In the UK, the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS) is acknowledged as the counterpart of EU's Scientific Committee on Consumer Safety (SCCS). It assesses the chemical and biological risks of non-food and non-medicinal consumer products, including cosmetic products and their ingredients, and offers scientific opinions to the Office for Product Safety and Standards (OPSS). Recently, SAG-CS has published two opinions on the use of Butylated Hydroxytoluene (BHT) and Kojic Acid in cosmetic products.1-2
On the other hand, in December 2021 and March 2022, SCCS released scientific opinions respectively on BHT and Kojic Acid. When comparing these opinions with those of SAG-CS, there are some differences. Specifically,
Concerning BHT, comparing with SCCS, SAG-CS takes additional measures by establishing individual safe concentration limits for topical leave-on oral care products, and does not consider this ingredient to show endocrine activity evidence based on the available data;
In terms of Kojic Acid, SAG-CS' opinion focuses on its use in face and hand creams, while the SCCS' opinion pertains to Kojic Acid as a skin lightening agent in cosmetic products. Besides, the SAG-CS' opinion concludes that Kojic Acid does not meet the criteria of an endocrine disrupting chemical in vivo according to the WHO/IPCS (2002) definition, taking into consideration the exposure levels experienced by the majority of the population through cosmetic use at the specified level.
A detailed comparison between the opinions of SAG-CS and SCCS can be found in the table below.
Ingredient | SAG-CS Opinions | SCCS Opinions |
BHT | a. BHT is safe for use at the following maximum concentrations: - 0.001% in mouthwash, and topical leave-on oral care products; - 0.1% in toothpaste; - 0.8% in hydroalcoholic-based fragrances (spray and non-spray), rinse-off skin and hair cleansing products, leave-on skin and hair products, and face make-up products. | a. Considering the concerns related to its potential endocrine disrupting properties, BHT is deemed safe when used at the following maximum concentrations: |
Kojic Acid | a. Kojic Acid is safe for use at a maximum concentration of 1% in face cream (including those for application to the neck) and hand cream. | Considering the concerns related to its potential endocrine disrupting properties, Kojic Acid is considered safe when used as a skin lightening agent in cosmetic products at concentrations of up to 1%. |


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