SCCS/1628/21
Scientific Committee on Consumer Safety
SCCS
THE SCCS NOTES OF GUIDANCE FOR THE TESTING OF
COSMETIC INGREDIENTS AND THEIR SAFETY
EVALUATION
11
TH
REVISION
The SCCS adopted this guidance document
at its plenary meeting on 30-31 March 2021
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ii
TABLE OF CONTENTS
ACKNOWLEDGMENTS ................................................................................................ 1
Main changes in 11th REVISION of the SCCS Notes of Guidance (NoG) ............................ 4
1. INTRODUCTION ................................................................................................... 5
2. THE SCIENTIFIC COMMITTEE ON CONSUMER SAFETY, SCCS..................................... 7
2-1 BACKGROUND ............................................................................................... 7
2-2 MANDATE ...................................................................................................... 7
2-3 RULES OF PROCEDURE ................................................................................... 7
2-4 OPINIONS ..................................................................................................... 7
2-4.1 The "Notes of Guidance" ............................................................................. 7
2-4.2 SCCS Cosmetic ingredient dossiers .............................................................. 8
2-4.3 Specific issues taken up in NoG ................................................................... 9
3. SAFETY EVALUATION OF COSMETIC INGREDIENTS ................................................ 10
3-1 SAFETY EVALUATION OF COSMETIC INGREDIENTS AS APPLIED BY THE SCCS ..... 10
3-2 CHEMICAL AND PHYSICAL SPECIFICATIONS OF COSMETIC INGREDIENTS .......... 13
3-2.1 Chemical identity ..................................................................................... 13
3-2.2 Physical form ........................................................................................... 14
3-2.3 Molecular weight ...................................................................................... 14
3-2.4 Identification and purity of the chemical and isomer composition ................... 14
3-2.5 Characterisation of the impurities or accompanying contaminants .................. 15
3-2.6 Relevant physicochemical specifications ...................................................... 15
3-2.7 Solubility ................................................................................................ 15
3-2.8 Partition coefficient (Log Pow) ................................................................... 16
3-2.9 Homogeneity and stability ......................................................................... 16
3-3 EXPOSURE ASSESSMENT .............................................................................. 17
3-3.1 Functions and uses of cosmetic ingredients ................................................. 17
3-3.2 Identification of relevant exposure scenarios ............................................... 17
3-3.3 Identification of the targeted dose for safety evaluation ................................ 17
3-3.4 External exposure .................................................................................... 18
3-3.4.1 Exposure models and tiered approach .................................................. 18
3-3.4.1.1 Dermal exposure models ................................................................. 19
3-3.4.1.2 Oral exposure models ...................................................................... 19
3-3.4.1.3 Inhalation exposure models ............................................................. 20
3-3.4.2 Model parameters .............................................................................. 23
3-3.4.2.1 Daily use amounts and retention factors ............................................ 23
3-3.4.2.2 Concentrations ............................................................................... 27
3-3.4.2.3 Parameters specific for inhalation exposure ........................................ 27
3-3.4.3 Aggregate exposure ........................................................................... 27
3-3.5 Internal Exposure .................................................................................... 29
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3-3.5.1 Toxicokinetics (ADME) ........................................................................ 29
3-3.5.1.1 Dermal/percutaneous absorption ...................................................... 30
3-3.5.1.2 Absorption after ingestion ................................................................ 33
3-3.5.1.3 Inhalation ...................................................................................... 33
3-3.5.2 Differences in metabolism for different routes ....................................... 34
3-3.5.2.1 Systemic metabolism ...................................................................... 34
3-3.5.2.2 Dermal metabolism ......................................................................... 35
3-3.5.2.3 Lung metabolism ............................................................................ 35
3-3.5.3 PBPK modelling ................................................................................. 36
3-3.5.4 Calculation of the systemic exposure dose (SED) ................................... 38
3-3.5.4.1 Calculation of the inhalation SED (SEDinh) ......................................... 39
3-3.5.5 Aggregation of the systemic dose ........................................................ 40
3-3.5.6 Human biomonitoring ......................................................................... 40
3-3.5.6.1 Definition ....................................................................................... 41
3-3.5.6.2 Fields of application ........................................................................ 41
3-4 RELEVANT TOXICOLOGICAL TOOLS FOR THE SAFETY EVALUATION OF COSMETIC
INGREDIENTS ...................................................................................................... 42
3-4.1 New Approach Methodology (NAM) and Next-Generation Risk Assessment
(NGRA) ............................................................................................................ 42
3-4.2 Adverse Outcome Pathway (AOP)............................................................... 44
3-4.3 In silico Assessment of Toxicological Hazard ................................................ 45
3-4.3.1 In silico Toxicity Models ...................................................................... 45
3-4.3.2 Read-across ...................................................................................... 46
3-4.4 Acute toxicity .......................................................................................... 47
3-4.4.1 Acute oral toxicity .............................................................................. 48
3-4.4.2 Acute dermal toxicity ......................................................................... 48
3-4.4.3 Acute inhalation toxicity ..................................................................... 49
3-4.5 Skin corrosion and skin irritation ................................................................ 49
3-4.5.1 Skin corrosion ................................................................................... 49
3-4.5.2 Skin irritation .................................................................................... 49
3-4.6 Serious eye damage and eye irritation ........................................................ 50
3-4.7 Skin sensitisation ..................................................................................... 52
3-4.7.1 Skin Sensitisation Quantitative risk assessment (QRA) ........................... 55
3-4.7.2 Next-Generation Risk Assessment Approach (NGRA) .............................. 56
3-4.8 Repeated dose toxicity.............................................................................. 57
3-4.8.1 The use of uncertainty factors (UFs) for extrapolation for study duration .. 58
3-4.8.2 Selection of PoD ................................................................................ 59
3-4.9 Reproductive toxicity ................................................................................ 59
3-4.10 Mutagenicity / Genotoxicity .................................................................... 60
3-4.10.1 Definitions ........................................................................................ 60
3-4.10.2 Mechanisms ...................................................................................... 61
3-4.11 Carcinogenicity ..................................................................................... 68
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3-4.12 Photo-induced toxicity ........................................................................... 70
3-4.12.1 Photo-irritation and photo-sensitisation ................................................ 70
3-4.12.2 Photomutagenicity / Photogenotoxicity ................................................. 71
3-4.13 Human data in hazard assessment .......................................................... 73
3-4.14 Other considerations ............................................................................. 73
3-5 GENERAL PRINCIPLES FOR THE CALCULATION OF THE MARGIN OF SAFETY AND
THRESHOLD OF TOXICOLOGICAL CONCERN ............................................................ 74
3-5.1 Calculation of the Margin of Safety of a cosmetic ingredient .......................... 74
3-5.1.1 The PoD value ................................................................................... 74
3-5.1.1.1 Determination of NOAEL .................................................................. 74
3-5.1.1.2 Determination of BMD ..................................................................... 75
3-5.1.1.3 Choice of models ............................................................................ 75
3-5.1.1.4 Adjustment factors to the PoD .......................................................... 76
3-5.1.2 The PoDsys value............................................................................... 76
3-5.1.3 MoS Analysis ..................................................................................... 76
3-5.2 The threshold of toxicological concern (TTC) ................................................ 78
3-5.2.1 General concept of TTC in risk assessment ............................................ 78
3-5.2.2 TTC approach for human health risk assessment of chemical substances and
cosmetic substances........................................................................................ 79
3-5.2.3 iTTC APPROACH ................................................................................. 81
3-6 SPECIAL CONSIDERATION FOR CERTAIN COSMETIC INGREDIENTS.................... 82
3-6.1 Multi-constituent natural ingredients .......................................................... 82
3-6.2 Identification of mineral, animal, botanical and biotechnological ingredients in a
cosmetic product ............................................................................................... 83
3-6.3 Animal-derived cosmetic substances .......................................................... 84
3-6.4 Sun protection substances ........................................................................ 85
3-6.5 Endocrine active substances (EAS) ............................................................. 85
3-6.5.1 Definitions ........................................................................................ 85
3-6.5.2 Identification of EDs and regulatory consequences ................................. 86
3-6.5.3 Stepwise approach for cosmetics and their ingredients ........................... 86
3-6.5.4 Cosmetic ingredients suspected to have ED properties ........................... 90
3-6.6 CMR Substances ...................................................................................... 91
3-6.7 Lifetime Cancer Risk (LCR) ........................................................................ 92
3-6.8 Nanomaterials ......................................................................................... 92
3-6.8.1 Definition of nanomaterial ................................................................... 92
3-6.8.2 Potential safety issues of nanomaterials ................................................ 93
3-6.8.3 Required information for nanomaterials ................................................ 95
3-6.9 Hair dyes and hair dye components ............................................................ 96
3-6.9.1 MoS calculations for hair dye formulations ............................................ 96
3-6.9.2 Assessment of oxidative hair dye substances and reaction products ......... 96
3-6.10 Cosmetic ingredients for baby and children products ................................. 97
3-6.10.1 Definitions ........................................................................................ 97
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3-6.10.2 Age-related susceptibilities/sensitivities ................................................ 98
3-6.10.2.1 Dermal exposure of the newborn and early infant ............................ 98
3-6.10.2.2 Cosmetic products used in the nappy area ..................................... 100
3-6.11 Substances with very low dermal absorption ........................................... 100
3-7 FURTHER REMARKS FOR APPLICANTS ............................................................ 100
4. REFERENCE LIST .............................................................................................. 102
APPENDIX 1: INFORMATION ON REGULATION (EC) No 1223/2009 AND THE SCCS ......... 145
APPENDIX 2: LISTS OF SUBSTANCES ....................................................................... 152
APPENDIX 3: STANDARD FORMAT OF THE OPINIONS ................................................. 155
APPENDIX 4: ANIMAL TESTING: INTERFACE BETWEEN REACH AND COSMETICS
REGULATIONS ....................................................................................................... 164
APPENDIX 5: CMR GUIDANCE ON SAFE USE OF CMR SUBSTANCES IN COSMETIC
PRODUCTS ............................................................................................................ 165
APPENDIX 6: REQUIREMENTS FOR THE CERTIFICATE OF ANALYSIS FOR A COSMETIC
INGREDIENT .......................................................................................................... 169
APPENDIX 7: DETAILED EXPOSURE DATA FOR COSMETIC PRODUCTS .......................... 170
APPENDIX 8: KEY CHARACTERISTICS OF CARCINOGENS ............................................ 172
APPENDIX 9: GUIDELINES ON MICROBIOLOGICAL QUALITY OF THE FINISHED COSMETIC
PRODUCT .............................................................................................................. 174
APPENDIX 10: FREE ACCESS TO IN SILICO MUTAGENICITY/GENOTOXICITY AND
CARCINOGENICITY DATABASES ............................................................................... 177
APPENDIX 11: INHALATION PARAMETERIZATION ....................................................... 178
APPENDIX 12: LIFETIME CANCER RISK (LCR) APPROACH ............................................ 179
APPENDIX 13: PoD USED FOR TTC DERIVATION ........................................................ 180
ABBREVIATIONS AND GLOSSARY OF TERMS ............................................................. 181
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Nam et ipsa scientia potestas est
For knowledge itself is power
Francis Bacon (1561 - 1626) Essays
The “Notes of Guidance for the Testing of Cosmetic Ingredients and Their Safety
Evaluation by the SCCS” is a document compiled by the members of the Scientific
Committee on Consumer Safety (SCCS, replacing the former SCCP, SCCNFP and SCC).
The document contains relevant information on the different aspects of testing and
safety evaluation of cosmetic substances in Europe. The emphasis of this guidance is on
cosmetic ingredients, although some guidance is also indirectly given for the safety
assessment of finished products. It is designed to provide guidance to public authorities
and to the cosmetic industry in order to improve harmonised compliance with the
current cosmetic EU legislation. An important development in recent years was the full
implementation of the cosmetic legislation, Regulation (EC) No 1223/2009, meaning
that the animal testing and marketing bans fully apply from 2013 onwards: no in vivo
testing of finished products after 11 March 2004; no in vivo testing for local toxicity after
11 March 2009 and no in vivo testing for repeated dose toxicity (including sensitisation)
toxicokinetics and developmental toxicity from 11 March 2013 onwards for the purpose
of cosmetics. For this reason, the SCCS has closely followed the progress made with
regard to the development and validation of alternative methods, with emphasis on
replacement methodology.
The "Notes of Guidance" are regularly revised and updated in order to incorporate the
progress of scientific knowledge in general, and the experience gained, in particular in
the field of testing and safety evaluation of cosmetic ingredients.
The previous revision of the Notes of Guidance took place in 2018 (SCCS/1602/18).
Since then, several new addenda, opinions and memoranda of importance to the content
of this guidance document have been adopted and they form the basis of this new
revision. Focus is on exposure and the application of alternative methods, more
specifically on non-animal methods/new approach methodology (NAM).
As was also the case in previous revisions, individual opinions are not provided in detail
but, where relevant, are briefly summarised and clearly referred to.
The "Notes of Guidance" have been compiled to provide assistance in the complex
process of the testing and safety evaluation of cosmetic ingredients in the EU.
Input of scientists from the Scientific Committee on Health and Environmental and
Emerging Risks (SCHEER) and Cosmetics Europe (CoE) is gratefully acknowledged.
The Chairperson
ACKNOWLEDGMENTS
SCCS members listed below are acknowledged for their valuable contribution to the
finalisation of this guidance document.
SCCS members
Dr U. Bernauer
Dr L. Bodin
Prof. Q. Chaudhry (SCCS Chair)
Prof. P.J. Coenraads (SCCS Vice-Chair)
Prof. M. Dusinska
Dr J. Ezendam
Dr E. Gaffet
Prof. C. L. Galli
Dr B. Granum
Prof. E. Panteri
Prof. V. Rogiers (SCCS Vice-Chair and rapporteur)
Dr Ch. Rousselle
Dr M. Stepnik
Prof. T. Vanhaecke
Dr S. Wijnhoven
SCCS external experts
Dr A. Koutsodimou
Prof. W. Uter
Dr N. von Goetz
All Declarations of Working Group members are available on the following webpage:
Register of Commission expert groups and other similar entities
The SCCS Notes of Guidance document is not open for commenting period as it
remains a living document, which is regularly updated. Any observation may be
sent to SCCS mailbox ([email protected]) for further consideration by
the SCCS.
Keywords: SCCS, SCCS Notes of Guidance for the Testing of Cosmetic Ingredients and their
Safety Evaluation, 11
th
revision, SCCS/1628/21.
Opinion to be cited as: SCCS (Scientific Committee on Consumer Safety), SCCS Notes of
Guidance for the Testing of Cosmetic Ingredients and their Safety Evaluation 11
th
revision,
30-31 March 2021, SCCS/1628/21.
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1
About the Scientific Committees
Two independent non-food Scientific Committees provide the Commission with the scientific
advice it needs when preparing policy and proposals relating to consumer safety, public health
and the environment. The Committees also draw the Commission's attention to the new or
emerging problems which may pose an actual or potential threat.
They are the Scientific Committee on Consumer Safety (SCCS) and the Scientific Committee
on Health, Environmental and Emerging Risks (SCHEER), and they are made up of
independent experts.
In addition, the Commission relies upon the work of the European Food Safety Authority
(EFSA), the European Medicines Agency (EMA), the European Centre for Disease prevention
and Control (ECDC) and the European Chemicals Agency (ECHA).
SCCS
The Committee shall provide Opinions on questions concerning health and safety risks
(notably chemical, biological, mechanical and other physical risks) of non-food consumer
products (for example cosmetic products and their ingredients, toys, textiles, clothing,
personal care and household products such as detergents, etc.) and services (for example:
tattooing, artificial sun tanning, etc.).
Scientific Committee members
Ulrike Bernauer, Laurent Bodin, Qasim Chaudhry, Pieter Jan Coenraads, Maria Dusinska,
Janine Ezendam, Eric Gaffet, Corrado Lodovico Galli, Berit Granum, Eirini Panteri, Vera
Rogiers, Christophe Rousselle, Maciej Stepnik, Tamara Vanhaecke, Susan Wijnhoven
Contact:
European Commission
Health and Food Safety
Directorate C: Public Health
Unit C2: Health information and integration in all policies
L-2920 Luxembourg
©
European Union, 2022
PDF ISSN 1831-4767 ISBN 978-92-76-54826-3 doi:10.2875/273162 EW-AQ-22-017-EN-N
The opinions of the Scientific Committees present the views of the independent scientists who
are members of the committees. They do not necessarily reflect the views of the European
Commission. The opinions are published by the European Commission in their original
language only.
https://health.ec.europa.eu/scientific-committees/scientific-committee-consumer-safety-
sccs_en
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3
Applicants are invited to visit the SCCS website:
https://ec.europa.eu/health/scientific_committees/consumer_safety/opinions_en
where Applicants will find a checklist
for submitting a safety dossier of a cosmetic ingredient.
