification. Alternative methods, replacing animal testing, have been mandatory in Europe to evaluate cosmetics ingredients since
March 2013, according to a Commission Decision. However, at
present, the majority of toxicological tests still involve the use of
animals, as is also the case for other chemical substances. Traditionally,
toxicological data that are relevant to human health have
been obtained by studying the toxicological profiles on animals of
the substances under consideration, using the same exposure route
as that in humans (topical, oral or inhalation).
When a dossier containing information on a cosmetics product
is submitted to the SCCS for evaluation, the manufacturer should
provide the Commission with information on: acute toxicity (if
available); irritation and corrosivity to skin and eye; skin sensitisation;
dermal/percutaneous absorption; repeat dose toxicity;
mutagenicity/genotoxicity; carcinogenicity; reproductive toxicity;
toxicokinetics; photo-induced toxicity; and human data (SCCS/
1501/12).
One consideration before toxicological studies are accepted for
evaluation is whether the studies have been carried out according
to guidelines and following Good Laboratory Practice (GLP). In
some cases, this information is not present and the SCCS asks for
further information before making an opinion.
According to the Cosmetics Regulation (European Commission,
2009), it is prohibited in the EU to market cosmetics products
and their ingredients if they have been tested on animals for most
human health effects, including acute toxicity. This imposes on the
cosmetics industry the need for alternative approaches to the
safety testing of the ingredients of consumer products. After a
meeting of experts organised by the European Centre for the Validation
of Alternative Methods (ECVAM), the alternative methods
that existed at the time and had been applied to cosmetics were
reviewed (Adler et al., 2011; Hartung et al., 2011).
The 7th amendment to the EU Cosmetics Directive prohibits the
launching of animal-tested cosmetics on the European market after
2013. The European Commission invited stakeholders (industry,
non-governmental organisations, EU member states and the Commission’s
SCCS) to identify scientific experts in five areas of toxicological:
toxicokinetics, repeat dose toxicity, carcinogenicity, skin
sensitisation, and reproductive toxicity. The experts selected were
asked to analyse the status of and prospects for alternative methods,
and to provide a scientific estimate of the time necessary to
achieve full replacement of animal testing. In short, the experts
confirmed that it would take at least another 7–9 years for the
complete replacement of the current in vivo animal tests used
for the skin sensitisation safety assessment of cosmetics ingredients
for skin sensitisation. However, the experts were also of the
opinion that alternative methods may provide hazard information,
i.e., to differentiate between sensitisers and non-sensitisers, before
2017. This would, however, not provide complete information on
what safe exposure is, because the relative potency of a sensitiser
would still not be known. For toxicokinetics, the timeframe was
5–7 years to develop the models still lacking to predict lung
absorption and renal/biliary excretion; and even longer to integrate
the methods to fully replace animal toxicokinetic models.
For the systemic toxicological endpoints of repeat dose toxicity,
carcinogenicity and reproductive toxicity, the time necessary for
full replacement could not even be estimated (Adler et al., 2011).
CAAT-Europe assembled experts from Europe, America and Asia
to design a scientific roadmap for future risk assessment
approaches, considering that the animal use for cosmetics testing
for the European market has been banned. The key recommendations
proposed focused on improving existing methods, the combination
of hazard testing and toxicokinetics predictions and the
developing of integrated test strategies among others. Important
points are the data quality, and the scientific background of a test
method. Information from each test system should be mapped
along adverse outcome pathways (Leist et al., 2014).