Skin Cosmetics with Specific Duration of Application Now Require Multiple Dermal Irritation Tests

Takehome:

• Skin Cosmetics claiming an exact duration of application (e.g masks, facial scrub) require multiple dermal irritation test.
• This update contrasts with the previous requirement to conduct a single acute dermal irritation test.
• Meanwhile, expert panels from the technical review committee also discussed and tentatively agreed on the implementation of a 24h ocular irritation test.

Although not officially released, the amendment of test items for cosmetics with exact leave-on and rinse-off time had been notified to all approved testing institutions in China. For these categories of cosmetics, there is a tendency to strengthen safety testing. It is noteworthy that two products of this kind have been rejected during technical review due to failure to comply with new multiple dermal irritation test requirements.

An expert panel also reached a tentative agreement to also require a 24h ocular irritation test. This amendment hasn't been made official yet which should allow testing institutes and enterprise to prepare for pending changes.

REACH24H Interpretation:

Although multiple dermal irritation tests are stricter, more costly and time consuming, data suggests that products undergoing these tests are more likely to pass technical review. Therefore, this new requirement won't impose a significant technical barrier to trade or impact market access.

For the 24h ocular irritation test, experts from REACH24H predict this test will have a greater impact on market access and products will have a greater potential to fail technical review. Based on this if the pass rate for cosmetics is unreasonably low, this requirement may be repealed or adjusted to reflect industry technical capacities and market demands.