The EU Commission has released technical guidance which provides a non-exhaustive list of product claims which would not support the classification of leave-on hydro alcoholic hand gels as cosmetic products due to perception.

SAFEGUARDS | Cosmetics, Personal Care & HouseholdNO. 186/20

 SG 18620 Hand Gell

The EU Commission has released a technical guidance document on leave on hand gels, which is to complement the latest borderline manual, and the Guidance on the applicable legislation for leave-on hand cleaners and hand disinfectants.

This supplementary technical guidance provides a non-exhaustive list of product claims which would not support the classification of leave-on hydro alcoholic hand gels as cosmetic products due to perception.

Labeling elements that would not support a main cosmetic function of leave-on hydro alcoholic hand gels (not to be used on cosmetic products)
Claims (and their variations):
  • Antibacterial, antimicrobial, antiviral, virucide, antifungal (and their attributes, such as ‘antiviral properties’, ‘antibacterial ingredients’, ‘inhibits bacterial growth’)
  • Disinfecting, disinfectant, disinfection, sanitizer, sanitizing
  • Antiseptic
  • Kills X% bacteria/viruses/microbes
  • Decontaminating
  • Formulation recommended by the World Health Organisation (WHO);
  • Anti-COVID-19, anti-coronavirus, anti-SARS
References or allusions to:
  • Infection, pandemic, diseases
  • COVID-19, coronavirus, SARS-CoV-2
  • Microorganisms, bacteria, viruses, pathogens, germs, fungi
  • Disinfection
  • Medical use
  • Percentage of alcohol in the product
  • Safe hands
Pictures or graphical elements of:
  • (Corona)virus, bacteria, microbes
  • (Red) cross (when suggesting a medical connotation)
  • Shield (when indicating protection against microorganisms);
  • STOP sign (when indicating preventing/controlling the spread of a disease or infection or microbes)
  • Any sign related to hospital, pharmacy, ambulance, first aid, etc.
  • CLP pictograms

References

[1] Borderline Working Document on leave on hand gels
[2] Borderline Manual September 2020
[3] Guidance on the applicable legislation for leave-on hand cleaners and hand disinfectants (gel, solution, etc.)

As the world’s leading provider of inspection, verification, testing and certification services, SGS offers in-depth expertise into the requirements governing hand sanitizers and disinfectants. This service is backed by a global network of highly experienced experts and state-of-the-art laboratories. In the end, it’s only trusted because it’s tested. Contact us for more information or visit our website.  

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t: +852 2765 3672

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