Applicants are invited to visit the following website for further legislative information:
https://ec.europa.eu/growth/sectors/cosmetics/legislation_en
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MAIN CHANGES IN 11
TH
REVISION OF THE SCCS NOTES OF GUIDANCE (NOG)
The whole NoG have been revised and updated with a particular emphasis on the following:
- Inhalation models
- In silico methodology for genotoxicity/carcinogenicity
- General updating of NAMs
- Scientific concerns for the safety of the nanomaterials
- Update of ED section
- Discussion on uncertainty factors
- Updating of references in general
- Appendix 1: complying with the testing & marketing bans
- Appendix 9: guidelines on microbiological quality of the finished product
- Appendix 10: free access to in silico mutagenicity/genotoxicity databases
- Appendix 11: inhalation parameterisation
- Appendix 12: Lifetime Cancer Risk Approach
- Appendix 13: PoD used for TTC derivation
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1. INTRODUCTION
Since July 2013, Regulation (EC) No 1223/2009 applies for cosmetic products. Their safety-
in-use is, as was also the case for Directive 76/768/EEC, established by controlling the safety
of the ingredients.
For those ingredients for which some concern exists with respect to human health (e.g.
colourants, preservatives, UV-filters, hair dyes), safety evaluation is done at the Commission
level by the Scientific Committee on Consumer Safety (SCCS). These substances are
addressed in the Annexes of Regulation (EC) No 1223/2009.
For the safety evaluation of cosmetic ingredients, all available scientific data are considered,
taking into account the testing and marketing bans in force under Regulation (EC) No
1223/2009. This includes the physical and chemical properties of the compounds under
investigation, exposure via relevant exposure routes, in silico data such as results obtained
from (Q)SAR {(Quantitative) Structure Activity Relationship} modelling, chemical categories,
grouping, read-across, Physiologically Based PharmacoKinetics (PBPK) /ToxicoKinetics (PBTK)
modelling, in vitro and ex vivo experimental results and data obtained from animal studies
(in vivo) that have been carried out for the purpose of cosmetics before the testing and
marketing bans. The animal testing ban on finished cosmetic products applies since 11
September 2004; the testing ban on ingredients or combination of ingredients applies since
11 March 2009. The marketing ban applies since 11 March 2009 for all human health effects
with the exception of repeated-dose toxicity, reproductive toxicity, and toxicokinetics. For
these specific health effects, the marketing ban applies since 11 March 2013, irrespective of
the availability of alternative non-animal methods. In addition, clinical data, epidemiological
studies, information derived from accidents, data from Post-Marketing Surveillance (PMS) or
other human data are also taken into consideration
In the present update, the state-of-the-art with respect to the validated methods of the 3Rs
(Refinement, Reduction and Replacement) strategy of Russell et al. (1959), is incorporated
with emphasis on New Approach Methodologies (NAMs). In view of the testing and marketing
bans in the cosmetic regulation, the SCCS gives special attention to those alternative methods
that are suitable for the safety testing of cosmetic substances. New methodologies for risk
assessment of chemicals without using animal experimentation are worldwide being explored.
Attention is given here to Next-Generation Risk Assessment (NGRA) as a possible framework
for the safety evaluation of cosmetic ingredients and the NAMs that would fit into this
structure (Rogiers et al., 2020). Risk assessment of cosmetics and their ingredients is shifting
towards a strategic combination of NAMs and new technology with historical animal data, if
available, to come to a Weight of Evidence (WoE) decision making approach.
Although the "Notes of Guidance" are concerned with the testing and safety evaluation of the
cosmetic substances listed in the Annexes of Regulation (EC) No 1223/2009 and those for
which safety concerns have been expressed, they could be also of interest for all substances
intended to be incorporated in a cosmetic product. Even though the "Notes of Guidance" have
not been written for the latter purpose, they can indeed be of practical use in making a
Product Information File (PIF) for a finished cosmetic product as currently required by
Regulation (EC) No 1223/2009.
The European Chemicals Agency (ECHA) can ask for animal studies even if the substance is
foreseen only for cosmetic use (see Appendix 1, section 3). The applicant can submit these
animal data to ECHA, but cannot use these in the cosmetic product safety report (CPSR) for
the product information file (PIF) and cannot submit these to the SCCS for risk assessment
of the ingredient under cosideration. If SCCS knows about the existence of such a file at
ECHA, they can request access to these studies and consider whether the results have an
impact on the risk assessment of the substance and change their view.
The “Notes of Guidance” should not be seen as a prescriptive procedure, but rather as an
approach that may need to be adapted on a case-by-case basis when evaluating the safety
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6
of the Annex substances. However, when major deviations from standardised
protocols/procedures in the safety evaluation process have been adopted, it is essential that
Applicants provide scientific justification.
The "Notes of Guidance" will be revised as scientifically required on the basis of scientific
advances in toxicology and validated alternative methods or legislative changes.
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2. THE SCIENTIFIC COMMITTEE ON CONSUMER SAFETY, SCCS
2-1 BACKGROUND
The Commission Decision C(2015)5383 of 7.8.2015
1
established the new Scientific
Committees in the field of public health, consumer safety and the environment. Members
were appointed
2
for a five-year term (2016-2021) and a reserve list
3
was created. The term
was extended until end of 2026 due to Covid-19. The Principles and Working Procedures of
the Scientific Committees are stated in their establishing Decision and in the Rules of
Procedure adopted by their members (April, 2016)
4
.
For more information, see Appendix 1.
2-2 MANDATE
The SCCS is an advisory body that provides the Commission with scientific advice and safety
evaluations for Annex substances and compounds for which some concern for human health
exists. Its consultation for this task is compulsory.
For more information, see Appendix 1.
2-3 RULES OF PROCEDURE
The SCCS works with 3 working groups, dealing with:
cosmetic ingredients
methodology
nanomaterials.
Safety evaluations and advice are taken up in opinions, which are adopted during a plenary
meeting (or by written procedure). A commenting period of minimum four weeks (later
agreed on eight weeks) is foreseen for draft opinions before they are finalised and published.
For more information, see Appendix 1.
2-4 OPINIONS
Opinions are published on the SCCS website:
https://ec.europa.eu/health/scientific_committees/consumer_safety/opinions_en.
For more information, see Appendix 1.
2-4.1 THE "NOTES OF GUIDANCE"
One of the responsibilities of the SCCS is to recommend a set of guidelines to be taken into
consideration by the cosmetic and raw material industry in developing adequate studies to
be used in the safety evaluation of cosmetic substances.
This is done through the ‘Notes of Guidance for the Testing of Cosmetic Ingredients and Their
Safety Evaluation’ (NoG) that are regularly revised and updated in order to incorporate new
1
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/call_2015_5383_decision_with_annexes
_en.pdf
2
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/appointment_letter_2016_en.pdf
3
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/appointment_reserve_list_2016_en.pdf
4
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/rules_procedure_2016_en.pdf
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8
knowledge and scientific and regulatory advances. Therefore, dossiers submitted to the SCCS
should be in accordance with the latest published version of the NoG. The 10
th
Revision
SCCS/1602/18 is now replaced by this 11
th
Revision SCCS/1628/21.
As cosmetic ingredients are chemical substances, the NoG include the toxicological test
procedures reported in Commission Regulation (EC) No 440/2008. The latter describes the
basic toxicity testing procedures needed to evaluate different human health-related
toxicological endpoints and are internationally accepted as being the result of long-term
scientific agreement. Whereas the testing procedures for chemical substances take the 3Rs-
principle into consideration, animal experiments for cosmetic purposes are excluded in the
EU. For the safety evaluation of cosmetic ingredients only validated non-animal
methods/NAMs may be applied. Furthermore, testing procedures in accordance with the
Organisation for Economic Co-operation and Development (OECD) Guidelines, and, on a case-
by-case basis, well documented scientifically justified alternative methods that may not have
been officially validated yet are also carefully considered. Data obtained from animal
experimentation for the purpose of cosmetics or other consumer products legislation and
generated before the established cosmetic deadlines of the testing and marketing bans (see
1. Introduction) still may be used in the safety evaluation of cosmetics and their ingredients.
As regards data generated after the deadlines of the testing and marketing bans, see Section
3 of Appendix 1.
For the SCCS safety evaluation, the systemic doses obtained (mostly) after oral
administration are used. For local toxicity endpoints, normally only hazard identification is
carried out. Safety evaluation is done for intact skin.
2-4.2 SCCS COSMETIC INGREDIENT DOSSIERS
Regulation (EC) No 1223/2009 requires Annexed cosmetic substances to be notified, safety
assessed and adequately labelled before being allowed on the EU market. These annexes lay
down clear limitations and requirements for the cosmetic substances concerned. The safety
assessment of the cosmetic ingredients in the EU is overseen by the SCCS. The evaluations
carried out by the SCCS are based on safety dossiers submitted by Applicants (individual
company/associations, Competent Authorities).
In view of the animal testing and marketing bans of cosmetic ingredients/products, two main
routes to developing safety dossiers are possible:
In case a new ingredient is to be used exclusively in a cosmetic product, testing needs
to be in compliance with the restrictions on animal testing placed under Regulation
(EC) No 1223/2009 and safety data need to be derived from non-animal alternative
methods/NAMs.
When an ingredient has pre-existing safety data derived from animal tests (e.g. an
existing cosmetic ingredient) that have been carried out before the regulatory
deadlines, it can still be used.
Animal test data relating to chemical substances to be used also in products other
than cosmetics (e.g. food, medicines, biocides, etc.) can also be used for supporting
safety assessment of an ingredient intended to be used in a cosmetic product.
Further information is provided in Section 3 of Appendix 1.
In case of a negative or inconclusive opinion by the SCCS, resubmission of a dossier
is only possible when the Applicant provides sufficient (new) evidence to address
the concerns raised.
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2-4.3 SPECIFIC ISSUES TAKEN UP IN NOG
In addition to the regular revision of the NoG and the study of toxicological dossiers of
cosmetic substances for inclusion in one of the Annexes of Regulation (EC) No 1223/2009,
in the following sections some specific issues are addressed. Examples include (non-
exhaustive list):
New Approach Methodology (NAM) in the safety assessment of cosmetic ingredients
Introduction to Next Generation Risk Assessment (NGRA)
• Threshold of Toxicological Concern (TTC)
Endocrine disruptors’ issues
CMR (Carcinogenic, Mutagenic, toxic to Reproduction) issues
Safety assessment of hair dyes and colourants
• Safety assessment of nanomaterials
Safety of cosmetic ingredients for babies and children
Fragrance allergy in consumers
Risk and health effects: miscellaneous
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3. SAFETY EVALUATION OF COSMETIC INGREDIENTS
3-1 SAFETY EVALUATION OF COSMETIC INGREDIENTS AS APPLIED BY THE SCCS
- The safety of cosmetic products is based on the safety of the ingredients
The rationale behind the safety of the cosmetic product being based on the safety of its
ingredients comes from the fact that many thousands of different cosmetic products on the
EU market are all derived from a limited number of substances. Hence, toxicity testing has
been concentrated on ingredients, and particularly on those that are intended to react with
biological moieties and therefore are of potential concern for human health. This is also the
basis for the lists of authorized, banned and restricted substances (Table 1).
Annex II
List of prohibited substances
Annex III
List of restricted substances
Annex IV
List of allowed colourants
Annex V
List of allowed preservatives
Annex VI
List of allowed UV-filters
Table 1: Annexes to Regulation (EC) No 1223/2009
- For the safety evaluation of cosmetic ingredients two channels are functional
The safety of the Annex substances is evaluated by the SCCS; the safety of cosmetic
products with all their ingredients is evaluated by the industry placing them on the EU
market. Thus, the Annex substances fall under the responsibility of the SCCS (left part of
Figure 1). All the ingredients in cosmetic products are the responsibility of the “Responsible
Person, RP”, as defined by Regulation (EC) No 1223/2009, through the safety assessor (right
part of Figure 1).
Figure 1: Human health safety evaluation of cosmetic ingredients in the EU.
PIF: Product Information File
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11
- This guidance, in principle, equally applies to the safety evaluations carried out
by the SCCS as by the safety assessors of the cosmetic industry.
Safety evaluation is generally performed taking into account the data provided by the industry
or in some cases by Members States authorities. The SCCS also has the opportunity to add
relevant data from the open literature or other relevant sources.
In general, the safety evaluation of cosmetic ingredients by the SCCS is based upon the
principles and practice of the risk assessment process universally applied for chemical
substances with the challenge that only validated replacement methods (or demonstrated to
be scientifically valid) should be used when testing for the purposes of the EU cosmetic
legislation.
A typical safety evaluation procedure comprises the following elements:
1) Hazard identification is carried out to identify the intrinsic toxicological properties of the
substance, i.e. whether it has the potential to damage human health. It is based on the
results of in vivo studies, in vitro and ex vivo tests, in chemico methodology, in silico
methods and read-across, clinical studies, case reports, epidemiological studies and data
from Post-Marketing Surveillance (PMS). Intrinsic physical and chemical properties of the
substance under consideration are also taken into account.
2) Exposure assessment
Human exposure is calculated based on the declared functions and uses of a substance
as a cosmetic ingredient, the amount present in the respective cosmetic product
categories and their frequency of use.
The single product exposure describes the exposure to a cosmetic ingredient in one
product category via one route.
The aggregate exposure, in the context of the NoG, is the sum of all relevant single
product exposures, so that it describes the exposure from all product categories in which
the cosmetic ingredient is used and all relevant exposure routes.
Where necessary, exposure of vulnerable consumer groups could be assessed separately
(e.g. children, pregnant woman, etc.).
Generally, only exposures from the use of a substance as cosmetic ingredient are
considered, with the exception of CMR compounds, for which non-cosmetic uses should
also be taken into account (see section 3-6.6 and Appendix 5).
3) Dose-response assessment
For the relationship between the exposure and the toxic response, a Point of Departure
(PoD) is determined. The PoD is defined as the dose-response point that marks the
beginning of a low-dose extrapolation (for threshold and non-threshold compounds). In
most Opinions a No Observed Adverse Effect Level (NOAEL) has been used as PoD.
The SCCS considers that, where usable in vivo data are available, the preferred method
for both threshold and non-threshold cosmetic ingredients is to express the dose metric
as BenchMark Dose (BMD). Both the European Food Safety Agency (EFSA) and the World
Health Organization (WHO) also recommend that the BMD approach for deriving the PoD
should be used as a starting point for human health risk assessment.
The BMD approach has a number of advantages over using NOAEL. It makes complete use of
the available dose - response data
- it takes into account the shape of the dose - response curve
- it is less dependent on dose spacing
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12
- it enables quantification of the uncertainties in the dose - response data using
statistical methodology (EFSA, 2016).
For compounds with a threshold, the PoD can be a NOAEL, a Lowest Observed Adverse
Effect Level (LOAEL), or a BMD Lower limit (BMDL) (for details of the NOAEL and BMD
approach, see Sections 3-4.8, 3-5.1)
4) Risk characterisation
In risk characterisation, the focus in the NoG is on systemic effects. In the case of a
threshold effect, the Margin of Safety (MoS) is mostly calculated from oral toxicity
studies, unless robust dermal toxicity data are available
5
. In the case of an oral toxicity
study, the following equation (1) is used:
PoD
sys
MoS = (1)
SED
The PoD
sys
is a dose descriptor for the systemic exposure to a substance and is calculated
from the oral PoD by use of the proportion of the substance systemically absorbed. SED
represents the Systemic Exposure Dose (see also Section 3-3.5.4). In this equation, PoD
is
BMDL or, alternatively, NOAEL or LOAEL, where BMDL cannot be calculated.
For non-threshold effects (e.g. a non-threshold carcinogenic effect), the lifetime risk is often
based on the BMD10 (benchmark dose response for a 10% response). The risk assessment
of carcinogens is described in Section 3-4.11.
Risk characterisation is followed by risk management and risk communication, which are not
in the remit of the SCCS, but of the European Commission or the RP, the latter when a finished
cosmetic product and its ingredients are involved (Figure 1).
Besides the normal procedure when the industry or Member States or their representatives
submit a complete dossier, in some cases, either upon request of the Commission or on a
voluntary basis, industry provides additional data on cosmetic ingredients that have been
assessed in the past. An evaluation exclusively based on additional reports, together with
summaries of earlier submissions, however, may not be adequate. Therefore, complete
dossiers may be required case by case, even though a re-evaluation of only a part of a dossier
appears necessary. Dossiers and full studies should be submitted in common formats such
as pdf or Word and need to be readable and searchable.
Other common formats that allow copy/paste actions are accepted. Scanned documents that
are not readable/ searchable are not accepted.
It is beyond the scope of the NoG to discuss the whole process of risk assessment. Numerous
review articles and textbooks exist on this topic. The aim is to highlight some key aspects to
explain why certain data and test results should be provided in the dossiers on the cosmetic
substances presented to the SCCS for evaluation.
An example of the framework of a typical dossier is given in Appendix 3.
