Authorities’ inspections – what do they check

Authorities’ inspections – what do they check, Gerd Mildau, Cosmetics Expert, CVUA, Germany

The 3 pillars of cosmetics surveillance in Germany are check of GMP, analysis and assessment of the products on the market, Check of product information file (safety report, claims, nano, serious undesirable effects). The numerous competent authorities and the cosmetics experts at CVUA Karlsruhe as official laboratory work closely together. Every year a lot of different projects are planned risk-orientatedly. It is very important that the analytical methods are validated and that the planning strategy is in compliance with the capacities of the inspectors, technicians and instruments in the course of the year. Actual market surveillance studies were Nitrosamines in nail polish, Caffeine in skin care products, fragrance allergens in perfumes, 1.4-Dioxane in showergels, Corticosteroids in skin care products, phthalates in perfumes, in vitro SPF in sun screens, heavy metals in decorative cosmetics & tattoo inks, MI/MCI in leave on products, glyoxylic acid/formic acid in hair straightening products, Hydrogen peroxide in tooth bleaching, pigments in lip sticks, microbiological status (pathogenic germs), kojic acid/mercury/Hydroquinone in bleaching creams. The results of those projects are discussed in the light of different judgement
  • -          article 3 CPR, i.e. not safe respective serious Risk=RAPEX-case)
  • -          article 14 CPR, i.e. banned or not permitted for the intended use
Furthermore check of product information files at manufacturers (responsible persons) is done continuously, e.g. for nanomaterials used as raw materials in cosmetics.

Finally GMP-checks at manufacturers are discussed.