KFT Goes to Hollywood

People say that a picture says a thousand words. How much more do movies say? But how can a film cover the complex topic of regulatory chemical compliance? And how could anyone develop a meaningful plot based on it?

Regulatory chemical compliance appeals to our desire for safety and security, so it also deals with trust. Customers and users want trustworthiness and transparency. They want to be sure that a product actually contains what the label indicates and that the label indicates what a product actually contains– and they want to do both seamlessly. Those who take that to heart will have fans on their side. In short: Brands that want to be seen as likeable and reputable should at least do what the law requires.

But enough with the words: Let the pictures speak!

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Many Consumer Products with Child-Resistant Fastenings Violate CLP Requirements

The ECHA Forum, a body made up of CLP experts from various countries, has inspected a total of 797 products as part of a European-wide enforcement project. Every third product was not packaged or labeled according to the CLP requirements. This finding was presented to the ECHA in June.

The goods that were tested included consumer products like disinfectants, bleaching agents, and various types of cleansers. According to CLP, all the products are to have child-resistant fastenings and tactile warnings. The requirements for child-resistant fasteners was not met in 32 cases, classification and labeling in terms of child-resistant fasteners was inadequate in 66 cases, and tactile warnings were incorrect or missing completely for 77 products.

A total of 24 products had not been approved for the market, and an additional 24 had to be removed from the market. Many of the companies involved recalled their products voluntarily.

The authors demanded that national agencies explain the CLP requirements for child-resistant fasteners and tactile warnings to companies more clearly. For more information, see the report of   the ECHA.

In this context, we’d like to note our seminar on labeling hazardous goods according to chemical and transportation laws on October 13 and our presentation on the classification and labeling of substances and mixtures according to CLP on November 9–10 (both available in German only). Please contact us with any questions at mail@kft.de.

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EU Commission Approves Use of Titanium Dioxide as a UV Filter

The EU Commission has decided to approve the use of nanoform titanium dioxide in a concentration up to 25% weight by weight as a mineral UV filter in cosmetics. Annex VI of the Cosmetics Regulation (EC) No. 1223/2009 was amended accordingly; the new regulation takes effect on August 2.

The leaders of the Commission based their decision on a recommendation of the Scientific Committee for Consumer Safety (SCCS). However, titanium dioxide is not approved for use in sprays. Members of the SCCS states that more research is needed to determine if such use would enable nanoparticles to enter the lungs.

Do you have any questions about titanium dioxide and its permitted use in your products? Please contact us at cosmetic@kft.de.

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India Plans New Cosmetics Law

The Indian Government wants to draft a new drug and cosmetics law that better aligns its requirements with global standards for manufacturing and product safety. The specifics of the planned law are unknown.

The cosmetics industry in India likes the plan. The old law, passed in the 1940s, no longer meets current needs and allows too much room for interpretation, says Kajal Anand, president of the All India Cosmetics Manufacturers Association (AICMA).

According to the foreign trade agency Germany Trade & Invest (GTAI), India’s market for cosmetics shows strong growth. The perfume industry alone grew by an average of 20% between 2009 and 2014, and growth continues unabated.

Because of safety concerns, consumers keep a particularly critical eye on cosmetics. That’s why you should make sure that your products are safe. We therefore recommend our customer meeting on September 13 (German only) that will focus on the regulatory foundation of cosmetics marketing. If you have any questions about cosmetics, please contact us at cosmetic@kft.de.

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Brazil: Chemicals Law on the Way

The Brazilian Ministry of the Environment (Ministério do Meio Ambiente: MMA) has published the draft of a chemicals law. The draft is open to public consultation until the middle of August. Representatives of the National Commission on Chemical Safety (CONASQ) have drafted the document and will present the final version to the Congresso Nacional, which will mold the document into a law.

One feature of the proposed law is the creation of a national database for chemicals, much like the case in the European Union and Canada. The list should include chemicals that are manufactured in or imported into Brazil in a quantity of at least one ton per year. Lawmakers will require the companies specify the firm, the amount, the intended use, the CAS number, and the Globally Harmonized System (GHS) classification and labeling of the substance. The information must be submitted within three years after the law appears in the official gazette.

Furthermore, the proposed law would create two committees. The first would assess risks, select substances, and evaluate substances according to specific criteria, such as carcinogenic properties, persistence, hormonal activity, and human and environmental effects. The second would define prohibitions and limitations and decide on permissible quantities.

Brazil is Germany’s most important trade partner (in German) in Latin America. More than 1,300 German-Brazilian companies, 900 of them in Sao Paulo alone, employ about 250,000 people. However, the country is in the midst of a deep recession right now. Investments have decline for ten consecutive quarters.