5
For the case that a dermal repeated dose toxicity study is used, see Section 3-4.8 and 3-5.1
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13
The contact point for dossier submissions and regulatory/risk management questions is:
GROW-F2@ec.europa.eu
The SCCS address for scientific requests is: SANTE-C2-SC[email protected]pa.eu
3-2 CHEMICAL AND PHYSICAL SPECIFICATIONS OF COSMETIC INGREDIENTS
Physical and chemical properties of substances are considered as crucial information, since
they may indicate potential risks. For example, a small Molecular Weight (MW) hydrophobic
compound is more likely to penetrate through the skin than a high MW hydrophilic compound.
Physical and chemical properties also identify physical hazards of the substance (e.g.
corrosiveness as indicated by pH of aqueous solution, volatility, explosiveness, flammability).
In addition, some QSAR (Quantitative Structure Activity Relationship) programmes and
empirical models require physical and chemical property values as inputs for in silico
estimation of properties and potential biological effects.
The basic and minimal specifications for any cosmetic ingredient to be evaluated are:
1) Chemical identity;
2) Physical form;
3) MW;
4) Characterisation and purity of the chemical, including isomer composition whenever
relevant for safety assessment;
5) Characterisation of the impurities or accompanying contaminants;
6) Solubility;
7) Partition coefficient (Log P
ow
);
8) Vapour pressure (volatile liquids);
9) Homogeneity and stability;
10) Further physical and chemical properties if relevant for safety evaluation.
For nanomaterials, special requirements for provision of physicochemical data apply (see
Section 3-6.8). Original data on all these points must be included in each toxicological dossier
and information and documentation for all analytical data should be provided.
The appropriate certificate of analysis must also be presented for the test chemical used to
generate the data as submitted in the dossier to the SCCS.
Preference is clearly given to measured parameters of relevant batches on the market over
calculated values (e.g. log P
ow
) or literature data (where often batches are tested that differ
from the batches used in toxicological tests and therefore may have different composition /
impurity profiles).
In the following section, the methods are (where relevant) accompanied by their
corresponding reference number in Regulation (EC) No 440/2008 (2008/440/EC).
3-2.1 CHEMICAL IDENTITY
The precise identity and chemical nature of the substance under consideration and its
structural formula must be given. The Chemical Abstracts Service (CAS) number of the
chemical, the International Nomenclature of Cosmetic Ingredients (INCI) name or Common
Ingredient Nomenclature (CIN) name and the EC number (see Appendix 2 for more details)
should be provided.
With regard to substances that cannot be identified in terms of their structural formula,
sufficient information should be provided on the method of preparation (including all physical,
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14
chemical, enzymatic, (bio)technological or microbiological steps) and the materials used in
their preparation to enable assessment of the probable structure and activity of the
compound(s).
For the safety evaluation of a complex mixture (e.g. an extract), complete information should
be provided on the origin of the source materials (e.g. part of a plant), extraction method
and any additional processes and/or purification steps used (see Section 3-6.1) to establish
a standardised material as representative of the extract present in commercial products.
In case of a mixture, components must be described in terms of qualitative and quantitative
formulae. These could be: main components, preservatives, antioxidants, chelators, buffering
agents, solvents, other additives, impurities and/or additional external contamination.
When a cosmetic ingredient and its derivatives (salt, ester, …) are submitted for evaluation,
this must be clearly specified in the dossier, because the chemical form can determine the
safety evaluation. The physical and chemical properties of all specific chemical forms must be
provided, and the same specific substances must be used in the toxicological studies
performed for the safety evaluation. Any deviations must be justified.
3-2.2 PHYSICAL FORM
A description of the physical form should be given: powder, paste, gel, liquid. For
nanoparticles, further information as specified in Section 3-6.8 should be given, including the
particle size and its distribution.
For polymer ingredients, the molecular weight distribution should be provided.
3-2.3 MOLECULAR WEIGHT
The MW of each substance should be given in Daltons. In the case of mixtures, the MW must
be given for the constituents.
3-2.4 IDENTIFICATION AND PURITY OF THE CHEMICAL AND ISOMER COMPOSITION
The degree of purity must be clearly indicated. The validity of the analytical methodology
used must be shown. When a reference material/standard is used for the determination of
purity, a certificate of analysis of the reference standard should be submitted (Appendix 6)
Purity of the active substance based on High Performance Liquid Chromatography (HPLC)
peak area can only be accepted when:
1) a reference material of known purity is used,
2) the HPLC recovery of the test material is clearly documented,
3) the ultraviolet (UV) detection of the active substance is performed at λ
max
, in an
appropriate mobile phase, and
4) peak purity of the active substance is clearly documented.
The experimental conditions of the techniques used for the chemical characterisation UV,
Infra Red (IR) and Nuclear Magnetic Resonance (NMR) spectroscopy, Mass Spectrometry
(MS), chromatographic techniques e.g. Gass Chromatography (GC), elemental analysis, etc.)
as well as the resulting spectra, chromatograms etc. should be provided.
The substance(s) used in physical and chemical tests, toxicity studies, etc., mentioned in the
dossier, must be either exactly the same material(s) under consideration or justifiably
representative of the substances present in commercial products.
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15
When a substance is a mixture of isomers, only the relevant isomer(s) used as a cosmetic
ingredient should be included in the safety assessment. The other isomer(s) is/are considered
as an impurity or impurities. Information on isomer composition should be provided.
3-2.5 CHARACTERISATION OF THE IMPURITIES OR ACCOMPANYING CONTAMINANTS
In addition to the purity of the substance under consideration, identity in terms of the
chemical nature and concentration of impurities that may be present must also be stated.
Impurities should be characterised and quantified by an appropriate analytical method, e.g.
by HPLC-PDA (Photometric Diode Array), LC-MS/GC-MS, NMR spectroscopy etc., using
reference standards with documented purity, where appropriate. Validated analytical
procedures should be used for impurity testing. There is no specific recommendation available
to assess the limit of acceptable non-CMRs impurities for cosmetic products.
Small changes in the nature of some impurities may considerably alter the toxicity of
substances. In general, results of safety studies on a particular substance are only relevant
when they refer to that substance used, with its own specific purity and impurity profile. The
scientific validity of tests performed on batches of the substance with diverging purities
deserves careful interpretation. Therefore, it must be ensured that neither other impurities
nor an increased level of impurities are present in the representative commercial material.
For this, the stability of the synthesis process, including any purification measures, is
important. A change in these processes will need careful re-evaluation of the impurities, even
if the level of purities remains the same.
3-2.6 RELEVANT PHYSICOCHEMICAL SPECIFICATIONS
A typical physicochemical dataset consists of:
- Physical state (solid, liquid, gas)
- Organoleptic properties (colour, odour, taste if relevant)
- Solubility (EC A.6) in water and relevant solvents, including receptor fluids (at … °C)
- Partition coefficient (EC A.8) (Log P
ow
, at … °C), if applicable
- Flash point (EC A.9)
- Physical properties depending on the physical state:
o for liquids: boiling point (EC A.2), relative density (EC A.3) (at … °C), pK
a
(at … °C),
viscosity (at … °C), vapour pressure [EC A.4] (at … °C), ....
o for solids: morphological form (crystal form, amorphous, ...), melting temperature
(EC A.1), pK
a
(…% in ..., at … °C), ...
o for gases: density (EC A.3) (at … °C and pressure), auto-ignition temperature (EC
A.15)
- In case of a UV-absorbing substance, the UV-absorption spectrum of the compound should
be included. It is self-evident that for UV filters, the UV spectrum is indispensable.
- For nanomaterials and nanoparticles special requirements apply (see Section 3-6.8).
3-2.7 SOLUBILITY
The solubility (EC A.6) of the substance in water and/or in any other relevant organic solvent
should be stated (in g/l at °C). Some substances are sparingly soluble or insoluble in
aqueous media or other solvents. These should be clearly stated. In Table 2, different
solubility terms have been defined.
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16
Where the solubility of the active substance in water is low (according to EU Method A.6), a
highly sensitive and selective analytical technique (such as LC/MS) should also be used to
document the solubility and to rule out that the soluble material may be an impurity (or
impurities) in the test material. Similarly, solubility of substances that are poorly soluble in
various solvents should be measured by highly sensitive and selective analytical technique
(such as LC/MS). In cases of low solubility of the active substance in reverse phase HPLC
mobile phases, sensitive detection systems, such as MS, should be applied, or another normal
phase chromatography should be used.
The solubility of the active substance in the solvent systems used in various studies should
also be clearly presented.
Table 2: Definition of solubility terms (adapted from USP38/ USP38NF33*and General
Notices (Ph. Eur. 10
th
Ed.)
Term*
Parts of Solvent Required
for 1 Part of Solute*
Solubility defined in g/L
(deduced by SCCS)
Very soluble
Less than 1 part
>1000
Freely soluble
1 to 10 parts
100-1000
Soluble
10 to 30 parts
33.3-100
Sparingly soluble
30 to 100 parts
10-33.3
Slightly soluble
100 to 1000 parts
1-10
Very slightly soluble
1000 to 10000 parts
0.1-1
practically insoluble, or
insoluble
>10000, or equal to10 000
parts
< 0.1 or = 0.1
*Under USP38/ USP38NF33: practically insoluble is used in USA; in EU: insoluble
3-2.8 PARTITION COEFFICIENT (LOG POW)
The n-octanol/ water partition coefficient (EC A.8) should be given, along with the pH and
temperature conditions.
In the case of a calculated value, the method used for estimation should be specified.
LogP
ow
values often depend on the pH, especially for ionisable molecules, zwitterions, etc.
Therefore, a single calculated value of Log P
ow
, without any reference to the respective pH,
cannot be correlated to the physiological conditions and the pH conditions of the dermal
absorption studies.
3-2.9 HOMOGENEITY AND STABILITY
Homogeneity data of the test solutions with respect to the content of the test substance,
under experimental conditions, should be provided.
Data on the stability of the test substance under the experimental conditions of the reported
studies and under conditions of use should be provided. Validated analytical procedures
should be used to determine stability of the test substance. In addition, the stability of the
test substance relating to its thermal stability and, if applicable, sensitivity to moisture or
oxygen under storage conditions and in typical cosmetic formulations should also be provided.
Any degradation products should be chemically characterised. In this regard, it is important
that the storage conditions and the lengths of studies chosen should be sufficient to cover
the storage, shipment, and subsequent use. The stability studies should also be conducted
on the test substance packaged in a container, which is the same as the container intended
for storage and distribution for marketing.
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17
3-3 EXPOSURE ASSESSMENT
3-3.1 FUNCTIONS AND USES OF COSMETIC INGREDIENTS
For substances that are evaluated as cosmetic ingredients, the concentration, function and
way of achieving that function in marketed cosmetic products should be reported. In
particular, it should be explicitly mentioned whether substances are meant to be included in
sprays or aerosols since consumer exposure via inhalation is then probable and needs to be
taken into consideration in the overall risk assessment.
In addition, other uses of the substance (e.g. in consumer products, industrial products) and,
wherever possible, the concentrations involved in such uses should be described.
3-3.2 IDENTIFICATION OF RELEVANT EXPOSURE SCENARIOS
In order to assess exposure of the end users, relevant exposure scenarios have to be
identified that comprise all the important functions and uses of a cosmetic ingredient (see
Section 3-3.1). These scenarios need to describe "reasonably foreseeable exposure
conditions" (Cosmetics Regulation (EC) No 1223/2009, Article 16 f), under which these the
cosmetic product should be safe.
The following parameters describe an exposure scenario. However, the list is not exhaustive,
and further parameters may need to be taken into account. Note that all routes of exposure
(dermal, oral and inhalation) should be considered in view of the intended use of the product.
cosmetic product type (s) in which the ingredient may be used
method of application as detailed as possible, e.g. rubbed-on, sprayed, applied and
washed off, etc.; considerations whether the product is a rinse-off or leave-on product
and which retention factor should be applied
concentration of the ingredient in the marketed cosmetic product
quantity of the product used at each application
frequency of use
total area of skin contact
duration of exposure
target consumer groups (e.g. children, people with sensitive, damaged or
compromised skin) where specifically required
application on skin areas exposed to sunlight
location of use (indoors/outdoors) and ventilation
3-3.3 IDENTIFICATION OF THE TARGETED DOSE FOR SAFETY EVALUATION
The hazard identification can either point to systemic effects that require comparison to a
SED or local effects, like skin/eye irritation, skin sensitisation, sun-induced skin reactions or
effects on the lungs, which mostly are dependent on the amount of substance acting on the
surface tissues of the respective body part and require comparison to a Local External Dose
(LED).
In the exposure assessment, first the LEDs are calculated that are expected at the specific
body entrances and available for uptake. The most important body entrances for substances
in cosmetics are the skin, the inhalatory tract and the mouth. These correspond to the uptake
routes for internal exposure (dermal route, inhalation route and oral ingestion). For selected
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18
products other entrances are possible, e.g. via the eyes (e.g. eye makeup), or via genital
regions (e.g. intimate spray, intimate creams).
As an example, the LED in the lung (the amount of compound per g of lung tissue) can be
compared to a “local” NOAEL, and a local MoS can be calculated for effects on the lungs.
The external exposure can further be used to calculate internal (or systemic) exposure which
corresponds to an internal dose (see Section 3-3.5.4). For the calculation of the SED,
absorption (or uptake) specific to the respective exposure route has to be taken into account.
For risk assessment, the MoS (see Section 3-5.1) is based on the internal dose, i.e. the SED.
3-3.4 EXTERNAL EXPOSURE
3-3.4.1 EXPOSURE MODELS AND TIERED APPROACH
Exposure is calculated based on exposure scenarios by using appropriate exposure models.
Generally, external exposure is calculated by multiplying the concentration/fraction of a
substance in a source with the amount of the source that is applied on, or reaches, a specified
site. To save time and resources, a tiered approach is normally followed that first
investigates exposure based on generic exposure scenarios with conservative point values as
model parameters (screening level).
Where necessary, these conservative exposure estimates are refined in a higher tier by using
probabilistic approaches or other means of refinement (Meek et al., 2011).
For the safety evaluation of cosmetics, such a screening level approach is the calculation of
aggregate exposure according to the NoG. The parameter values presented there can be used
as the basis for a deterministic first-tier assessment. If a refinement is necessary, a
probabilistic approach can be followed by the use of appropriate models and/or tools.
However, this needs to be clearly justified. For regulatory purposes, the probabilistic approach
needs to be conservative but realistic and transparent.
In particular, for probabilistic assessments the SCCS recommends the following:
- Habits and practices in a population regarding the use of product categories may be
treated probabilistically, under the assumption that they will not change rapidly over time.
- The target protection goal will be the 95
th
percentile of the European population.
Therefore, for a probabilistic assessment the relevant SED for deriving the MoS will be the
95
th
percentile of the probabilistically assessed population exposure.
- Ingredient concentrations in product categories should normally cover the worst case, i.e.
for ingredients with restrictions on concentrations and applicability domains (Annex III of
the EU Cosmetic Regulation), also in the probabilistic assessment the maximal allowed
concentrations should be used, and for other ingredients the maximal concentrations that
are realistically foreseeable in a specific product category. This is because product
formulations may be highly variable over time, so that an assessment of ingredient
concentrations at a specific point in time may not cover the use of the ingredient in the
future.
- For reasons of transparency, the model equations and the input parameters need to be
provided together with the exposure estimates, so that the exposure calculation is
reproducible. If this is not possible, because a specific tool has been used, the original
input file containing used distributions and all settings, and the original output file need
to be provided by the Applicant. The output file needs to contain the date of the
assessment, the relevant model settings and parameters for this assessment and the
associated results, ideally not only in tabular form by giving relevant percentiles of the
exposure distribution, but also by graphical visualisation.
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19
3-3.4.1.1 DERMAL EXPOSURE MODELS
For cosmetics, the dermal route is often the most important one.
Apart from the general approach, the calculation of dermal exposure needs to take into
account that only a fraction of the product is retained on the skin. Therefore, a retention
factor F
ret
is used that represents the fraction available for uptake. For leave-on cosmetics
(e.g. creams, body lotion, etc.) mostly a fraction of 1 (100%) is used, while for rinse-off
cosmetics (e.g. shower gel, shampoo, etc.) a smaller fraction is used that depends on the
respective product. In Tables 3A and 3B retention factors are listed that are applied by the
SCCS.
External dermal exposure (E
dermal
) per day for a substance from a certain product category
x
can be calculated according to:
The daily amount (q
x
) and retention factor (f
ret x
) are specific to the product category under
consideration, and do not depend on the substance. When multiplied, they yield the daily
effective amount per product category, Eproduct = q
x
x f
ret x
, which is listed in Tables 3A and
3B for the most important product categories. Multiplied with the concentration or fraction of
a substance in a product, they yield the external dermal exposure to a substance per product
category E
dermal x
,
as shown in equation (3).
This external exposure can be used to calculate the SED by multiplying with the chemical-
and route-specific uptake rate and normalisation by the bodyweight (see chapter 3-3.5.4).
