Are leave-on cleaners considered cosmetics or biocidal products?
Depending on its allegations, the presence of an active substance or the product’s purpose, a hand cleaner may be considered as a biocidal product or a cosmetic product. Below, you will find the main differences and requirements which come from these categories.
If you put on the European market a leave-on hand cleaner, as a skin cleaner participating to the general hygiene of person, it will be considered a cosmetic product. As such, it will require the creation of a Product Information File and its notification on the CPNP (Cosmetic Product Notification Portal).
This product may switch to the biocides category for example if the allegations indicate disinfection purpose or a biocidal action: “Antibacterial”, “Effective against coronavirus”, etc. Indeed, this type of allegations clearly shows a disinfecting action for the skin and, therefore, a biocidal action. It would also be the case of a product containing an active substance and it is thus mainly destined to a biocidal use.
If the cleaner falls into the biocidal products category, it is regulated by the European regulation on biocidal products (EU n°528/2012). To be able to legally commercialise your product, you will need to comply with this regulation; meaning obtaining a marketing authorisation for the biocidal product, and even comply with some national requirements, if your product’s active substance is under examination.
Some derogations currently exist in several European countries to put hand sanitizers on the market. To know more about this topic, please sign up for our webinar.
What strategy should you adopt to commercialise your products?
In order to angle your leave-on cleaning product’s development as well as to ensure its compliance on the market, it is essential to determine beforehand which purpose you intend to give it. If you wish to clearly state your ambition to contribute to the fight against Covid-19 and participate to public health, it would be better to commercialise hand sanitizers which disinfect the skin and therefore actively tackle the Coronavirus. Otherwise, cosmetic leave-on hand cleaners continue to be useful outside of the pandemic context.
With the Covid-19 pandemic, the demand in sanitizing products is increasing everyday and we can forecast a similar tendency for the coming months, especially with the quarantines in several countries being slowly lifted. With a return to normal life, the necessity to wash one’s hands without access to water or classic soap will become ever more frequent.
Do not hesitate to contact EcoMundo’s expert on the subject. We guide companies wishing to participate in the fight against Covid-19, be it through the commercialisation of cosmetics (soaps, etc.), of biocidal products (hand sanitizers, disinfectants…) or even protective masks (surgical masks, FFP2 masks).
Wish to know more about biocidal products?
For more information, do not hesitate to contact Fang Zhou or one of our experts via our contact form, indicating the purpose of your inquiry.
