The EU has a rather Byzantine way of regulating cosmetics. The rules are set by the European Commission in Brussels. This is run by the commissioners, of whom there are 28 one from each state. They have what strikes me as quite a modest sized staff and they don’t employ any scientists specifically to look at cosmetics and indeed don’t have a department that dedicated to the industry. So the regulations are drawn up by general bureaucrats.
They can change the rules if they are asked to by various interested parties, mainly EU governments. So the proposal comes in and the commission is charged with responding to it. In the case of an issue that needs some scientific evaluation the commission can ask a panel of scientific advisers to investigate. These are called the Scientific Committee on Consumer Safety and is composed of well respected academics. This isn’t their full time job, and I’m not sure whether or not they get paid directly from the Commission for their work. For particular issues they also co-opt experts in the field to help.
So the Commission asks them a specific question, or set of questions. They then come back with an opinion when they have mulled it over. They do this in great detail and publish a report of their conclusions along with all the data they have used to come to it. These reports are great for people like me who want to be up to date on safety issues but don’t have time to keep an eye on all the literature. They come with a comprehensive literature review along with the committee’s comments on the research. And they show all their working, so you know how the committee have assessed the work. So for example the recent one about retinol is 84 pages long and took me about 2 hours to read. But it would have taken weeks to get anywhere near the same depth on my own. So although the system is a bit confusing it certainly has some benefits.
Once the commission gets its opinion, it can then decide whether or not to adopt the opinion and how to go about doing so. Typically the opinions are acted on pretty much as originally written, usually with a reasonable length of time allowed before they come into force. Four years is typical. So basically when an opinion comes out you are pretty safe in assuming that you should follow it as soon as practical because the chances are you are going to have to in the reasonably near future.
Which brings me to the most recent opinion to come out. This is all about vitamin A and its derivatives. The one that matters to cosmetic scientists and consumers is retinol. The question is, does applying it contribute in a significant way to the amount of vitamin A in your body? This is important because while vitamin A is a necessary component of the diet, it is possible to have too much. If you really eat a lot it can damage your bones, but that is well beyond the levels that you might get from a skin cream. The risk that is actually of concern is that of causing damage to unborn children during pregnancy.
The approach the SCCS took was to look at what was recommended for food and to compare that with actual use levels of retinol in cosmetics. Its conclusion was that at the maximum levels of which they are aware there was no risk for anyone over the age of one. I don’t think that there are any anti-ageing products intended for children under the age of one, so that effectively means that they have given existing products the all clear. But given that there is currently no limit on the use level of retinol, I would conclude that the logical move for the commission would be to impose a limit based on the levels as assessed by the committee.
I’ll be making that assumption anyway.
I have left out all the numbers to make this post more readable, but if you are interested you can find them all here.
In the meantime retinol becomes the first vitamin I know of where you could say that it is possible to get a reasonable dose across the skin. I was asked about this some time ago. British Beauty Blogger wanted to know if she could get her vitamins in the bath – presumably so she can write even more blog posts. Sadly I had to say no. I still don’t think it’s practical, but I may have spoken too soon.