In cases where the amount per day q
x
is not given or if more detailed probabilistic
assessments should be performed, the amount per day can be calculated from the frequency
of application (Table 4) and the amount per application. In Appendix 7 (Table A.7) a
literature review can be found listing studies which provide detailed external exposure values
to different cosmetic products. These are given for specific countries. Furthermore, the
external daily exposure per product category can be used to derive a LED (2). Normally, local
dermal effects depend on the surface load, so that the total dermal exposure is normalised
by the Skin Surface Area of application (SSA).
3-3.4.1.2 ORAL EXPOSURE MODELS
The same principles as described for dermal exposure can be applied for oral exposure.
Ingestion can be calculated according to equation (3) by applying adequate retention factors.
Such oral retention factors are needed to take into account that only a fraction of the orally
applied products will be ingested. Since orally applied cosmetics such as toothpaste,
mouthwash or lipstick are normally not intended to be ingested, such retention factors will
normally be small.
E
dermal x
= C
x
X q
x
X f
ret x
(3)
E
dermal x
(mg/day): external exposure available for dermal uptake from product
category
x
X: product category
C
x
(mg/g): concentration/ fraction of a substance in a product category
X
q
x
(g/day): amount of product category
that is applied/received per day
f
ret x:
retention factor specific to product category
x
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20
3-3.4.1.3 INHALATION EXPOSURE MODELS
Cosmetic substances can be inhaled in the form of powder, vapor, aerosolised droplets or
aerosolised particles.
For powders, the principles are very similar to spray products. Inhalation exposure to
cosmetic powders during intended use usually is limited and the safety of airborne particles
depends in particular on the aerodynamic diameter of the particles. In the safety evaluation
of powders, the robustness of the exposure data plays a major role (Steiling et al., 2018).
Vapours result from the transfer of volatile substances into the air after dermal or spray
application of products or due to evaporation of substances. Non-volatile substances can be
transferred into the air mechanically by spraying, where they are initially present in the form
of small droplets or particles.
External exposure to vapour can be calculated directly based on the concentration of the
substance in the air.
Aerosolised particles and droplets normally result from spraying or other mechanical
dispersion. Their deposition efficiency in the respiratory tract is size-dependent but also
depends on density, and hygroscopicity (ability of a substance to attract and hold water
molecules from the surrounding environment) and is influenced by the local anatomy and
airflow (Braakhuis et al., 2014). However, particle and droplet size is generally regarded as
the most important influencing factor for deposition. The size of the particles/droplets after
spraying is influenced by the actual formulation (surface tension) and by the vapour pressure
of the different solvents and propellants used in the formulation. It is also closely related to
the geometry of the spray nozzle and the can size.
Generally, there are two types of spray application devices: propellant driven aerosol sprays
and pump sprays. According to Bremmer et al. (Bremmer et al., 2006a; Bremmer et al.,
2006b), propellant driven aerosol sprays are often developed to produce a fine mist, with
often a relevant fraction of particle/droplet size <10 µm, compared to pump sprays, which in
general produce larger particles/droplets. However, also for pump sprays the size of the
droplets produced depends on the spray nozzle and studies e.g. by Quadros and Marr
(Quadros and Marr, 2011) have shown that pump sprays can even produce particles/droplets
in the nano size range. Another important consideration in relation to the airborne
droplets/particles is that they can dry off quickly while airborne and become small enough to
become respirable due to evaporation of the solvents/ formulants. It is therefore
recommended that safety assessment of the sprayable products should take into account not
only the size distribution of the generated aerosol droplets but also their size distribution just
before settling. This is especially important for spray/sprayable cosmetic products containing
nanomaterials, for which measured droplet size as well as size distribution of the dried
residual particles will need to be provided. For more detailed considerations, see Guidance on
the Safety Assessment of Nanomaterials in Cosmetics (SCCS/1611/19).
A sprayed formulation generally consists of droplets and/or particles of different sizes, which
change their number and size distribution with time (e.g. by aggregation of particles and
evaporation of solvent) before they reach the airways. The size fraction comprising
droplets/particles with a Mass Median Aerodynamic Diameter (MMAD) of ≤100 μm is generally
regarded as inhalable. As rodents inhale and exhale to a much larger extent through their
nostrils than humans, particles are more likely to reach the lung in rodents.
For humans, usually three main fractions of the airborne aerosol are distinguished: the
inhalable fraction, the thoracic fraction, and the respirable fraction. These particle size
fractions are defined in the EU-standard EN 481 for measurements in workplaces (CEN,
1993). Estimates for adults and children during typical activities with both nasal and oral
inhalation have been determined by Brown et al. (Brown et al., 2013).
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21
It should be noted that after mucociliary clearance, further intake of insoluble particles or
their components via the oral route may occur in humans.
The level of exposure can be directly measured under standard exposure conditions or
estimated by using mathematical models. When measuring exposure, it is important to do it
during the relevant exposure period after spraying, under relevant conditions (Carthew et al.,
2002; Rothe et al., 2011).
When using mathematical models, a tiered approach should be followed. Default equations
can be used as a conservative, worst case approach, and as a first estimate (ECHA, 2012b).
For a more realistic assessment 1- or 2-Box models, as well as higher-tier models, can be
considered. In a classical 1-Box model it is assumed that the entire spray amount is
instantaneously released into the air and distributed in a box of a specific size, which e.g.
simulates the breathing zone (Box A in Figure 2). The resulting air concentration is then
multiplied by the breathing rate and the time spent in the box to calculate the exposure. A
2-Box model takes into account the dilution of the substance over time. As in the 1-Box
model, the assumption is that the spray is instantly released and distributed in a box A around
the head. There the aerosol is present for exposure over a defined time, after which the full
amount of aerosol in the first box is transferred to a larger second box B (see Figure 2),
where it is available for inhalation for a second defined time period. For a conservative
approach, the air exchange (fresh air getting in, exhaust air getting out) can be assumed as
zero. An example for a 2-Box model is given in Rothe et al., 2011.
Figure 2: Deterministic 2-Box model (according to Steiling et al., 2014); copyright from
Elsevier, first published in Toxicology Letters 227, 2014.
For higher tier assessment, one of the tools that can be considered for calculating exposure
estimates is the ConsExpo model (www.consexpo.nl).
This tool comprises two modules for inhalation: 1) exposure to vapour and 2) exposure to
sprays.
The spray module calculates the exposure based on the inhalable fraction of the generated
aerosols. For conventional (non-nano) substances, it is assumed that these are
homogeneously distributed in the box through the generated aerosols.
For that reason, in the experiments carried out for the calibration of ConsExpo, aerosols with
a size <1 µm have not been taken into account, because ConsExpo is mass-based and the
mass of aerosol droplets <1µm is negligible compared to the aerosols present in the inhalable
fraction of 1-20 µm.
_____________________________________________________________________________________________
22
In ConsExpo, key parameters in the calculation of the inhalation exposure are room volume,
spray duration, ventilation rate, exposure duration and product specific parameters, such as
“mass generation rate” (rate at which mass is released by spraying), airborne fraction, aerosol
size distribution, and weight fraction of the ingredient. Note that since nanoparticles had not
been measured in the calibration data set underlying the model, ConsExpo Spray cannot be
used directly for nanoparticles.
Inhalation is not the intended route of exposure for cosmetic exposure. Therefore, the flow
chart (see Figure 3) can be followed to determine whether assessment of inhalation exposure
is necessary for a given cosmetic formulation.
Figure 3: Basic principles for the tiered safety assessment of inhalable cosmetic products
and their ingredients. Modified from Steiling et al. (2014); grey = related to ingredients;
yellow = related to product exposure.
_____________________________________________________________________________________________
23
3-3.4.2 MODEL PARAMETERS
For the parameter values, either point values (deterministic assessment) or distributions
(probabilistic assessment) can be used. Regardless of the method, the calculation needs to
be conservative. In the case of a deterministic assessment this means that higher percentiles
should be used for most parameters. In order not to be overly conservative, for some
parameters, such as the body weight, a mean or a standard value can be chosen.
3-3.4.2.1 DAILY USE AMOUNTS AND RETENTION FACTORS
Upon request of the SCCS, Cosmetics Europe has provided a large-scale use study for the
most important consumer product categories (based on frequency and amount of use in the
general population) among consumers in different European Member States. These Member
States were Spain, Great Britain, France, Germany and Denmark, where the population of
Spain represented the populations of southern European countries, such as Spain, Italy,
Portugal and Greece; Great Britain represented those of the United Kingdom and Ireland. The
population of France represented only the one of France, whereas the population of Germany
represented mid-European countries such as Germany, Belgium, Luxembourg, the
Netherlands and Austria. The population of Denmark represented the northern European
countries i.e. Denmark, Finland and Sweden. Prediction for the European population was
realised by generating daily applied amounts using probabilistic analysis for 11 product
categories, i.e body lotion, deodorant, facial moisturiser, shampoo, lipstick, toothpaste,
mouthwash, shower gel, liquid foundation, hand cream and hair styling products (Hall et al.,
2007; McNamara et al., 2007, Hall et al., 2011). The publications report consumed amounts
of cosmetic products per day and per kg bodyweight. They do not differentiate between
frequency of application and amount per application based on the assumption that for
regularly used products the frequency and amount are inversely correlated.
In Table 3A conservative point values for the estimated amount q
x
are listed that can be
used to assess exposure in a first tier. From the amount distributions generated in the
probabilistic assessments (Hall et al., 2007, Hall et al., 2011), the P90 was chosen for both
daily and relative daily amount applied to the skin, respectively. These amounts were
multiplied with the respective retention factors f
ret
(derived in SCCNFP/0321/00) to yield the
effective exposure to a product category (E
product
). For deriving the relative amounts and
exposures reported in Table 3A, bodyweight distributions from the European countries
included in the study were used in a Monte Carlo approach explained in Hall et al., 2007 and
McNamara et al., 2007.
From the E
product
derived below, the dermal exposure E
dermal
to a substance can be calculated
according to equation (4):
E
dermal
= E
product
X C
x
(4)
where
C
x
: substance concentration in a product category.
_____________________________________________________________________________________________
24
Table 3A: Daily exposure levels for different cosmetic product categories in Europe,
calculated by multiplying daily amounts (Hall et al., 2007, 2011) and f
ret
.
Product type
Relative
daily
amount
applied
1
Retention
factor
2
Calculated
daily
exposure
Calculated
relative
daily
exposure
1
q
x
/bw
f
ret
E
product
E
product
/bw
(mg/kg
bw/d)
(g/d)
(mg/kg
bw/d)
Bathing, showering
Shower gel
279.20
0.01
0.19
2.79
Hair care
Shampoo
150.49
0.01
0.11
1.51
Hair styling
products
57.40
0.10
0.40
5.74
Skin care
Body lotion
123.20
1.00
7.82
123.20
Face cream
24.14
1.00
1.54
24.14
Hand cream
32.70
1.00
2.16
32.70
Make-up
Liquid foundation
7.90
1.00
0.51
7.90
Lipstick, lip salve
0.90
1.00
0.057
0.90
Deodorant
Deodorant non-
spray
22.08
1.00
1.50
22.08
Deodorant spray
10.00
1.00
0.69
10.00
Oral hygiene
Toothpaste
(adult)
43.29
0.05
0.138
2.16
Mouthwash
325.40
0.10
2.16
32.54
1
The specific body weight of the persons involved in the study is used and not the default value of 60
kg.
2
The retention factor (f
ret
) was introduced by the SCCNFP to take into account rinsing off and dilution
of finished products by application on wet skin or hair (e.g. shower gels, shampoos) (SCCNFP/0321/00);
f
ret
has no units.
The large-scale study cited above only included the most frequently used 12 cosmetic
products. Deterministic amounts and exposure data for further cosmetic products had been
provided earlier for normal and extensive use (Colipa 16.01.97 BB-97/007, SCCNFP
/0321/00). Table 3B lists conservative use levels for some cosmetic products based on
female usage (higher than for males) and extensive use reported by SCCNFP.
_____________________________________________________________________________________________
25
Table 3B: Estimated daily exposure levels in Europe for additional cosmetic product
categories, which are not covered by Hall et al., 2007, 2011 (SCCNFP/0321/00; Steiling et
al., 2012; Colipa 16.01.97 BB-97/007).
Product type
Estimated
daily
amount
applied
Relative
daily
amount
applied
5
Retention
factor
1
Calculated
daily
exposure
Calculated
relative
daily
exposure
q
x
q
x
/bw
f
ret
E
product
E
product
/bw
(g/d)
(mg/kg
bw/d)
(g/d)
(mg/kg
bw/d)
Hair care
Hair conditioner
2
3.92
-
0.01
0.04
0.67
Semi-permanent
hair dyes (and
lotions)
2
35 ml
(per
application)
-
0.1
Not
calculated
3
-
Oxidative/permanent
hair dyes
2
100 ml
(per
application)
-
0.1
Not
calculated
3
-
Make-up
Make-up remover
2
5.00
-
0.10
0.50
8.33
Eye shadow
2
0.02
-
1.00
0.02
0.33
Mascara
2
0.025
-
1.00
0.025
0.42
Eyeliner
2
0.005
-
1.00
0.005
0.08
Deodorant
Deodorant aerosol
spray
(ethanol-based)
4
1.43
20.63
1.00
1.43
20.63
1 The retention factor (f
ret
) was introduced by the SCCNFP to take into account rinsing off and dilution
of finished products by application on wet skin or hair (e.g. shower gels, shampoos, …)
(SCCNFP/0321/00). Being a fraction between 0 and 1, f
ret
has no units.
2 Product categories not covered by Hall et al., 2007, 2011.
3 Daily exposure value not calculated due to the low frequency of application.
4 Steiling et al., 2014: ‘ethanol-based’ are products containing ethanol as the principal ingredient.
5 The specific body weight of the persons involved in the study is used and not the default value of 60
kg.
Alternatively, if daily use data are not available, the daily use can be calculated from the
frequency of the application event and the amount per event. For calculating the amount per
event e.g. the surface area of body parts can be helpful. Therefore, in Table 4 human surface
areas (Bremmer et al., 2006a; Bremmer et al., 2006b) and the frequency of application are
provided. For calculating a first tier, the maximum frequency per day should be multiplied by
the maximally applied amount. For daily amounts per body weight these amounts can be
divided by the default human body weight of 60 kg.
_____________________________________________________________________________________________
26
Table 4: Mean exposed skin surface area per product category (Bremmer et al.,
2006a; Bremmer et al., 2006b) and frequency of application per product
category
Product type
Surface
area for
application
SSA (cm
2
)
Body areas
Frequency
of
application
Bathing, showering
Shower gel
17500
total body area
1.43/day
Hand wash soap
860
area hands
10/day
3
Bath oil, salts, etc.
16340
area body- area hands
1/day
Hair care
Shampoo
1440
area hands+ ½ area head
1/day
Hair conditioner
1440
area hands+ ½ area head
0.28/day
Hair styling products
1010
½ area hands+ ½ area head
1.14/day
Semi-permanent hair
dyes (and lotions)
580
½ area head
1/week
(20min.)
Oxidative/ permanent
hair dyes
580
½ area head
1/month
(30min.)
Skin care
Body lotion
15670
area body-area head
(female)
2.28/day
Face cream
565
½ area head (female)
2.14/day
(+applied on neck)
320
1
(+ applied on back of
neck)
80
2
Hand cream
860
area hands
2/day
Make-up
Liquid foundation
565
½ area head (female)
1/day
Make-up remover
565
½ area head (female)
1/day
Eye shadow
24
2/day
Mascara
1.6
2/day
Eyeliner
3.2
2/day
Lipstick, lip salve
4.8
3
2/day
Deodorant/antiperspirant
Deodorant spray
4
and
non- spray
5
200
both axillae
2/day
Fragrances
Eau de toilette spray
200
total body area
1/day
Perfume spray
100
area hands
1/day
Men’s cosmetics
Shaving cream
305
¼ area hand (male)
1/day
Aftershave
305
¼ area hand (male)
1/day
Sun care cosmetics
Sunscreen lotion/
cream
17500
total body area
2/day
1 If the in vitro dermal absorption assay was not performed under in-use conditions, an additional
correction factor can be introduced.
_____________________________________________________________________________________________
27
2 Besides these European values, it should be noted that the US EPA also published default values for
Skin Surface Areas (SSAs) of relevant parts of the human body (US EPA, 1997).
3 Danish Ministry of the Environment, Environmental Protection Agency: Survey of liquid hand soaps,
including health and environmental assessments.
4 Daily exposure value not calculated due to the low frequency of exposure
5 Steiling et al., 2014: ethanol-based’ are product categories containing ethanol as the principal
ingredient.
The SCCS emphasises that it is not the intention to provide parameter values and exposure
estimates for all cosmetic product categories. Only for the most common categories are
default values provided. For all other cosmetic product categories, the individual companies
and/or the qualified safety assessors need to make a case-by-case assessment of the daily
exposure level and/or the frequency of application. Exposure values, frequency of application
and other relevant information for individual cosmetic product categories can be found in
Appendix 7.
