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Borderline products

Sometimes it may be unclear whether a particular product is a cosmetic product under cosmetics legislation or whether it falls under other sectorial legislation. In the case of these “borderline products”, the decision on a product’s classification must be taken on a case-by-case basis.

The European Commission has published guidance documents to facilitate the application of EU legislation in these cases. They include a “manual” on the application of Article 1 of the Cosmetics Directive, i.e. the definition of a “cosmetic product” (see below) and the various guidelines on the borderline between cosmetics legislation and other sectorial legislation.