Cosmetic Packaging

In the European Union, the contents of cosmetics are regulated by the Cosmetics Regulation (EC) No 1223/2009, which provides the following legal requirements which must be met by the company placing the cosmetic product on the market:

  • review cosmetic ingredients and only use compliant ingredients,
  • manufacture cosmetics in accordance with GMP,
  • perform product safety assessments,
  • prepare a compliant product label,
  • prepare and maintain a product information file.

However, there is scarce detail on the requirements for the cosmetics packaging. There are only general guidelines:

  • the packaging must not contain any of the substances expressly not allowed in the Cosmetics Regulation
  • the packaging should be in line with the general safety requirement of Article 3 for the cosmetic product
  • the packaging should be safe for human health when used under normal or reasonably foreseeable conditions.

The very useful guideline for safety assessment of cosmetic packaging is an advisory document developed by Cosmetic Europe: INFORMATION EXCHANGE ON COSMETIC PACKAGING MATERIALS ALONG THE VALUE CHAIN IN THE CONTEXT OF THE EU COSMETICS REGULATION EC 1223/2009,  13 June 2019:

“Regarding a potential impact of the packaging on the safety of the cosmetic product, the main concern lies with the potential migration of substances from the packaging into the cosmetic formulation. Depending on the material combination used, such migration may be unavoidable – and indeed, the Cosmetics Regulation acknowledges in Article 17 that: “The non-intended presence of a small quantity of a prohibited substance, stemming from … migration from packaging, which is technically unavoidable in good manufacturing practice, shall be permitted provided that such presence is in conformity with Article 3” (i.e. the requirement for products to be safe). It is therefore important that the cosmetic product safety assessor receives relevant information on the composition and migration behavior of the packaging material in order to be aware if any significant migration occurs and assess whether it would impact the cosmetic formulation safety.

For the following reasons, the information generated under food packaging legislation can in principle also be used for the safety assessment of packaging used for cosmetic products:

  • physicochemical similarities between many cosmetic formulations and typical food materials
  • manufacturing standards based on Good Manufacturing Practices
  • safety assessment of the food packaging based on its composition and potential migration of substances into the food
  • similar worst-case ratio of packaging surface to packaging content between food and cosmetics

The Food Contact supply chain has developed a practical approach based on existing legislation which can be adapted for Cosmetic Packaging. The principle has been adopted that, in the majority of cases, if the packaging is safe for a specific type of food, it should also be suitable for cosmetics that have similar physical chemical properties as this food”.

For each component where this is possible, the supplier should therefore state and prove:

  • compliance with the general requirements of EU Framework Regulation (EC) No 1935/2004 on food contact materials,
  • compliance with the Good Manufacturing Practices (GMP Regulation (EC) No 2023/2006),
  • compliance with requirements of EU or national legislation that are applicable for the specific type of food material,
  • the types of food (food simulants) for which this statement of compliance is valid. This allows the cosmetic product safety assessor to determine whether the information on food packaging safety is relevant for his specific cosmetic formulation.

To help our customers comply with the above rules – and to make sure their products and packaging are safe to the consumer, our laboratories at J.S. Hamilton offer a range of testing services for cosmetic packaging:

  • overall and specific migration into all food simulants
  • specific migration of:
    • Primary Aromatic Amines (PAAs) and Annex II Metals,
    • plasticizers, antioxidants, monomers and other additives,
    • Non-Intentionally Added Substances (NIAS) Screenings by methods: GC-MS/FID, LC-QToF-MS, Hedsapace-GC/MS,
    • bisphenols A, B, S, F and epoxy resin derivatives BADGE, BFDGE and NOGE in coated materials, plastics and adhesives,
    • mineral oils (MOSH/POSH & MOAH),
  • sensory analysis acc. DIN 10955, EN 1230-1/-2
  • colorfastness acc. EN 646, DIN 53160-1 / -2
  • barrier properties against gases: oxygen (OTR), water (VWTR), CO2

Contact our specialists today if you want to schedule testing or organize a sales meeting.

Trainings

ABOUT TRAINING COURSES

J.S. Hamilton Poland conducts prestigious seminars, trainings, workshops and laboratory classes aimed at the food, cosmetics and household chemistry, packaging and environmental protection sectors. The participants of training courses can be: technologists, quality and laboratory workers, production department employees, personnel responsible for quality and product safety, managers and employees of legal or marketing departments. Everyone can raise their professional competence, improve work efficiency and better prepare themselves to carry out their professional tasks at a relatively low cost of training. J.S. Hamilton Poland is registered in the Register of Training Institutions (RIS) and the Database of Development Services – PARP, which allows the participants of our training courses to obtain co-financing of training from public funds.

Moreover, the competence of the trainers and the quality of the trainings conducted have been confirmed by the ISO 9001: 2015-10 Certificate in the scope of training and development and consulting services.

AREAS OF TRAINING

Our offer includes training in areas such as:

  • Food safety and quality, including training courses and workshops covering: sensory evaluation, microbiological testing, allergen and GMO analysis, food safety management systems, HACCP, ISO 22000, FSSC, BRC and IFS systems for retail chains, commodity and food quality training;
  • feed safety, the implementation of HACCP procedures, the GMP+ system, the legal aspects of trade in feed and provisions relating to its labeling;
  • Packaging, including: training on BRC food packaging safety, global and specific migration, eco-design, life cycle and packaging recycling;
  • Cosmetics, including: training and workshops on sensory and microbiological analysis of cosmetics, legal requirements for safe use and labeling of cosmetic preparations;
  • Environmental protection, including: training and workshops on sewage sludge management, packaging waste management, municipal tasks in the field of environmental protection, charges for using the environment;
  • Chemicals and petroleum products, including: training in liquid fuel sampling light fuel oil sampling, test methods for fuel oil and liquid fuels, quantity accounting for fuel oil.

TRAINING STAFF

Training courses are conducted by lecturers drawn from our own staff, using their extensive knowledge and experience. We also invite experts and auditors of leading certification companies, employees of consulting companies from Poland and abroad to give lectures.

The mission of our company is to take care of the welfare of our customers by satisfying the educational needs of the participants of our seminars and training courses and by organising training courses at the highest level.

TRAINING PACKAGES

We offer training packages, covered by a special discount, which will allow you to obtain the necessary knowledge in a given subject. After each training included in the package you receive a certificate confirming your participation in the training, and completion of the whole package guarantees obtaining a specialist certificate.

CLOSED TRAINING

In order to meet the expectations of our clients, we organise training adapted to the needs and specificity of the company. Each training included in the training schedule can be realised as a closed training on customer’s request. This also applies to training courses which are not listed in the training schedule.

Training courses and workshops are organised at a time and location determined by the client. Programs are usually priced according to the number of days and the number of participants so that the company can save considerable sums of money in the case of larger groups and reduce travel and accommodation costs by organising the training at its own premises. Each participant receives training materials. The training ends with a certificate or attestation confirming the highest quality of training.

QUALITY AND FOOD SAFETY MANAGEMENT ACADEMY J.S.HAMILTON POLAND

The Training and Audit Department of J.S. Hamilton Poland also invites for a cycle of training courses, which in a comprehensive way prepares present and future employees of quality departments of food industry companies for the role of managers responsible for the development, implementation and improvement of food and packaging safety and quality management systems.

In one semester (165 hours), students of the Academy acquire knowledge in the areas of food contaminants, sensory analysis, packaging regulations, quality management system requirements and food safety. Our lecturers, experienced auditors and managers of quality departments in food industry companies, share their practical knowledge with the students on how to carry out and document audits and interpret legal provisions.