KFT works with companies in Brazil and is thoroughly familiar with Regulatory Chemical Compliance. Please contact us at reach@kft.de.

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Food Contact Materials: EU Parliament Urgently Calls for Stronger Guidelines

The Environment, Public Health and Food Safety Committee (ENVI) of the European Parliament has demanded that the EU Commission develop new, EU-side guidelines for food contact materials (FCM). Such FCM include paper, cardboard, coating materials, printing inks, adhesives, plastics, rubber, and metal that are used to manufacture packaging, containers, cooking utensils, cutlery, and plates.

According to the Committee members, no uniform rules yet exist that forbid the use of carcinogenic, mutagenic, or reprotoxic materials or substances that are classified as substances of very high concern (SVHC) by REACH.

A current draft report by ENVI criticizes that Regulation (EC) No. 1935/2004 because it has so far covered only 4 (plastics, ceramics, regenerates cellulose, and active and intelligent packaging substances) of the 17 materials listed in the Annex. Individual EU countries have issued national regulations for individual materials in the meantime, but gaps and no EU-wide, mandatory solutions exist yet.

Along with this grievance, a current article in Regulatory Toxicology and Pharmacology serves as the basis for the committee to appeal to the EU Commission. The authors report on more than 6,000 substances that can be found in paper and cardboard. The ECHA lists 19 of them as an SVHC. It’s also notable that about 77% of the compounds have not been evaluated for toxicity or evaluated at all. The authors state that based on the physical and chemical properties of the substances, most of them are bioavailable, meaning that they can enter food through contact with it.

Ensure that your products do not harm human health in any way. If you have any questions about the laws involved, we are pleased to partner with you. Contact us at reach@kft.de.

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More Transparency Demanded for Cosmetics

Surveys shows that most women want to know what ingredients are in perfumes and other cosmetics so that they can avoid contact allergies. However, most packaging uses collective terms like “perfume”, “fragrance”, or “flavor”. These terms hide combinations of more than 100 different substances. Consumers cannot recognize if the product contains allergens.

Alexandra Scranton, the director of Women’s Voices for the Earth (WVE) reports on this situation in an essay for the online portal ChemicalWatch. She says what the majority of women are thinking. Three of every four mothers in the United States want safe products. They look at lists of ingredients closely to avoid any health risks that the family might face. Those figures come from a survey of 1,000 American mothers last year. Another survey came to similar conclusions. More than half of all women read labels in detail to avoid coming into contact with specific substances like sulfates, parabens, or Polyethylene glycols.

Good reasons exist for such careful reading. According to a report of the British Journal of Dermatology, about 40% of the 12,000 participants in 5 European countries have suffered from a contact allergy at some point in their life. They read product labels very carefully so that they can avoid fragrances.

According to the German Allergy and Asthma Association (Deutscher Allergie- und Asthmabund), almost every fifth person has had an allergic reaction to one of the most common contact allergens.
In its report (available in German only) on the current spread of allergies in Germany, the Robert Koch Institute warns of minimizing the harm of allergies. The institute even speaks of a widespread disease that affects the quality of life for many people and calls the “allergy problem in Germany a serious problem in our healthcare.”

Ensure the safety of your products at all times and make it a strong and trustworthy hallmark of your brand. We can help. Contact us at cosmetic@kft.de.

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TTIP: Organizations Pillory the EU Commission

In preparation for the 14th round of TTIP negotiations, more than 65 organizations have sent an open letter to Martin Schulz, the president of the European Parliament. The signatories include nongovernmental agencies like the Center for International Environmental Law (CIEL), ClientEarth, and the Health and Environment Alliance (HEAL). The letter criticizes the current practices of the EU Commission, which, the authors claim, does not follow the recommendations of the European Parliament when negotiating with representatives of the United States.

With its resolution, the European Parliament encourages the EU Commission not to negotiate certain topics, such as laws on chemicals, pesticides, and cosmetics, given the significant discrepancies that exist between the EU and the United States. The same request applies to planned laws that protect health and the environment.

As part of a compliance check, the signatories of the letter checked to see how well the EU Commission held to the resolution of the EU Parliament. The result? Representatives of the EU clearly include REACH and other laws in negotiations and keep the U.S. representatives in the loop regarding planned laws and other measures so that these representatives can influence the laws.

This situation is disturbing because the EU Commission thereby softens current EU standards (like threshold values for pesticide residue in foodstuffs) to remove commercial barriers.

Protect the marketability of your products. If you have any questions, please contact us at reach@kft.de.

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