1. Discussion on Rinse-Off Cosmetics
EU Ecolabel
Discussion on Rinse-Off Cosmetics
Michele Galatola
Coordinator of the EU Ecolabel
European Commission / DG Environment – Circular economy and eco-innovation unit

2. Background Issue for discussion
Criterion 3 requirements on fragrances identified as of Sensitizers of Special concern by the SCCS
Background – requests and opinions expressed in EUEB Members
-have a criterion specific on fragrances
-check overlap of criterion 3c (hazardous substances) and restriction on substances meeting the classification requirements for: H317: May cause allergic skin reaction
- set specific requirements on fragrances identified as Sensitizers of Special Concern by the SCCS and set threshold limit 100ppm
(for 3 fragrances complete ban and for 17 threshold limit 100ppm)
Other suggested proposals: withdraw of derogation on fragrances on H412 and H413? Set a longer list of restricted fragrances (more than 20). Fragrance-free products.

3. Proposal
Criterion 3 - Excluded or limited substances and mixtures Specified excluded
ingoing substances and mixtures
(ix) The following fragrances and ingredients of fragrance mixtures hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC), Atranol and Chloroatranol shall not be present in the final product;
Assessment and verification: the applicant shall provide a signed declaration of compliance supported by declarations from manufacturers of mixtures, as appropriate, confirming that the listed substances and/or mixtures have not been included in the product.
In addition:
-Provide clarification in the manual on how criterion 3c can be implemented
-explore option of amendment if considered for necessary e.g. Maturity for further decisions on fragrances