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Alcohol hand rub- Cosmetic vs Biocides debunked

Updated: Sep 2, 2020

The outbreak of Covid -19 has brought up lots of confusions regarding the applicable regulation of hand sanitisers in the UK and Europe.

As the current provision for using duty free alcohol and tax-free PPE are coming to an end, it is important to get your product classification right.

An alcohol rub or hand gel can be considered as a biocidal product if the product makes biocidal claims i.e kills 99.9% of bacteria, antibacterial, anti-viral hand gel. The product is considered as a Product Type 1, Human hygiene biocidal product. Where the active is still under evaluation i.e Ethanol; the transitional measures apply in each of the EU member states.

An alcohol rub or hand gel can be considered as a cosmetic product in Europe if it does not make any biocidal claims. A cosmetic product safety report, Product information file, Responsible person (PR) and product registration (CPNP) are required to place a cosmetic product on the market as per the requirements of the EU Cosmetic Product Regulation.

You can also consider the primary function for the product to establish the applicable regulation.

The notification under the transitional requirements in the main EU states are straightforward and you can have your product registered in a short period of time with minimal cost.

Other issues to consider are to select the correct applicable testing requirements for the intended sector and bacteria, yeasts and virus type when choosing EN1276, EN1500, EN14476.

C4C Consultancy can provide safety assessments and regulatory compliance services for cosmetics and biocidal products. We can help to review your product and plan a compliance strategy for the UK and EU markets where you intend to distribute and sell.

contact C4C Consultancy

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