Introduction We hope that our readers have familiarized themselves with the basic requirements of the technical regulation for cosmetic products. Manufacturers should already clearly define the necessary steps for preparing for its entry into force. Most responsible people understand that there is a lot of work to be done.
The question arises:
"How to prove the safety of products before the introduction of the technical regulation?"
Reminder
Since October 1, 2023, the Law of Ukraine "On the System of Public Health" has entered into force, which repealed the validity of the Law of Ukraine "On Ensuring Sanitary and Epidemiological Welfare of the Population", which provided for the conduct of state sanitary and epidemiological expertise of products, so sanitary and hygienic conclusions / SES conclusions are not issued by the State Food and Consumer Service.
The Resolution of the Cabinet of Ministers No. 833 of 07/26/2022 on the approval of the Technical Regulation for Cosmetic Products (TRKP) comes into force only from August 3, 2024, therefore the principles of placing non-food products on the market in Ukraine and ensuring its safety are regulated by the laws of Ukraine "On the System of Public Health", "On the General Safety of Non-food Products", "On State Market Surveillance and Control of Non-food Products", state San-Pins on products.
In any case, the product must be safe, and the procedure for proving its safety is transferred to manufacturers, importers, and other market participants.
Key steps for preparing for the introduction of cosmetic regulation
Implementation of the GMP Management System (DSТУ EN ISO 22716:2015): Start developing and implementing a production management system that meets the requirements of the DSТУ EN ISO 22716:2015 standard "Cosmetics. Good Manufacturing Practice (GMP)".
Safety Assessment and Preparation of a Safety Report: Ensure that cosmetic products undergo tests to assess microbiological safety, tests for preservation and stability, and other indicators as needed. Its compliance with the new requirements and the possibility of preparing a safety report depends on this. Prepare for the preparation of a safety report by undergoing training from competent specialists who have already passed the procedures for preparing the report and notification in the EU.
Notification on the Electronic Portal of the Ministry of Health: From the moment the electronic portal of the Ministry of Health opens, notify (provide) information about your cosmetic products. This is a necessary condition for the legal production of products and their introduction into circulation.
Main documents proving the safety of products
Before the technical regulation comes into force, the main documents that can prove the safety and compliance of products with the requirements of the new legislation should be TU (for domestic manufacturers), test protocols, and a voluntary conformity certificate.
How to prove the compliance of products before the introduction of the cosmetic regulation?
Proving the safety of products will vary slightly for different types of manufacturers and will include the need:
Domestic Manufacturer in Ukraine and Foreign Manufacturer outside the EU:
Ensure that cosmetic products undergo laboratory safety assessment tests, which you can use in the future for safety assessment according to the requirements of the technical regulation;
undergo voluntary conformity assessment by obtaining a conformity certificate from an independent assessment body, based on TU (for a domestic manufacturer), marking, and test results.
Foreign Manufacturer from the EU:
Check and confirm the compliance of the product with European standards and provide appropriate documentation on safety assessment (the presence of the COSMETIC PRODUCT SAFETY REPORT-CPSR report and test results is required);
Undergo voluntary conformity assessment based on the assessment of marking, test results and/or CPSR safety report, obtaining a conformity certificate from an independent assessment body.
Obtaining a voluntary conformity certificate will confirm the safety of the product and will guarantee the safety of cosmetic products for the end consumer, and will allow you to quickly convince your customers that the product meets safety standards.
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