New entries on the Borderline Manual

Last month, the European Commission published an update to the Borderline Manual, carried out by the Working Group on Cosmetic Products.

The Borderline Manual is a tool that helps us determine if a product falls within the cosmetic regulation or within some other regulation.?

In this update, the following product types have been added:

• Section 3.5.8. - Glues/adhesives intended to fix articles like fake nails, false eyelashes, jewellery on teeth, etc.: The Borderline Manual mentions that, if the glue can change the appearance of nails, teeth or eyelashes by itself, it could be considered a cosmetic product. While if the glue only has the function of attaching an object to an external part of the body, it would not be considered a cosmetic product.
• Section 3.5.9. - Magnetic eyeliners (eyeliner applied on an eyelash line, which can also allow false lashes to be attached to the eyelid): A tinted magnetic eyeliner can meet the definition of a cosmetic product, as it can change the appearance of the external part of the skin where it is applied (main function), while the function of attaching a false eyelash can be considered a secondary function.

It is important to remember that this document is only a guide and is not legally binding.

?The decision whether to consider a product as a cosmetic must be made by the national competent authorities, after carrying out a case-by-case analysis and considering the definition of a cosmetic product mentioned in the EU Cosmetics Regulation 1223/2009.

?For more information, you can take a look at our blog article on Cosmetics Classification in Europe: Case Studies – Taobe Consulting.

By Maria Jose Coronado , Senior Safety Assessor.