For sunscreen products, an application of 18.0 g/d is used in the MoS calculation (see also
3-6.4).
3-3.4.2.2 CONCENTRATIONS
As parameter values for concentration, the maximal allowed levels need to be taken into
account. If different levels are allowed in different product categories, the category-specific
levels should be considered.
3-3.4.2.3 PARAMETERS SPECIFIC FOR INHALATION EXPOSURE
For spray products - both propellant and pump sprays - the relevant concentration to calculate
exposure is not the concentration in the formulation, but the concentration in the spray mist,
which can be inhaled (3-3.4.1.3). The droplet size distribution should also be considered.
Finally, according to the explanations in 3-3.4.1.3 (inhalation models), another important
parameter is the deposition rate. Deposition rates have, for example, been determined in an
International Commission Radiological Protection project (ICRP, 1994).
In Appendix 11, possible parameterization for a 2-Box inhalation model is given as an
example and needs to be adapted to the specific exposure scenario.
Taking into account the small timeframe of the calculation and large variation in room
ventilation, for a conservative estimate it should be assumed that no ventilation occurs.
3-3.4.3 AGGREGATE EXPOSURE
Aggregate exposure is obtained by aggregating (adding up) the exposures to a cosmetic
ingredient contained in several single product categories (e.g. shampoo, hand cream, etc). It
needs to be calculated when several product categories contribute. For the calculation of
LEDs, the aggregation is specific to the investigated site and if a risk assessment should be
conducted for local exposure, the cosmetic ingredient single doses need to be added up for
the specific investigated site. In the absence of a valid approach for a quantitative risk
assessment of the local effect (which is e.g. the case for skin sensitisation), the assessment
is hazard-based. If the external aggregate exposure should serve to calculate SEDs,
aggregation needs to take into account all product categories that can be taken up by a
specific route. For each route a specific aggregate external exposure needs to be provided. If
aggregation over routes is necessary, because different routes (e.g. dermal and inhalation
route) contribute, aggregation over routes needs to be calculated on the level of internal
exposure.
_____________________________________________________________________________________________
28
For aggregate dermal exposure as a first tier, the SCCS recommends to calculate the LEDs
and SEDs based on the product category-specific exposures E
product
given in Table 5. For
preservatives and other substances that are regulated with the same maximal concentrations
in all product categories, the LEDs or SEDs can be directly derived by multiplying the
aggregate E
product
with the maximal allowed concentration (Cx) by skin surface area (SSA in
cm
2
). For other cosmetic ingredients the respective E
product
needs to be multiplied with the
maximal concentration specific to the product category.
Whenever available, the values in Table 5 were taken from the E
product
presented in Table
3A. For some product categories probabilistic data were not available and for these categories
earlier information provided by Cosmetics Europe was used (Table 3B). Note, that the E
product
for the oral care products in this context is used for calculating the dermal exposure (via
mucosa) and not oral exposure. Oral exposure, if applicable, needs to be calculated
separately.
Table 5: Product exposures for the deterministic calculation of aggregate exposure for
preservatives through cosmetic use.
Note that these values can also be used for other ingredients when aggregate
exposure calculations are needed for one or more classes of cosmetic products.
Type of cosmetic
product
exposure
Product category
Daily
Exposure
E
product
Relative daily
exposure
E
product
/bw
1
(g/d)
(mg/kg bw/d)
Rinse-off
skin& hair
cleansing products
Shower gel
0.19
2.79
Hand wash soap
0.20
3.33
Shampoo
0.11
1.51
Hair conditioner
0.04
0.67
Leave on
skin& hair
cleansing products
Body lotion
7.82
123.20
Face cream
1.54
24.14
Hand cream
2.16
32.70
Deodorant non-
spray
1.50
22.08
Hair styling
0.40
5.74
Make-up
products
Liquid foundation
0.51
7.90
Make-up remover
0.50
8.33
Lipstick
0.06
0.90
Eye make-up
0.02
0.33
Mascara
0.025
0.42
Eyeliner
0.005
0.08
Oral care
Products
2
Toothpaste
0.14
2.16
Mouthwash
2.16
32.54
Aggregate
exposure
17.4
269
1. The specific bw of the persons involved in the study is used and not the default value of 60kg
2. Oral care product categories are not corrected and are presumed here to only represent dermal
exposure (mucosa)
_____________________________________________________________________________________________
29
The consumer may also be exposed to cosmetic substances through inhalation (e.g. through
spray applications) or oral exposure. These exposure routes are not considered for Tables
3A, 3B, 4 and 5 since the inhalation and oral risk is assessed on a case-by-case basis.
For CMR 1A and 1B substances, according to Art. 15d of the Cosmetic Regulation, the
consideration of aggregate exposure from all sources (including non-cosmetics) is required.
3-3.5 INTERNAL EXPOSURE
Internal exposure can either be measured in humans or calculated from external exposure
e.g. by applying route-specific absorption factors that translate the amount of substance
entering the body into the amount that is available in the bloodstream and constitutes the
dose acting on organ level. In this guidance, this dose is called the SED. There are also other
ways to calculate this internal dose, e.g. by more realistically describing the toxicokinetics
and applying different kinds of PBPK models.
3-3.5.1 TOXICOKINETICS (ADME)
The term "toxicokinetics" is used to describe the time-dependent uptake, distribution and fate
of a substance entering the body. This includes Absorption, Distribution, Metabolism and
Excretion (ADME). All of these processes need to be known to understand the fate of
substances once they come in contact with the body. The testing guidelines for toxicokinetics,
including dermal absorption (EC B.36 Toxicokinetics, EC B.44 Skin absorption: in vivo
method, EC B.45 Skin absorption: in vitro method; corresponding with OECD 417
(toxicokinetics), 427 (in vivo method), 428 (in vitro method), respectively), are designed to
elucidate particular aspects of the fate and the potential toxicity of the substance under test.
The results may assist in the design of further toxicity studies and their interpretation.
Moreover, after absorption of a substance under consideration, its metabolic transformation
and fate can have an important effect on its distribution in the body and its excretion, as well
as on the toxic potential. Therefore, in specific cases, in vivo or in vitro biotransformation
studies are required. However, the conduct and use of in vivo studies is restricted due to the
animal testing ban for cosmetic ingredients in the EU.
Apart from data on dermal absorption, further toxicokinetic data for cosmetic ingredients are
only available under certain circumstances, but their relevance may be high for extrapolating
both in vivo and in vitro animal data to the human situation.
Any route-to-route extrapolation of toxicity can be performed in a case-by-case manner based
on expert judgement of scientific information, including available toxicokinetic information. It
can, however, only be performed in the case of systemic toxicity. In this regard, not only the
degree of absorption, but also metabolism should be considered (ECHA, 2012a, 2015).
A review of the current status of toxicokinetics in the safety evaluation of cosmetics and their
ingredients can be found in several JRC reports (Adler et al., 2011, JRC Scientific and Policy
Report 2013a, 2014a, b, 2015, 2016, 2017 (more specific to toxicokinetics), 2018, 2019,
2020). At present, no validated alternative methods that completely cover the field of ADME
exist. Some in vitro models could be suitable for contributing to the assessment of the
absorption of substances from the gastro-intestinal tract (e.g. Caco-2 cell cultures) or the
biotransformation of substances (e.g. isolated hepatocytes, HepaRG™ cells, and their
cultures), but most of the existing models have not been officially validated (Adler et al.,
2011; Eskes et al., 2005; JRC Scientific and Policy Report 2013a, 2014a, 2014b, 2015, 2016,
2017, 2018, 2019, 2020).
In a limited number of cases, human toxicokinetic study results are available to the SCCS for
cosmetic ingredients, e.g. zinc pyrithione (SCCS/1512/13), cyclopentasiloxane D5
(SCCS/1549/15), phenoxyethanol (SCCS/1575/16), salicylic acid (SCCS/1602/18) and
aluminium (SCCS/1613/19). It would be a step forward to include more human toxicokinetic
_____________________________________________________________________________________________
30
studies in the dossiers of Annex substances provided that a) risk assessment cannot
adequately be performed by use of other data/methodologies and b) such human studies are
ethically acceptable.
3-3.5.1.1 DERMAL/PERCUTANEOUS ABSORPTION
Human exposure to cosmetic substances occurs mainly via the skin. In order to reach the
circulation (blood and lymph vessels), cosmetic ingredients must cross a number of cell layers
of the skin, of which the rate-determining layer is considered to be the stratum corneum.
A high number of factors influence this process, including the molecular weight, charge,
lipophilicity of the compounds, the thickness and composition of the stratum corneum (which
depends on the body site), the duration of exposure, the amount of topically applied product,
the concentration of target compounds, occlusion, vehicle, skin integrity, etc.
Recommended procedures and advice with respect to dermal absorption have been given by
several international bodies (ECETOC, 1993; US EPA, 1996a; OECD,2004; WHO, 2006; OECD,
2011a, EFSA 2017; SANTE 2018; OECD 2019). Sometimes, different terminology is used.
a. Guidelines for dermal absorption studies
Skin absorption studies can be performed in principle in vivo (OECD 427) or in vitro (OECD
428). Detailed guidance on their performance is available (OECD 2004, 2011a, OECD 2019),
although no OECD test guideline is available to describe how to conduct in vivo human dermal
absorption studies. In addition, the SCCNFP (Scientific Committee on Cosmetics and Non-
Food Products) adopted a first set of Basic Criteria for the in vitro assessment of dermal
absorption of cosmetic ingredients back in 1999 (SCCNFP/0167/99). The SCCS updated this
Opinion in 2010 (SCCS/1358/10). A combination of OECD 428 guideline with the SCCS "Basic
Criteria” (SCCS/1358/10) is considered to be essential for performing appropriate in vitro
dermal absorption studies for cosmetic ingredients.
b. The SCCS “Basic Criteria”
The purpose of in vitro dermal absorption studies of cosmetic substances is to obtain
qualitative and/or quantitative information on the compounds that may enter the systemic
compartment of the human body under in-use conditions. These amounts can then be taken
into consideration to calculate the MoS during risk characterisation.
Numerous specific parameters or working conditions need to be taken into consideration:
1) The design of the diffusion cell (technicalities and choice between static and flow through
system).
2) The choice of the receptor fluid (physiological pH, solubility and stability of chemical in
receptor fluid should be demonstrated, no interference with skin/membrane integrity,
analytical method, etc.).
3) The skin preparations should be chosen and treated with care. Human skin from an
appropriate site remains the gold standard. If not available, pig skin is an alternative
(Gerstel et al., 2016).
4) Skin integrity is of key importance and should be verified. Poor barrier quality may lead
to high dermal absorption values. Skin integrity can be measured using a variety of
methods (Guth et al., 2015, Fasano et al., 2002, Lehman et al., 2017).
5) Skin temperature has to be ascertained at normal human skin temperature.
_____________________________________________________________________________________________
31
6) The test substance has to be rigorously characterised and should correspond to the
substance that is intended to be used in the finished cosmetic products.
7) Dose and vehicle/formulation should be representative for the in-use conditions of the
intended cosmetic product including contact time. Several concentrations, including the
highest concentration of the test substance in a typical formulation, should be tested.
8) Regular sampling is required during the whole exposure period, taking into account
delayed penetration into skin layers.
9) Appropriate analytical techniques should be used. Their validity, sensitivity and detection
limits should be documented in the report.
The test compound is to be determined in all relevant compartments:
- product excess on the skin surface (dislodgeable dose),
- stratum corneum (e.g. adhesive tape strips),
- living epidermis (without stratum corneum),
- dermis,
- receptor fluid.
10) Mass balance analysis and recovery data are to be provided. The overall recovery of
test substance (including metabolites) should be within the range of 85-115%.
11) An appropriate number of controls (for in vitro studies: diffusion cells) should be used
to determine the background level. In cases where there is a high background level and
a high variability of the background level, it may be necessary to determine it for every
single donor in an appropriate number of repetitions.
12) Treatment of non-detects: if measurements are below the Limit Of Detection/ Limit Of
Quantification (LOD/LOQ) or below the background level for the calculation of
absorption, either the lower bound (zero) or upper bound (LOQ/LOD) can be used. The
choice of either upper or lower level needs to ensure that the highest possible absorption
value is calculated. Variability / validity / reproducibility of the method should be
discussed. The SCCS considers that for a reliable dermal absorption study, 8 skin
samples from at least 4 donors should be used. The absorption needs to be calculated
for each single diffusion cell and these values should be used to derive the mean
absorption. An appropriate number of repetitions should be used for each donor.
13) Radioactive labelling of the substance under consideration is often used in order to
increase sensitivity. Justification should be given for the type and site of labelling chosen
e.g. present or not in ring structure(s) or side chain(s), use of single or double labelling,
etc. This information is important with respect to the biotransformation and stability of
the compound.
14) The technical ability of the performing laboratory and the validity of the method used
should be assessed at regular intervals, at least twice per year, by using reference
compounds like caffeine or benzoic acid. These data should be included in the study
report (OECD, 2004; Van de Sandt et al., 2004).
15) Sample application in vitro should mimic human exposure, normally 1-5 mg/cm² for a
solid and up to 10 µl/cm² for liquids (OECD 428).
Exceptions may exist, e.g., oxidative hair dyes, where 20 mg/cm² are usually applied for 30-
45 minutes (depending on the intended use).
Experience has shown that in vitro measurements using less than 2 mg/cm² are not
technically feasible while the amounts of cosmetic products applied to the skin usually do not
exceed 1 mg/cm² under in-use conditions. Thus, the in vitro tests are performed with applied
amounts exceeding the intended use conditions and, if the resulting dermal absorption given
in percent of the test dose is used to calculate SED, they may result in an underestimation of
systemic exposure.
_____________________________________________________________________________________________
32
It is important to know whether the formulation can affect the bioavailability of one of its
compounds. There are many penetration enhancers and excipients (such as liposomes) that
may be specifically added to a cosmetic formulation to facilitate the dermal absorption of
certain ingredients.
It is advised to perform dermal absorption studies in the risk assessment process. In the
absence of experimentally determined dermal absorption, a 50% default value is
used. This conservative value may also be used in cases where only inadequate dermal
absorption data are available.
The amounts measured in the dermis, epidermis (without stratum corneum) and the receptor
fluid will be considered as dermally absorbed and taken into account for further calculations.
In the case of substances with very low dermal absorption and limited permeation (e.g.
colourants or UV-filters with high molecular weight and low solubility), the epidermis may be
excluded from the calculations (e.g. opinion on Polyaminopropyl Biguanide (PHMB) -
Submission III, SCCS/1581/16) when it is demonstrated that no movement of the chemicals
from the skin reservoir to the receptor fluid occurs (Yourick et al., 2004; WHO, 2006).
Adequate detection of substances that are poorly soluble in water is important in the receptor
fluid of an in vitro dermal absorption study to ascertain that the dermal absorption concerns
the active substance and not the impurities.
For nanomaterial, it is also important to ascertain whether the substance absorbed through
the skin was in nanoparticle form or in a dissolved chemical state.
Where studies correspond to all of the basic requirements of the SCCS, the mean +1SD
(Standard Deviation) will be used for the calculation of the MoS. In case of significant
deviations and/or very high variability, the mean + 2SD may be used. Where the
deviation is too high, the study is not accepted and is excluded.
Especially for substances intended to be used as UV-filters, studies have been submitted to
the SCCS using damaged skin (e.g. SCCS/1594/18; SCCS/1546/15). So far, there is no
standard protocol for the investigation of dermal absorption through damaged skin, or a
common understanding of “damaged skin” (wounded, physically damaged, sunburnt, etc.).
Therefore, the SCCS prefers study results obtained with intact skin. Information from
damaged skin can only be considered as supporting information.
It should be noted that when experimental values have been derived from a limited number
of data points (N), standard deviation is calculated using 'N'. Only in cases where the number
of data points is > 30, can 'N-1' be used.
c. Substances with very low dermal absorption
A retrospective study of the Annex substances present in the Opinions (2000-2014) of the
SCCS and its predecessors has shown that the cosmetic ingredients characterised by the
following physicochemical properties may be indicative of very low dermal absorption (Ates
et al., 2016):
- MW>500 Da,
- High degree of ionisation,
- Log P
ow
-1 or ≥ 4,
- Topological polar surface area >120 Å
2
,
- Melting point > 200°C
For dealing with data on very low dermal absorption, see Section 3-6.11.
_____________________________________________________________________________________________
33
3-3.5.1.2 ABSORPTION AFTER INGESTION
For products intended for oral use, like toothpastes and mouthwashes, inevitably some
amount will be ingested. If no experimentally derived data are provided, the SCCS will take
the conservative absorption value of 100%.
