Single-use plastics, do the changes of the new regulation affect cosmetic products?

03/02/2021

The Single-Use Plastic Directive (EU) 2019/904 was published in June 2019. The new law, known also as the single-use plastics (SUP) Directive, aims to prevent and reduce the impact of certain plastic products on the environment, in particular the aquatic environment, and on human health.

When a Directive is published, Member States of the European Union must apply these measures at their own regulations no later than 2 years after the entry into force of the Directive (i.e. by July 2021).

This Directive will impact:

Plastic food-contact materials and articles through (among others).
A ban on certain single-use plastics.

What measures will it involve?

New marking requirements will be introduced.
The collection goals for plastic packaging will be increased.
The extended producer responsibility scheme will grow.
And the design requirements for beverage containers will be increased.

So, recently, it was published the new European Regulation No. 2020/2151 about laying down rules on harmonized marking specifications on single-use plastic products listed in Part D of the Annex to Directive (EU) 2019/904 of the European Parliament and of the Council on the reduction of the impact of certain plastic products on the environment, and it shall apply from 3rd July 2021.

Harmonised marking specifications (and illustrations of the labels) are included for different types of products, as wet wipes; tobacco products, beverage cups; and sanitary towels (pads), tampons, and tampon applicators. Today we will describe the requirements for cosmetic wet wipes.

What requirements will wet wipes have, for example?

Wet wipes, i.e. pre-moistened wipes for personal hygiene and for domestic use. In addition to this type of products, we should take into account “Sheet Masks”·or “Patch”, that is, for masks or patches made for physical support of a liquid product, whether facial, for the contour of the eyes, hands, feet, etc., since we could say that they are wet wipes, although these products are not specified as such in part D of the annex to Directive (EU) 2019/904.

Special attention must be paid since in many cases the composition of these “sheet masks” are 100% cellulose, but sometimes they may contain a small plastic percentage (binder), even if it is very small. In this case, it would also apply to them.

The products will bear the marking and Harmonised marking specifications for wet wipes which are specified in Annex II of Regulation No. 2020/2151.

It applies to packaging of wet wipes with the surface area of 10 cm2 or more. It does not apply to packaging with the surface is less than 10 cm2.

POSITION: The marking shall be placed horizontally on the external front or top surface, whichever is more clearly visible, of the packaging. The boxes of the marking shall not be separated. When opening the packaging in accordance with any instructions, the marking should not be torn or made illegible.

SIZE: The marking will cover at least 6 % of the surface area on which it is placed, with a maximum required size shall be 3 cm by 6 cm (18 cm2). Where the area of the external front or top surface of the packaging on which the marking is placed is less than 65 cm2, the minimum size of the marking shall be 1,4 cm by 2,8 cm (3,92 cm2).

DESIGN: The marking shall be composed of two equal-sized red and blue boxes, and a rectangular black box containing the information text ‘PLASTIC IN PRODUCT’ placed below the two equal-sized boxes. The ratio between the height and length of the marking shall be 1:2.

The design of the marking shall be reproduced without adding any effects, adjusting the colors, retouching, or extending the background. The marking shall be bordered by a thin white line.

The information text ‘PLASTIC IN PRODUCT’ shall be in upper case and in Helvetica Bold font. The font size shall be a minimum of 5 pt and a maximum of 14 pt.

The text written at the marking will be written in the official languages where the product will be sold. Where the information text is translated into another or several official languages of the Member States, the translated information text shall be placed either close below the marking, or inside the rectangular black box below the first language, and shall be in both cases clearly visible.

In exceptional cases due to spatial constraints on the external front or top surface of the packaging, the information text translated into another or several official languages of the Member States may be placed elsewhere on the packaging as close as possible to the marking.

Therefore, this marking has to be visible, clearly legible, and indelible and must be placed on the sales container and grouped packaging of these products, that is, in the sales unit of the product.

In addition, by way of derogation from the first sentence of this point, the marking of the packaging of wet wipes placed on the market before 4th July 2022 may be affixed by means of stickers.

From Cosmeservice, we recommend you start the process as soon as possible to avoid any risk. We would like to offer all our assistance in order to update concerned references to comply with the EU Regulation and they would be marketed successfully.