Recently the EU parliament published amendments to the labelling of fragrance allergens in cosmetic products, expanding from the current 24 fragrance allergens to an additional 56 identified fragrance allergens.
This is important as Health Canada, under their Canada Gazette Part I posting from February 11, 2023, proposes to incorporate by reference (IBR), Annex III of the EU Cosmetics Regulations of which we have concerns with and do not support his proposal as under these circumstances, such incorporation would pre-empt and/or circumvent critical due regulatory and scientific processes.
We are aware the CHPSD (Consumer and Health Products Safety Directorate) is contemplating alternative options to Incorporation By Reference (IBR), but IBR is not yet off the table as an option, yet this will highlight that, if this is the approach CHPSD wishes to take this is a significant development given the 3 to 5-year transition timeline in the EU which we would look to preserve if CHPSD proceeds with expanding the list via IBR.
Additionally, the EU publication reports these as fragrance allergens as opposed to contact allergens, highlighting why IBR is not a viable option as this undermines our engagement from the Canadian perspective where the enabling of Canadian engagement using appropriate scientific-based delineation efforts are what we are seeking to preserve.