Although not officially recognised as a validated alternative method, Caco-2 cells, derived
from human colon carcinoma, have been most widely proposed as representing a cell culture
model for oral permeability screening. Given the high number of variables involved in the
complex process of intestinal absorption (Turco et al., 2011), it is of key importance to work
under well-documented and standardised conditions in order to be able to draw valid
conclusions when such in vitro models are being applied (SCCS Expert Methodologies
meeting, 2011). It is therefore necessary to report on all aspects of the experimental setup
and provide detailed information on the control of the variables. Caco-2 and similar models
indeed have a number of advantages and disadvantages (Grès et al., 1998; Le Ferrec et al.,
2001; Thomas et al., 2008; Adler et al., 2011, Fredlund et al., 2017). Great attention is
particularly required in cases where non-suitability of the in vitro model has been reported,
e.g. for highly lipophilic compounds, substances with poor absorption, substances with a
carrier-mediated transport or when first-pass metabolism is involved (Thomas et al., 2008,
Beloqui et al., 2016). Study of the predictive capacity of two in vitro cellular systems- the
Caco-2/ATCC parental cell line and the Caco-2/TC7 clone concluded that good prediction is
obtained only for highly absorbed compounds (100% correctly classified), while moderately
and poorly absorbed compounds are frequently overestimated (Prieto et al., 2010). The
model has been a subject of improvement (Shah et al., 2014, Takenaka et al., 2017, Di Marco
et al., 2017).
3-3.5.1.3 INHALATION
Cosmetic ingredients might be inhaled as gases, vapours, (liquid) aerosols or powders and
enter the respiratory tract. The physical form of the ingredient plays a decisive role in the
absorption process. Further, absorption via inhalation is governed by respiratory patterns and
the physiology of the respiratory tract, which consists of the nasopharyngeal, the
tracheobronchial and the pulmonary regions.
Gases and vapours are absorbed in the pulmonary region. However, if gases are reactive or
very water soluble, they might not reach the pulmonary region due to reaction with cell
surface components of the naso- or tracheobronchial region or due to solution into the
aqueous mucus layer of the respiratory tract (eventually followed by out-partitioning). Thus,
hydrophilic vapours/gases are more prone to be removed from the upper respiratory tract
whereas lipophilic substances are more likely to reach the deep lung. There, absorption into
the bloodstream may occur when the molecule is sufficiently lipophilic to dissolve in the
lipophilic alveolar mucus and to cross the alveolar and capillary membranes.
The rate of absorption of a gas into the circulation is governed by the blood to gas partition
coefficient (the ratio of the concentration of a chemical in blood and the concentration of the
chemical in the gas phase).
Once deposited in the lung, (partially) soluble particles dissolve (partially) in the lining fluid
(mucus layer) of the epithelium where inert particles might form non-dissolved but colloidal
suspensions. For further considerations of particle behaviour refer to the Guidance on the
Safety Assessment of Nanomaterials in Cosmetics (SCCS/1611/19).
If information on the extent of inhalation absorption is available from experimental studies
and/or physico-chemical parameters, this information is used. However, if no data are
presented, the SCCS considers that for the calculation of inhalation exposure an absorption
of 100% should be used.
_____________________________________________________________________________________________
34
3-3.5.2 DIFFERENCES IN METABOLISM FOR DIFFERENT ROUTES
3-3.5.2.1 SYSTEMIC METABOLISM
Metabolism of xenobiotic substances in mammals mainly occurs via phase I and/or phase II
reactions mediated by Xenobiotic Metabolising Enzymes (XMEs). This can also involve active
transport of substances in (Phase 0) and/or out of the cells (Phase 3). Phase I reactions such
as oxidation, reduction, hydrolysis etc. introduce functional groups into the molecule
(functionalisation). Phase II reactions render the xenobiotic substance or its metabolite(s)
more hydrophilic so that they can be better eliminated via bile or urine, by conjugation mainly
with glutathione, glucuronic acid or sulfate. In most cases, phase I metabolites that may be
reactive are also inactivated by these conjugation reactions.
Metabolism of xenobiotic substances may differ from species to species due to different
protein structures and substrate specificities of XMEs and different levels of expression and
regulation of the subfamilies of XMEs (isoenzymes) as well. These potential species
differences are in general considered in risk assessment by the use of an interspecies
default factor for toxicokinetics including metabolism (see Section 3-5.1.3). However, the
use of a fixed factor may under certain circumstances lead to errors in risk assessment if
large interspecies differences of metabolism between laboratory animals and humans are not
recognised and/or not adequately accounted for. Although such cases seem to be rare, some
well-characterised substances have been described as possessing different carcinogenic
potencies due to the different metabolisms of laboratory species compared and humans
(Oesch and Hengstler, 2014).
In mammals, expression and regulation of XMEs depend on many factors, including genetic
factors (polymorphisms), external causes (e.g., enzyme inducers or inhibitors), individual
factors such as gender, age, nutrition, health status (disease), pregnancy and several other
factors. These potential individual differences are considered in risk assessment by the use
of an intraspecies default factor for toxicokinetics (including metabolism) (see Section 3-
5.1). This intraspecies factor may need to be adapted if substance-specific information is
available (e.g., human XME polymorphisms).
In general, metabolic capacity of XMEs in mammalian liver is much higher than in extra-
hepatic tissues including skin, when based on metabolic capacity per gram of tissue. In
addition to quantitative differences in metabolic capacity there are also major differences in
the constitutive expression and regulation of XMEs between mammalian liver and extra-
hepatic tissues including skin (Oesch et al., 2007; Gundert-Remy et al., 2014; Oesch et al.,
2014.Therefore, in some cases, when an XME isoenzyme form is not active in rodent liver
such as human N-acetyltransferase 1 (NAT1), extrahepatic metabolism including skin may
qualitatively differ from that in the liver (e.g., hair dyes p-Phenylenediamine (A7)
SCCS/1443/11 and 6-Amino-m-cresol (A75) SCCS/1400/11).
Although data on systemic or dermal metabolism is not a regular requirement for SCCS safety
evaluation, such data is helpful and sometimes required to complete the toxicity profile of a
cosmetic ingredient.
Data on metabolism of a substance is primarily obtained by in vitro or ex vivo methods using
cellular or tissue materials from laboratory animals and increasingly from human sources.
Much progress has been made during the last years in preserving metabolic capacity and
regulation of XMEs in cells in culture, for instance by developing 3D-cultivation techniques.
At present, these methods are still under development (Anton et al., 2015; Baptista et al.,
2016; Fang and Eglen, 2017; Chen et al., 2018).
Extrapolation from in vitro metabolism data to the in vivo situation may be difficult although
some progress has been made, in particular in combination with Physiologically Based
PharmacoKinetic (PBPK) modelling (Coecke et al., 2013; Wilk-Zasadna et al., 2014; see also
Section 3-3.5.3). Often, in vivo data from laboratory animals, or even more from humans, is
helpful or even indispensable in order to clarify if or to which extent relevant metabolites are
formed (see OECD 417 on toxicokinetics).
_____________________________________________________________________________________________
35
Because of the species differences of XMEs, human in vivo data are the gold standard,
however, it should be considered as the last resort and in view of the Memorandum on the
use of human data (SCCS/1576/15).
3-3.5.2.2 DERMAL METABOLISM
Skin is both a physical and a biochemical barrier to the absorption of chemicals, micro-
organisms and particulate materials. Besides the role of the stratum corneum as the most
critical structure with a barrier function, there is growing evidence that XMEs may have
physiological functions in addition to defence of xenobiotic substances. Hence, constitutive
expression and regulation (induction) of XMEs is tissue-specific, also in skin. Most of the major
enzymes found in the liver may also be present in the skin but often at lower activity levels.
Phase II reactions in skin apparently play a greater role than phase I reactions of which the
metabolic capacity is considered very low. It is plausible to assume that the role of phase II
enzymes in skin is primarily to inactivate exogenous substances, thus supporting the barrier
function of skin (Oesch et al., 2007; SCCP/1171/08; Oesch et al., 2014; Gundert-Remy et
al., 2014; Kazem et al., 2019).
There are examples that only small percentages of substances are metabolised in skin. On
the other hand, in some cases nearly complete biotransformation during dermal absorption
was observed. Whereas the fate of chemicals in the skin with regard to the type and degree
of metabolism was considered a matter of uncertainty (SCCP/1171/08), much progress has
been made in the characterisation of XMEs in human skin and cutaneous metabolism,
including the metabolic competence of cutaneous cell types, such as keratinocytes and
dendritic cells. Moreover, the development and metabolic characterisation of in vitro skin
models has made progress. The comparison of XME activities of native human skin, 2D- and
3D-models (e.g. EpiDerm
TM
and SkinEthic
TM
Reconstructed human Epidermis (RhE) models)
and monolayer cultures of HaCaT cells showed promising similarities (Hewitt et al., 2013;
Oesch et al., 2014; Wiegand et al. 2014; Kazem et al., 2019). These models are now well-
established, but additional work is still necessary as none of these skin models has yet been
officially validated for metabolism.
These skin models may help in the future to clarify important questions e.g. oxidative bio-
activation of prohaptens to haptens (Bergström et al., 2007; Karlberg et al., 2008, 2013,
SCCS/1459/11, Urbisch et al., 2015 and 2016).
3-3.5.2.3 LUNG METABOLISM
The lung is a complex organ comprised of anatomically different parts (trachea, bronchi,
bronchioli and lung alveoli) accommodating a large number of different cell types which might
contribute to xenobiotic metabolism. As in skin, the expression of xenobiotic metabolizing
enzymes in the lungs is lower compared to liver. Nevertheless, there are certain metabolising
enzymes which are preferentially expressed in the lung (e.g. CYP2A13, CYP2F1). Both
functionalising and conjugating enzymes have been identified mainly in bronchiolar
epithelium but also in pneumocytes, alveolar macrophages, Clara cells, respiratory epithelium
and serous cells.Cytochrome P450 (CYP) enzymes involved in xenobiotic metabolism have
been identified in lung tissues from different species including humans (overview, Gundert et
al., 2014; Oesch et al., 2019).
They can vary considerably between humans. Amongst conjugating enzymes, Glutathione S-
Transferases (GSTs), Uridine diphosphate GlucuronosylTransferases (UGTs) and arylamine-
N-AcetylTransferases (NATs) have been identified, as well as, partially, their local distribution
in the lung. Other enzymes present in lung are epoxide hydrolases and certain transporters
suc as Multidrug Resistance Proteins (MDR1 and MRP1) or Breast Cancer Resistance Protein
(BCRP) (Gundert-Remy et al., 2014).
_____________________________________________________________________________________________
36
3-3.5.3 PBPK MODELLING
PBPK models are quantitative descriptions of the Absorption, Distribution, Metabolism and
Excretion (ADME) of chemicals in biota, based on interrelationships among key physiological,
biochemical and physicochemical determinants of these processes (WHO, 2010).
These models are not only used to translate external exposures into an internal (target)
dose in the body, but are also developed to help with:
Intra- and interspecies extrapolation (variability issues)
Route-to-route extrapolation
Dose extrapolation
Replacement of default assessment factors by more specific, substance-derived
factors
Physiological, anatomical, biochemical and physicochemical parameters are necessary to
build up PBPK models in which ADME processes are represented by equations and organs by
body compartments. Whereas physiological and anatomical parameters are readily available,
biochemical (e.g. metabolic rate constants) and physicochemical parameters (e.g. partition
coefficients) are substance-specific and can be measured values or estimated values (the
latter e.g. obtained by fitting processes using the PBPK model). The use of estimated values
in further modelling might, however, increase uncertainties associated with a model.
The PBPK model should be capable of predicting the observed basic pharmacokinetics of the
chemical (parent compounds or metabolites) before the model can be used for simulations of
specific scenarios. Moreover, the acceptable prediction of dose metric should follow the
acceptance criteria as indicated in the World Health Organisation (WHO) guidance (IPCS,
2010), i.e. the ratio between simulated and observed data should be on average within a
factor of 2. If the ratio between simulated and observed data (parent compounds and/or
metabolites) is not within a factor of 2, it will be necessary to refine and update the model
with further ADME data.
If a metabolic scheme is available, evaluation on how well the model describes the respective
metabolic/biochemical processes (number of metabolites, metabolites tree) should be
performed.
Sensitivity analysis is an important component of model verification, especially for
uncertain parameters with a high potential to influence the outcome of the simulation. A
sensitivity analysis needs to be performed for all parameters. It provides a quantitative
evaluation of how input parameters influence the dose metrics or other model output of
relevance to the risk assessment, or to the problem as defined at the beginning (WHO/IPCS,
2010).
Note that: Sensitivity analysis results are expressed as absolute values of a normalised
coefficient and are:
High: ≥ 0.5
Medium: 0.2 ≤ medium< 0.5
Low: 0.1 low< 0.2
Uncertainty analysis must be performed by the Applicant. It evaluates the impact of the
lack of precise knowledge of parameter values and model structure on dose metric simulations
(WHO/IPCS, 2010). For parsimony, uncertainty analysis could be limited to the parameters
identified through the sensitivity analysis as the ones that have the highest likelihood to affect
the result of the model calculations.
The notion of uncertainty encompasses both true uncertainty (i.e. in model parameter value)
and variability (i.e. from population variability). Variability refers to inherent heterogeneity
that is distributed within a defined population, such as body weight. In contrast, true
uncertainty refers to a parameter that has a single value, which cannot be known with
precision due to measurement or estimation error, such as partition coefficient.
_____________________________________________________________________________________________
37
The level of uncertainty is determined based on the ratio of the 95th Percentile (P95) over
the median value (P50) for the selected dose metric i.e., Area Under the Curve (AUC),
Maximum Concentration (Cmax), etc.
Uncertainty analysis results are either summarised as having a high uncertainty (value could
be a factor of 2 or higher); a medium uncertainty (value could be a factor between 0.3 and
2) or a low uncertainty (value could be a factor of 0.3 or lower).
The outcome of sensitivity and uncertainty analyses might inform the reliability of a model to
provide dose metric predictions of use in risk assessment, as illustrated in Figure 3
(WHO/IPCS, 2010).
Figure 3: Illustration of the role of sensitivity and uncertainty analyses in determining the
reliability of PBPK model predictions of dose metrics for safety evaluation (WHO/IPCS, 2010)
Note that uncertainty and sensitivity analysis are generally necessary for any type of model
calculation.
The reliability of the model predictions of dose metrics for the safety evaluation, where
feasible, are based on the level of sensitivity of the predictions to the model parameters and
the level of uncertainty of the parameter values.
If the highly sensitive parameters are also the ones that are highly uncertain, then the
reliability of the model would be questionable (WHO/IPCS, 2010).
When estimated data from PBPK models are submitted to SCCS which are intended to be
used for MoS calculation, i.e. for quantitative safety evaluation, then it should also be
demonstrated that the model correctly predicts experimental data that have not been used
to build the model, preferably in the form of a peer-reviewed publication. Further, all
equations - input parameters and information about software used should be provided
preferably in a tabular form.
In conclusion, SCCS will use data from PBPK models for quantitative risk assessment only if
sufficient details (see below) are provided so that the calculations can be evaluated.
Otherwise, the data may only be used as supporting information. In this respect, the following
are needed:
1) Model structure and characterisation that involves the development of conceptual and
mathematical descriptions of the relevant compartments of the human or animal body as
well as the exposure and metabolic pathways related to the chemical under study.
2) Model parameterisation that involves obtaining quantitative estimates of measures of the
mechanistic determinants (e.g. anatomical, physiological, physicochemical, biochemical
parameters);
3) Mathematical and computational implementation
4) Model simulation, i.e. simulation of the kinetics;
_____________________________________________________________________________________________
38
5) Model evaluation and validation that involves comparison of the a priori predictions of the
PBPK model with experimental data as well as conducting uncertainty, sensitivity and
variability analyses.
It should be noted that PBPK modelling has usually been based on experimental data, often
animal data, to build up the model. It needs to be stressed that such modelling results will
only be acceptable if data from animal tests have been used within the relevant regulatory
restrictions.
3-3.5.4 CALCULATION OF THE SYSTEMIC EXPOSURE DOSE (SED)
The SED can be calculated following different tiers. In a first tier, the SED is calculated
deterministically from the first tier conservative external exposure estimates by multiplication
with a conservative point value for the absorption fraction. Normally, the major route of
exposure will be via the skin. Therefore, the following equations specifically treat the
calculation of first tier exposure via skin but can be adapted for other routes accordingly.
Higher tier calculation of the SED can be derived e.g. from external exposure distributions
derived with probabilistic models (see Section 3-3.4).
Calculations of the SED
There are two ways of calculating the SED, depending on the way the dermal absorption of a
compound is reported:
-it is preferably based on the absolute amount bioavailable (µg/cm²) after a certain time
period, based on the highest anticipated concentration. In that case, the default value of
involved SSA needs to be known per product type (see Table 4 in Section 3-3.4.2) to
estimate the systemic availability of the substance.
