A personalised cosmetic, as it can be guessed by the name, is a cosmetic created solely and exclusively for a specific consumer, based on their needs and tastes.
This technique of making cosmetic products “to the consumer’s taste” began with the development of fragrances, where each user could choose the scent notes they wanted to arrive at their perfect fragrance. Now, this trend is finding its way into the field of make-up and skin care cosmetics.
But speaking of legislation, what do we need to know?
The first thing we need to find out is whether we are really dealing with cosmetic product, because depending on the casuistry in which the personalised product is found, we can say that it is a personalised cosmetic product or not.
Therefore, we are going to look at the different cases we face when we talk about personalised product:
- Kits with components that are mixed with specific instructions.
- Kits of substances and mixtures, without liking them to specific instructions on how to get to the final cosmetic product and, moreover, the components are not cosmetic products by themselves.
Kits with components that are mixed according to specific instructions
These kits are made up of products that on their own can be considered cosmetic, but by mixing them following the specific instructions provided by the manufacturer, we will obtain more personalised cosmetic product, which will have a synergistic and increased effect on the routine we want to emphasise. For example: a base cream to which a specific depigmenting serum is added for blemished skin.
This means that we are dealing with a cosmetic product and the general Cosmetic Regulation applies to it as to any other cosmetic product on the market. In other words, the applicable regulation would be Regulation (EU) No. 1223/2009 on cosmetic products.
Kits of substances and mixtures, without linking them to specific instructions
These kits, as indicated in the name, do not have specific mixing instructions to obtain the finished cosmetic product. However, neither can the substances included be considered as final cosmetic product on their own.
Therefore, on this occasion we are dealing with a product that cannot be considered as a cosmetic product and which the Cosmetic Regulation cannot be applied, but CLP applies to all the components, that is, SDSs would be required for all the substances a mixtures that make up the kit.
In short, if you have doubts about whether your personalised product complies with the definition of cosmetic according to Regulation (EU) No. 1223/2009; or, if you already have the answer and want to market it in Europe, do not hesitate to contact us, we will go hand in hand with you throughout the process.