Vastuskiri

Dear Maria

I understand the complicity of this question.

We had communication on this topic with the commission in 2016 and had a non official answer: It is a case-by-case decision whether or not a certain type of glue can be considered to be a cosmetic product, by assessing the characteristics and purpose of the product against the relevant criteria of the Cosmetics Regulation, i.e. whether the glue is a substance or mixture placed in contact with the external parts of the body or with the teeth with a view of exclusively or mainly changing the appearance of that part of the body. It is not excluded that in some cases specific glues can be considered as a cosmetic product, intended to be placed on the respective parts of the body with the sole purpose to change the appearance of those parts (as opposed to a universal glue in general), once another article is attached.

Also it was explained to us that if glue is named as eyelash glue or nail glue – then it could be a cosmetic product. If it is named simply as a glue, then it is not a cosmetic. Anyway it has to be assessed on the case-by case basis. The member states approach was different and for example in Finland according to our knowledge they consider eyelash glues and nail glues as a chemicals and require a CLP labelling on such kind of products.

Also if you look in CPNP there are a lot of CPNP notifications on eyelash- and nail- glues. So we are looking carefully on the presentation, composition and labelling of such kind of products and evaluate on case-by-case basis. And we accept the classification of such kind of eyelash- and nail- glues as a cosmetic products with appropriate CPNP notifications, CPSR etc., but do not object if additionally to cosmetic labelling on the product we see also CLP labelling elements as our neighbour countries consider this products as chemicals.

Hope it helps to get the understanding of our position.

Kind regards

Natali Promet

Chief specialist

Chemicals Safety Department

+372 794 3533

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Dear Sir/Madam,

I hope this email finds you well.

My name is Maria and I am contacting you on behalf of Obelis s.a., one of the largest European Responsible Person centres in Europe and co-founder member of ERPA, the European cosmetics Responsible Person Association.

According to the latest communication from the Manual of the Working Group on Cosmetic Products (Sub-group on borderline products) published on February 2024, it has been clarified that when a product is exclusively intended to glue an article to external parts of the body, it should not be classified as a cosmetic. Specifically, glue is to be considered a cosmetic only when its intended purpose is to ‘change the appearance’ through the addition of glitter and/or color, or when utilized as a mixture to fabricate artificial nails.

For this reason, kindly state your position on whether glue/adhesives for artificial nails and lashes should be considered cosmetics under Regulation 1223/2009/EC or if this product falls under the General Product Safety Directive (GPSD) as per Regulation 2001/95/EC. Please, explain the technical reasons underlying your choice for classifying this product.

Your input and clarification on this matter will help us understand the best procedure to follow.

Best regards,