-it may also be based on the percentage dermally absorbed. This depends on the amount
of finished product applied on the skin (see Table 3A and Table 3B in Section 3-3.4.2 for
default values per product type).
1) Dermal absorption of test substance reported in µg/cm²:
For calculating the SED (5), the skin surface has to be taken into account that should
be treated with the finished cosmetic product containing the substance under study, as
well as the frequency of product application per day. All other variables should have
been taken into consideration in the proper design of the dermal absorption study itself
(SCCP/0970/06).
(5)
Where:
SED (mg/kg bw/d)
Systemic Exposure Dose
DA
a
(µg /cm
2
)
Dermal Absorption as amount per surface, resulting
from an assay under in-use mimicking conditions
SSA (cm
2
)
Skin Surface Area expected to be treated with the
finished cosmetic product (see Table 4 in Section
SED = DAa x 10
-3
x SSA x f
appl
60kg
_____________________________________________________________________________________________
39
3-3.4.2 for SSA values per product type)
f
appl
(day
-1
)
Frequency of application of the finished product
bw (kg bw)
human body weight (default value: 60 kg)
2) Dermal absorption reported as a percentage of the amount of substance applied (6):
It is clear that the percentage of dermal absorption will only be of value when calculated
from in vitro studies with doses, concentrations and amounts mimicking, but not
exceeding the intended use conditions. Otherwise, the studies may result in an
underestimation of the penetration.
(6)
Where:
SED (mg/kg bw/day) Systemic Exposure Dose
E
product
(mg/kg bw/day) Estimated daily exposure to a cosmetic product per kg
body weight, based upon the amount applied and the
frequency of application (for calculated relative daily
exposure levels for different cosmetic product types,
Tables 3A and 3B, Section 3-3.4.2).
C (%) Concentration of the substance under study in the finished
cosmetic product on the application site
DA
p
(%) Dermal Absorption expressed as a percentage of the test
dose assumed to be applied in real-life conditions
If the actual number of applications differs from the standard application frequency assumed
for deriving the default values in Tables 3A and 3B, the SED for the respective product
category will have to be adapted accordingly.
3-3.5.4.1 CALCULATION OF THE INHALATION SED (SEDINH)
Inhalation can occur after volatilisation of a dermally applied substance or after spraying a
pump or propellant spray.
For calculating inhalation exposure to a substance after volatilization (7), the daily product
exposure can be multiplied by the substance concentration and a suitable, conservative
evaporating fraction (the worst-case parameter value for SED
inh
would be 1).
(7)
Inhalation exposure after spraying can be calculated by assuming instant release in a defined
box (1-Box model) or a 2-Box model according to (for calculations for the 1-Box model a
inh-2
is zero):
C DA
p
SED = E
product
x x
100 100
SED
inh
= E
product
x C x f
evap
100
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40
By using a 2-Box model the SED
inh
can be calculated according to the equations (8-10) below
(adapted from Rothe et al., 2011). For possible parameterization see Appendix 11.
SED
inh
= (a
inh-1
+ a
inh-2
) x f
ret
x f
resp
x f
appl
/bw (8)
a
inh-1,inh-2
= a
expo
x r
inh
x t
1,2
/ V
1,2
(9)
a
expo
= a
product
x C
product
x f
air
(10)
With
SED
inh
(mg/kg bw/d) systemic exposure dose from inhalation exposure
a
inh-1, inh-2
(mg) potential substance amount inhaled during boxes 1 or 2 with V
1,2
, resp.
f
ret
fraction of substance retention in the lung (inhaled exhaled)
f
resp
respirable fraction (different for pump and propellant sprays)
f
appl
(day
-1
) frequency of application
bw (kg) bodyweight
t
1,2
(min) duration of exposure in Box 1 or 2, respectively
V
1,2
(L) volume of Box 1 or 2, respectively
a
expo
(mg) amount of substance available for inhalation
r
inh
(L/min) inhalation rate
a
product
(g) sprayed amount of product
C
product
(mg/g) concentration of substance in the product
f
air
air-borne fraction
For the calculation of EA, the effective concentration of substance in the product should be
used by treating the propellant gas as part of the product. Otherwise the propellant fraction
can be accounted for as proposed by Rothe et al., 2011.
3-3.5.5 AGGREGATION OF THE SYSTEMIC DOSE
If all product categories have the same uptake rate or fraction, the aggregated SED can be
calculated by multiplying the route-specific aggregate external exposure with this uptake rate
or fraction. If some product categories are taken up at a different rate than the others, the
single external exposures need to be multiplied with the specific uptake rates, and then
aggregated.
If aggregation should be done over routes, the route specific SEDs can be added up. In some
cases (like e.g. when metabolism is different for the different routes), a PBPK model needs
to be applied for aggregating over routes.
3-3.5.6 HUMAN BIOMONITORING
In most risk assessment frameworks for chemicals, the default approach to calculate
exposure is to assess intake from different sources and different routes of exposure. Different
sources and routes are often assessed separately without aggregating exposure. This
approach includes various uncertainties and depending on the scope of the assessment may
over- or underestimate the real uptake. Overestimation may result from combining several
conservative parameters in a deterministic assessment, whereas real-life exposure may be
underestimated by not taking into account all relevant sources.
Human BioMonitoring (HBM) is therefore an important tool to survey the real life internal
exposure of humans resulting from ‘total’ exposure to chemicals via different routes (lung,
skin, digestive tract). By providing more accurate data on actual internal exposure, inclusion
of HBM data could improve human health risk assessment to consumer products for both the
general population (exposure via air, consumer products, drinking water and food) as well as
_____________________________________________________________________________________________
41
for workers (exposure via inhalation and/or skin), separately, or as part of the population
(Santonen, 2018).
3-3.5.6.1 DEFINITION
HBM is a systematic, continuous, or repetitive collection of biological samples for analysis of
chemical substances, metabolites or specific non-adverse biological effects to assess
exposure and health risk of exposed subjects, comparing the data observed with reference
levels and, if necessary, leading to interventions (Zielhuis, 1984).
For the assessment of non-adverse biological effects the term "Effect-Monitoring" is also used.
3-3.5.6.2 FIELDS OF APPLICATION
Besides the use of HBM for exposure assessment, population based HBM has emerged to
investigate the possible association between internal exposure to certain substances and
human health status and trends of exposure over time.
For cosmetic ingredients, the risk of systemic effects is largely determined by skin absorption,
which can be measured in vitro (OECD 428) (Section 3-3.5.1.1 In case of uncharged small-
size lipophilic substances, there may be a significant absorption, which may be a cause of
concern for low-dose biologically active molecules. In that situation, studies measuring the
unchanged compound or its metabolite in urine or blood of volunteers may be valuable. For
aggregate exposure, biomonitoring data may be useful to estimate the internal dose of
exposure resulting from different sources and routes of exposure (CMRs, Section 3-6.6).
These studies may provide an accurate estimate of the systemic effective dose in humans
under in-use conditions. Quantification by using biomarkers of exposure is increasingly used
to provide an integrated measure of a person’s multiple chemical-specific exposures.
Pharmacokinetics should also be taken into account (e.g. non-persistent, semi-volatile
chemicals are metabolised quickly).
It is difficult with HBM to determine the contribution of a specific source (e.g. exposure to a
substance in a cosmetic product) to the overall measured internal dose of exposure when
other (non-cosmetic) sources for uptake and exposure also contribute considerably to the
overall exposure. In such a case, HBM data and aggregate exposure modelling could support
each other in risk assessment. Aggregate exposure modelling serves to determine the
relative contribution of a product to the overall exposure, whereas HBM serves to evaluate
whether the model over- or underestimates the real exposure. Back-calculation from
biomonitoring data to external exposure data is possible but this requires additional
information (e.g., toxicokinetic data in humans).
HBM data may also provide insight into the biotransformation and elimination of the
substance in humans i.e. toxicokinetic aspects that with the ban of animal studies will be
increasingly difficult to document. If adequately applied (i.e. toxicokinetics and metabolism
of a substance are taken into account), HBM data can support and complement information
on all aspects of ADME of a cosmetic substance, which are addressed in the safety evaluation
dossier. HBM may also complement the results of further in vitro methods and animal studies,
which are usually used for exposure assessment and for risk assessment.
Especially in view of the prohibition of in vivo animal studies on cosmetic substances, HBM
makes it possible support risk assessment by providing in vivo information, also directly in
humans without the need for interspecies extrapolation, or the limitation of a small number
of subjects involved in human volunteer studies. If sufficient experimental animal data are
available, interspecies variation between animals and humans can also be addressed using
HBM.
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42
3-4 RELEVANT TOXICOLOGICAL TOOLS FOR THE SAFETY EVALUATION OF
COSMETIC INGREDIENTS
The SCCS has been closely following the progress made with regard to the development and
validation of alternative methods and updated its NoG on a regular basis taking progress into
consideration.
Besides validated alternatives, the SCCS may also accept, on a case-by-case basis, methods
that are scientifically valid as new tools (e.g., -omics” technology) for the safety evaluation
of cosmetic substances. Such valid methods may not have necessarily gone through the
complete validation process, but the Committee may consider them acceptable when there is
a sufficient amount of experimental data proving relevance and reliability and including
positive and negative controls.
According to the Cosmetics Regulation, the experimental studies have to be carried out in
accordance with the principles of Good Laboratory Practice (GLP)laid down in Council Directive
87/18/EEC. All possible deviations from this set of rules should be explained and scientifically
justified (SCCNFP/0633/02).
3-4.1 NEW APPROACH METHODOLOGY (NAM) AND NEXT-GENERATION RISK
ASSESSMENT (NGRA)
Whereas the terminology of Alternative Test Methods (ATMs)” does not cover all available
tools e.g., in silico methodology, the more general term, New Approach Methodology (NAM)
has been introduced. As for cosmetics and their ingredients, testing and marketing bans apply
with respect to animal use and also the obligation exists to only use validated replacement
alternatives, the need for validated non-animal alternative methods for chemical hazard
assessment is much more important in Europe for compliance with the Cosmetics Regulation
than for other regulatory frameworks. NAMs may include in vitro, ex vivo, in chemico and in
silico methods, read-across, as well as combinations thereof. Therefore, before any testing is
carried out for safety evaluation, all information on the substance under consideration should
be gathered from different available means. A set of criteria, universal across initiatives, to
evaluate NAMs fit-for-purpose was developed by a multi-stakeholder group and may support
greater consistency across different initiatives (Parish et al., 2020).
Many efforts are ongoing to modernise toxicological safety evaluation and to look for non-
animal methodology that can be used for the risk assessment of compounds that after long-
term exposure could be at the origin of systemic toxicity. One of these approaches is referred
to as NGRA (USEPA, 2014). The principles underpinning the application of an NGRA to
cosmetics have been defined by the International Cooperation on Cosmetics Regulation
(ICCR), a platform of regulators and cosmetics industry from the EU, the US, Japan, Canada
and Brazil (Dent et al., 2018). NGRA is a human-relevant, exposure-led, hypothesis-driven
risk assessment designed to prevent harm. It integrates several NAMs to deliver safety
decisions relevant to human health without the use of experimental animals. An NGRA should
be conducted using a tiered and iterative approach, following an appropriate literature search
and evaluation of the available data, and using robust and relevant methods and strategies.
Given the novelty of NGRA and the current lack of regulatory guidance on the use of a variety
of NAMs in decision-making, it is important that the assessment should be transparently
documented and explicit about the logic of the approach and sources of uncertainty (Dent et
al., 2018). A general NGRA workflow is described in Figure 5 (Berggren et al., 2017). The
tools useful for safety evaluation of cosmetic ingredients, which could also be used in case
NGRA would be taken as a possible workflow in the future, are described in chapters 3-4.2 to
3-4.14. Treshold of Toxicological Concern (TTC) and internal TTC (iTTC) approaches as a risk
assessment tools are described in 3-5.2.
_____________________________________________________________________________________________
43
The Methodology Working Group of the SCCS organised a workshop in February 2019 to
discuss the key issues with regard to the use of NAMs for the safety evaluation of cosmetic
ingredients (Rogiers et al., 2020). The aim was to progress from concept to the practical use
of NGRA with focus on systemic toxicity. The already existing NGRA for skin sensitisation
was not covered in the workshop. The progress made in this field is taken up under 3-4.7.2.
Several case studies were presented showing the feasibility of conducting NGRA for systemic
effects of cosmetic ingredients e.g. coumarin in face cream and body lotion (Baltazar et al.,
2020), highlighting some critical aspects such as the need for sufficient biological coverage
in terms of the mechanisms of action and cell types used, and the presence of a clear tiered
workflow. Physiologically based kinetic (PBK) modelling and characterisation of some stress
pathways involved were hereby applied (Moxon et al., 2020; Hatherell et al., 2020). Other
examples given were parabens (EU-ToxRisk project under Horizon 2020) and the hair dye 2-
methyl-1,4-benzenediamine (Goebel et al., 2014). The conclusion was that progress was
clearly made, but that more examples were needed to create confidence that NGRA is
protective, also for new compounds (Rogiers et al., 2020).
As NGRA for cosmetic ingredients does not try to predict toxicity thresholds, but rather looks
for a safe concentration of an ingredient in a particular product, the question of how to prevent
off-target toxicity was posed in a Cosmetics Europe Workshop on safety pharmacology
screening for cosmetic relevant chemicals, which took place 21-22 November 2020. The
initiative was taken to discuss whether secundary pharmacology”, as used by the
pharmaceutical industry in early drug development of lead compounds, using a relatively
limited panel including transporters, ion channels, enzymes, nuclear receptors, etc., could
be explored for its utility for cosmetic ingredients. It could open additional ways to create
trust in the NGRA approach of safety evaluation. More meetings will follow. The cosmetic
industry will use the term “pharmacology profiling”.
A number of case studies outside the cosmetic field, in which NGRA was applied, have been
published. This was done for the hazard characterization of the triazole fungicides (Van der
Ven et al., 2020) and the industrial chemical benzene (Luijten et al., 2020). For the
assessment of genomic damage of substances in general, a conceptual framework for a next
generation testing strategy was made available (Dearfield et al., 2017).
_____________________________________________________________________________________________
44
Fig. 5. Framework of the New Generation Risk Assessment (NGRA) (adopted from Berggren
et al.,2017 and Dent et al., 2018).TTC:Threshold of Toxicological Concern; MoA:Mode of Action.
Copyright from Elsevier, first published in Computational Toxicology, 4, 2017.
3-4.2 ADVERSE OUTCOME PATHWAY (AOP)
An AOP is an analytical construct that describes a sequential chain of causally linked key
events at different levels of biological organisation that lead to an adverse health or
ecotoxicological effect. An AOP starts with a Molecular Initiating Event (MIE), which is the
chemically induced perturbation of a biological system at the molecular level that eventually
leads to a specific adverse outcome. The MIE triggers a sequence of Key Events (KEs) that
occur at the cellular or organ level and are causally linked to the adverse outcome. The AOP
framework has been taken up by the OECD, providing a website to follow new developments
on this subject (https://aopwiki.org/). OECD 2017a, 2018 give guidance on how to document,
present and assess the relevance and adequacy of an AOP. The AOP concept has been applied
to a number of human-relevant toxicological endpoints including skin sensitisation (OECD,
2012b) (see Section 3-4.7). The quantitative aspect is, however, still a weak point or even
absent.
AOPs can be used to support the development of Integrated Approaches to Testing and
Assessment (IATA) and Defined Approaches (DA) (OECD 2012b, 2014b, 2017a, 2017b;
Tollefsen et al., 2014).
An IATA is a pragmatic approach that exploits and weighs existing information, including
human data and exposure information, alternative methodologies, such as in chemico and in
vitro assays, and tailored strategies for the purpose of chemical evaluation with applications
in risk assessment (Tollefsen et al., 2014; Patlewicz et al., 2015). While IATAs provide a
platform for data integration and a means for targeted testing for a specific purpose, it is not
necessarily framed by a mechanistic rationale. AOPs could be used to provide this mechanistic
basis and thus to identify data gaps or to contextualise a diverse range of existing data
(Tollefsen et al., 2014; Delrue et al., 2016: OECD 2017b; Sakuratani et al., 2018).
_____________________________________________________________________________________________
45
A DA consists of a fixed-data interpretation procedure applied to data generated with a
defined set of information sources to derive a result that can either be used on its own, or
together with other information sources within an IATA, to satisfy a specific regulatory need
(OECD, 2017b).
3-4.3 IN SILICO ASSESSMENT OF TOXICOLOGICAL HAZARD
In the absence of a recourse to in vivo testing, various in silico methods can offer a rapid,
cost-effective, and ethical approach for estimating the toxicological hazard of a cosmetic
ingredient The in silico models and tools are based on principles, rules and structural alerts
that have been derived from the relationship(s) between chemical structure and toxicity of a
group of related substances.
