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Directorate-General for Health and Food Safety
Terms of Reference
1. The Scientific Committee on Cosmetics and Non-Food Products evaluates the safety of hair dyes on the basis of dossiers submitted by the cosmetics industry. The long-term goal is to ensure the safety of all currently marketed hair dyes. Currently, many of the hair dyes that have been evaluated by the SCCNFP are listed in Annex II of Directive 76/768/EEC, "List of substances which must not form part of the composition of cosmetic products," or in Annex III, "List of substances which cosmetic products must not contain except subject to restrictions and conditions laid down."
2. An issue of a linguistic nature has recently come to the attention of the Commission which has led to serious consequences in the transposition of various technical adaptations of the Cosmetics Directive 76/768/EEC. In English, the working language of the SCCNFP, the term hair dyes can be used to refer to the dyeing of hair anywhere on the body. This is certainly the approach that has been taken by English-speaking Member States such as the UK and Ireland.
However, in languages such as French and Spanish, hair dyes has been translated and transposed at national level as relating only to the dyeing of the hair on the head (cheveux or cabellos respectively). Bodily hair (eyebrows and lashes, facial hair on the upper lip, hair on the arms or in the genital area) are described using different terms (poil and pelos) and are not referred to in national texts.
Mandate
The SCCNFP has been asked whether its opinions on the safety of hair dyes, and the resulting legislative measures, relate to the use of such materials on the head or on hair found elsewhere on the body
Opinion
The Scientific Committee on Cosmetic Products and Non-Food Products intended for Consumers states that reference to hair dyes within its opinions relates to the use of such products on hair over the entire body, unless otherwise indicated.
The rationale for this statement is :
- Article 1 of the Cosmetics Directive 76/768/EEC states that "a cosmetic product shall mean any substance or preparation intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips and external genital organs) …".
The reference to hair system indicates that application to all bodily hair is considered, rather than a specific bodily area;
- In several opinions on hair dyes mandatory warnings such as "do not use to dye eyelashes or eyebrows," are given, such as with phenylenediamines or for the bleaching agents hydrogen peroxide and hydroquinone. The presence of such warnings indicates that the materials can be used on all bodily hair, as directed by the manufacturer, unless otherwise indicated through a specific warning.
- The increased (incidental) absorption of materials over mucous membranes through
use on the upper lip or the genital area is unlikely to be significant due to the low concentrations and short exposure times involved, this would also be true for any potential impact on mucous membrane irritation or corrosion.
- From a toxicological view, the increased total systemic exposure to a hair dye through its use to dye small, specific areas of bodily hair is unlikely to impact a favourable exposure and safety assessment on the use of products on the head, due to the low quantities of the material used and the sporadic exposures.
1. The Scientific Committee on Cosmetics and Non-Food Products evaluates the safety of hair dyes on the basis of dossiers submitted by the cosmetics industry. The long-term goal is to ensure the safety of all currently marketed hair dyes. Currently, many of the hair dyes that have been evaluated by the SCCNFP are listed in Annex II of Directive 76/768/EEC, "List of substances which must not form part of the composition of cosmetic products," or in Annex III, "List of substances which cosmetic products must not contain except subject to restrictions and conditions laid down."
2. An issue of a linguistic nature has recently come to the attention of the Commission which has led to serious consequences in the transposition of various technical adaptations of the Cosmetics Directive 76/768/EEC. In English, the working language of the SCCNFP, the term hair dyes can be used to refer to the dyeing of hair anywhere on the body. This is certainly the approach that has been taken by English-speaking Member States such as the UK and Ireland.
However, in languages such as French and Spanish, hair dyes has been translated and transposed at national level as relating only to the dyeing of the hair on the head (cheveux or cabellos respectively). Bodily hair (eyebrows and lashes, facial hair on the upper lip, hair on the arms or in the genital area) are described using different terms (poil and pelos) and are not referred to in national texts.
Mandate
The SCCNFP has been asked whether its opinions on the safety of hair dyes, and the resulting legislative measures, relate to the use of such materials on the head or on hair found elsewhere on the body
Opinion
The Scientific Committee on Cosmetic Products and Non-Food Products intended for Consumers states that reference to hair dyes within its opinions relates to the use of such products on hair over the entire body, unless otherwise indicated.
The rationale for this statement is :
- Article 1 of the Cosmetics Directive 76/768/EEC states that "a cosmetic product shall mean any substance or preparation intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips and external genital organs) …".
The reference to hair system indicates that application to all bodily hair is considered, rather than a specific bodily area;
- In several opinions on hair dyes mandatory warnings such as "do not use to dye eyelashes or eyebrows," are given, such as with phenylenediamines or for the bleaching agents hydrogen peroxide and hydroquinone. The presence of such warnings indicates that the materials can be used on all bodily hair, as directed by the manufacturer, unless otherwise indicated through a specific warning.
- The increased (incidental) absorption of materials over mucous membranes through
use on the upper lip or the genital area is unlikely to be significant due to the low concentrations and short exposure times involved, this would also be true for any potential impact on mucous membrane irritation or corrosion.
- From a toxicological view, the increased total systemic exposure to a hair dye through its use to dye small, specific areas of bodily hair is unlikely to impact a favourable exposure and safety assessment on the use of products on the head, due to the low quantities of the material used and the sporadic exposures.
