Reg. 1223/2009 elect the cosmetic packaging as "ingredient" since the Safety Assessor has to consider its features and, above all, the substances or impurities that it can give to the cosmetic product.
This new role strongly influences the choice of packaging for the cosmetic product, since an important (and critical) phase of technical information exchange between the packaging manufacturer / producer and the "Responsible Person / Safety Assessor" duo needs to be considered.
The Responsible Person must put this information at the disposal of the Safety Assessor, and the Safety Assessor himself (due to technical expertise) can and should be involved in this process. But sometimes it is very difficult to get the information they need because the world of materials (glass, metal, but mostly plastics) is governed by other regulations that do not help the exchange of information.
The packaging assessment method (and therefore what information is needed) is the subject of special attention and is cited in many European Guidelines, but a guideline for the exchange of information between the cosmetics company and the supplier / producer of packaging is under construction.
Until the publication of the future Guidelines it is very important to deepen all the technical and legislative aspects that affect the evaluation and the compliance of the packaging, and that can condition the choice, in addition to the previous criteria regarding the suitability and compatibility with the cosmetic formulation.