The field of in silico toxicology has undergone a lot of scientific developments over the past
few decades with the availability of large property/effect databases, powerful data-mining
tools, diverse statistical algorithms and soft-computing techniques. These include predictive
computational models based on Structure-Activity Relationship (SAR) and Quantitative
Structure-Activity Relationship (QSAR), as well as computational tools for read-across of data
from structurally or functionally similar substances to a target (untested) substance. This has
also led to the development of hybrid models that derive toxicity estimates from a
combination of knowledge-based rules and statistically derived models (Benfenati, 2012).
A number of toxicity expert systems are also available that are based on a combination of
structure-activity rules, structural alerts, and/or (Q)SAR models (see below). A number of in
silico models and tools is currently available that cover a wide variety of chemical types and
many of the key toxicological endpoints that are required for risk assessment of chemical
substances. Out of these, those that fulfil the quality and reliability criteria, as set out by the
OECD (2014), can be considered for use in regulatory hazard/risk assessment.
3-4.3.1 IN SILICO TOXICITY MODELS
The toxicity estimates derived from a non-testing approach, such as a (Q)SAR model, can
only be as reliable as the chemical and toxicological data and the rules/algorithms used to
build it, the degree to which it was tested and validated, and depending on whether the query
substance is covered within its applicability domain (i.e. the model’s prediction space).
Because each model/system has a finite number and type of chemical structures behind it,
there will always be a limit to its applicability domain. In this regard, an in silico model/system
is only considered appropriate for regulatory use if it has been developed in accordance with
the stringent quality criteria and the validation principles laid down by the OECD in 2004
(www.oecd.org/chemicalsafety/risk-assessment/37849783.pdf). This means that a (Q)SAR
model/system not only needs to have been based on high quality chemical and toxicological
data, but it should also address a defined endpoint, be based on unambiguous rule(s)/
algorithm(s), clearly define the applicability domain, provide appropriate measures of the
goodness-of-fit, robustness and predictivity, and where possible, also provide a mechanistic
interpretation.
A few such models/systems are available in the form of both commercial and free-access
software platforms that may be considered for use in regulatory hazard/risk assessments.
The EU project ANTARES has carried out assessment of the validation characteristics of a
range of (Q)SAR models for various (eco)toxicological and environmental endpoints relevant
to data requirements under the chemical legislation REACH (Registration, Evaluation,
Authorisation and restriction of Chemicals). The project’s website (http://www.antares-
life.eu/ ) provides a list of the currently available free-access and commercial in silico models
and tools.
ECHA (2016) has published a document on how to use and report results from QSAR models.
_____________________________________________________________________________________________
46
Examples of the free-access in silico systems include
6
the OECD QSAR ToolBox that provides
a versatile suite of programs for the prediction of different toxicity endpoints based on
categorisation, (Q)SAR models, and read-across (www.oecd.org/chemicalsafety/risk-
assessment/oecd-qsar-toolbox.htm). Other examples of free-access in silico models/systems
include Hazard Evaluation Support System (HESS) for the assessment of repeated-dose
toxicity (www.nite.go.jp/en/chem/qsar/hess-e.html); and the expert systems such as Cramer
Decision Tree (Lapenna and Worth, 2011) that is based on structural alerts and expert
knowledge; the Benigni-Bossa Rule Base (Benigni et al., 2008) that is based on structural
alerts and QSARs for genotoxicity and carcinogenicity; the Toxicity Estimation Software Tool
(T.E.S.T.) that is based on an ensemble of QSAR models (www.epa.gov/chemical-
research/toxicity-estimation-software-tool-test); and the VEGA QSAR platform that is based
on (Q)SARs and other in silico tools (www.vega-qsar.eu).
The Joint Research Centre (JRC) maintains an inventory of available QSAR models
(https://eurl-ecvam.jrc.ec.europa.eu/databases/jrc-qsar-model-database).
A QSAR Model Reporting Format (QMRF) has also been developed by the JRC and EU Member
State authorities for summarising and reporting key information on QSAR models, including
the results of any validation studies. The information is structured according to the OECD
validation principles.
The ICCR has reviewed the use of in silico methods for safety evaluation of cosmetic
ingredients. The ICCR report (2014) has concluded that the current use of in silico approaches
for safety evaluation of cosmetic ingredients is largely limited to internal decision making
both at the industry and at the regulatory levels, and that they have not yet been adopted as
a mainstream alternative to testing methods.
This is because different models and systems may have been built using different datasets,
rules and/or algorithm(s), and therefore interpret chemical structures and toxicological data
in different ways. Each model/system also reflects a different level of uncertainty and
variability associated with the data used for developing it, the modelling process used, and
the differences in the applicability domains. In view of this, a high quality in silico
model/system needs to provide not only the toxicity estimates but also a measure of
uncertainty in the results.
The SCCS has published a Memorandum on the use of in silico methods for assessment of
chemical hazard (SCCS/1578/16). The memorandum has identified a number of limitations
and barriers in regard to the use of in silico models/systems in regulatory risk assessment of
chemicals. These include the fact that regulatory risk assessors use data mainly from
‘validated’ methods for risk assessment, they also consider that virtually none of the currently
available in silico models/systems carries an authoritative ‘validation’ tag. Other limitations
of in silico methods include inability of most of the free-access models/systems to make
precise estimates of the toxicity of different stereo isomers of chemical substances, inorganic
substances, and some other types of materials (e.g. nanomaterials). However, despite the
limitations in regard to official validation of in silico methods, some of the currently available
high - quality models and tools can provide additional supporting evidence that can be used
as part of the weight of evidence for risk assessment of cosmetic ingredients. The outcome
of in silico assessment can also provide useful insights to help identify a toxicological hazard
that can further guide the planning of more focused further (in vitro) testing.
3-4.3.2 READ-ACROSS
Read-across methods derive the estimates of toxicity of a query (untested) substance from
the existing data on other structurally or mechanistically ‘similar’ compounds.
A number of computational tools are available that allow the selection of closely-similar
analogues for data read-across on the basis of structure-activity principles and rules
6
Mention of any in silico model/system in this document does not constitute an approval of its quality, or
recommendation for use by the SCCS.
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47
(https://echa.europa.eu/support/registration/how-to-avoid-unnecessary-testing-on-
animals/grouping-of-substances-and-read-across).
In this regard, in silico models based on k-Nearest Neighbour (kNN) algorithm identify
analogous compounds that are most closely related to the target compound. Examples of in
silico platforms that incorporate kNN based models include VEGA and TEST. A number of
other programs have been designed specifically for read-across (Patlewicz et al., 2017).
Examples include ToxRead (www.vegahub.eu/download/toxread-download/) which also
shows chemical analogues in a graphic format, gives reasoning for relevance of the effect to
the target compound, and provides a description of the statistical importance of each rule.
The OECD toolbox also provides a means for read-across from its comprehensive databases
and/or additional datasets that can be added by the users. Similarly,
AMBIT (http://cefic-lri.org/toolbox/ambit/) and Toxmatch
(https://eurlecvam.jrc.ec.europa.eu/laboratoriesresearch/predictive_toxicology/qsar_tools/t
oxmatch) also provide useful means for identifying similar substances and read-across.
It needs to be emphasised that read-across should be carried out using appropriate
systems/tools that allow impartial selection of closely related analogues on the basis of
structure-activity based rule/algorithm. This is of utmost importance to avoid any subjective
selection and use of only a few analogues selected randomly on the basis of personal choices
or judgement.
Furthermore, the most crucial prerequisite for a reliable read-across is the appropriate
selection of similar/analogous substances. Thus, for the outcome of a read-across to be
reliable, the database used needs to be of high quality and sufficiently large to provide a
reasonable number of the analogues belonging to the same type/class and/or the mode of
action, and the in silico tool/system used needs to be transparent in terms of searching the
database for the analogues. Unlike (Q)SAR models, only a few closely related
structural/mechanistic analogues are generally sufficient for the purpose of read-across.
However, all analogues that are found within the generally accepted criteria for similarity
(appropriately ≥70% match), should be analysed and documented. The final conclusion of
read-across should be justified by expert opinion, and the exclusion of any analogue from
read-across (e.g. due to a structural or mechanistic anomaly) must be explained and justified.
In summary, whilst in silico models and read-across methods provide a useful non-testing
means for deriving estimates of toxicity of untested compounds that do not use animals, each
model can have certain limitations that can impact the reliability of the results, especially
when assessing different chemical types and toxicological endpoints. Therefore, the SCCS
considers the use of a single in silico model/system to be inadequate and recommends the
use of more than one relevant model/system to increase the reliability of the derived toxicity
estimates. Wherever possible, a combination of in chemico (e.g. grouping and other chemical
analogy approaches), in silico (e.g. QSAR models) and read-across methods should be applied
to derive estimates of toxicity before any experimental testing is considered. In the view of
the SCCS, the results of in silico toxicity assessment are more useful for hazard assessment
when they are integrated with other sources of evidence (e.g. in vitro results) into an overall
weight of evidence (WoE) (SCCS/1578/16; EFSA, 2017a). It should also be appreciated that
the use of in silico models and tools, and interpretation of the results, requires expert
judgement, appropriate documentation and justification, and therefore must not be treated
as the outcome of a ‘black box’ technology.
3-4.4 ACUTE TOXICITY
The term acute toxicity means those adverse effects occurring following oral or dermal
administration of a single dose of a substance, or multiple doses given within 24 hours, or an
inhalation exposure of 4 hours (Regulation (EC) No 1272/2008).
In light of the animal testing ban for cosmetic ingredients (see section 1 and Appendix 3),
data on acute toxicity is not mandatory for assessing the safety of cosmetic ingredients for
consumer uses. A WoE approach may be sufficient - such as justified conclusions from
_____________________________________________________________________________________________
48
chemical grouping/read-across, (Q)SAR, in vitro studies, or when accessible, repeated dose
toxicity studies.
Relative non-testing information sources on acute toxicity such as available approaches,
(Q)SAR software packages, a list of databases from where acute toxicity data may be
retrieved, can be found in ECHA-17-G-18-EN.
Some generic alternative approaches, mostly referring to read-across and physico-chemical
properties, are present in (OECD, 2017c).
If data on acute toxicity in vivo are available, these data should be provided. It should be
noted, however, that safety evaluation will be based on (sub)chronic toxicity studies.
3-4.4.1 ACUTE ORAL TOXICITY
A. NAMs
The only validated in vitro method existing at present for acute oral toxicity (EURL ECVAM
endorsed) is the 3T3 NR (Neutral Red) uptake test, applicable for non-classified chemicals,
based on a cut-off of LD50>2000 mg/kg bw (JRC, 2013). EURL ECVAM has issued
recommendations concerning the validity and limitations of this in vitro test (EURL ECVAM,
2013). An OECD acute toxicity waiver guidance document (OECD 2017c) includes, among
other criteria, the possibility to waive the acute oral toxicity study based on the results of an
alternative test or test battery, if the LD50 is predicted to be greater than 2000 mg/kg.
B. In vivo methods
The in vivo acute oral toxicity test was originally developed to classify the hazard of chemicals
based on their LD
50
value. LD
50
values are also used to trigger the labelling of compounds
with respect to acute toxicity (2008/1272/EC).
The original test method (EC B.1, OECD 401) has been replaced by alternative methods.
These are still animal tests. Therefore, results generated via these tests are only allowed
when performed before the testing and marketing bans were fully applied, or if the data were
obtained in order to be in compliance with other (non-cosmetics) legislation e.g. REACH. The
following refinement/reduction tests have been validated and consist of:
- The fixed dose method (EC B.1bis, OECD 420) abandons lethality as an endpoint and is
designed not to cause death, marked pain or distress to the animals.
- The acute toxic class method (EC B.1 tris, OECD 423) allows the determination of a
range of exposure doses where lethality is expected. The test follows a complex stepwise
dose scheme. Nevertheless, it offers, as a main and important advantage, a significant
reduction in the number of animals tested.
- The up-and-down procedure (OECD 425) allows an estimation of the LD
50
-value and
confidence intervals. The guideline significantly reduces the number of animals used.
3-4.4.2 ACUTE DERMAL TOXICITY
No validated non-animal alternatives for the in vivo acute dermal toxicity test (EC B.3,) are
currently available, however the updated OECD guideline 402 for the fixed dose procedure
is more in line with the 3R’s principles. Still, draft OECD TG 434 “Acute Dermal Toxicity, Fixed
Dose Procedure” (under drafting) uses fewer animals and less suffering.
_____________________________________________________________________________________________
49
3-4.4.3 ACUTE INHALATION TOXICITY
Currently no validated non-animal alternative exists for the replacement of the ‘in vivo’ acute
inhalation toxicity test (OECD 403). The latter was revised in 2009 (OECD 403, EC B.2).
Furthermore, a reduction and refinement method (EC B.52, OECD 436), describes the acute
toxic class method by the inhalation route. OECD 433 is a guideline of the fixed
concentration procedure by inhalation.
3-4.5 SKIN CORROSION AND SKIN IRRITATION
3-4.5.1 SKIN CORROSION
Skin corrosion is defined as irreversible damage to the skin, namely visible necrosis through
the epidermis and into the dermis, following the application of a test substance for up to 4
hours. Corrosive reactions are typified by ulcers, bleeding, bloody scabs, and, by the end of
observation at 14 days, by discolouration due to blanching of the skin, complete areas of
alopecia, and scars (EC B.4, OECD 404).
Corrosivity could occasionally occur after a manufacturing error or product misuse. A
cosmetic substance that has the intrinsic property to be corrosive is not necessarily excluded
for use in cosmetics. An example is potassium hydroxide KOH, the corrosivity of which
depends on the final concentration, the pH, the presence of "neutralising" substances, the
excipient used, the exposure route, etc.
A. NAMs
For skin corrosion testing, at present, there are three test guidelines on in vitro replacement
alternatives:
1) The Rat Skin Transcutaneous Electrical Resistance (TER) test which uses excised rat skin
as a test system and its electrical resistance as an endpoint (EC B.40, OECD 430).
2) The Reconstructed human Epidermis (RhE) Test Method which includes four validated
commercialised human skin models i.e. EpiSkin™, EpiDerm™ SCT (EPI-200), SkinEthic™
RHE and epiCS
®
(former Epidermal skin test 1000). They all consist of reconstructed
human epidermal equivalent and use cell viability as an endpoint (EC B.40bis, OECD 431).
Only the EpiSkin™ and EpiDerm™ models are included in EC B.40bis.
3) The In vitro Membrane Barrier Test Method (OECD 435), including the Corrositex
®
test
method, which has not been adopted in the European legislation.
B. In vivo methods:
The OECD 404 test is no longer allowed for cosmetics and their ingredients. Data obtained
from the in vivo skin corrosion/dermal irritation test should only be provided when already
available for a test performed before the animal testing ban or if the data were obtained for
the purpose to be in compliance with other (non-cosmetic) legislations.
3-4.5.2 SKIN IRRITATION
Dermal irritation is defined as the production of reversible damage of the skin, following the
application of a test substance for up to 4 hours (EC B.4, OECD 404).
_____________________________________________________________________________________________
50
A. NAMs
For skin irritation testing, at present, there is one test guideline on in vitro replacement
alternatives:
The Reconstructed Human Epidermis (RhE) Test Method (OECD 439) includes four
commercially available in vitro Skin Irritation Tests (SITs) which have been validated to be
used as:
- a stand-alone replacement test for in vivo skin irritation testing, or as
- a partial replacement test, within a tiered testing strategy.
These are: EpiSkin
TM
, EpiDerm
TM
SIT (EPI-200), SkinEthic
TM
RHE and LabCyte EPI-
MODEL24SIT, EpiCS, Skin
.Only the first four RhE models are included in EC B.46.
The endpoint used in the RhE test method is the cell-mediated reduction of MTT (3-(4,5)-
dimethyl-2-thiazolyl-2,5-dimethyl-2H-tetrazolium bromide). In order to obtain better
sensitivity, while maintaining similar specificity, a second endpoint, interleukin-1α (IL-1α)
production, has been suggested.
The in vitro test for skin irritation has been found useful by the SCCS for the testing of
cosmetic ingredients. However, when reducing substances, hair dyes and colourants are
present, which could interfere with the formazan colour evaluation (Lelièvre et al. 2007,
SCCS/1392/10), HLPC separation prior to quantification should be carried out
(SCCS/1392/10) for coloured and non-coloured test chemicals (Alépée et al., 2015). OECD
431 and 439 support this methodology.
OECD has developed a Guidance Document No. 203 on an IATA for skin corrosion and
irritation (OECD, 2014b). The Guidance Document has two aims: i) to propose an integrated
approach for replacing the strategy provided in the in vivo test guideline (OECD 404) and ii),
to provide consistent information on key performance characteristics of each of the individual
information sources comprising the IATA, and to provide guidance for decision making within
the approach.
B. In vivo methods:
The OECD 404 test is no longer allowed for cosmetics and their ingredients. Data obtained
from the in vivo skin corrosion/dermal irritation test should only be provided when already
available for a test performed before the animal testing ban or if the data were obtained for
the purpose to be in compliance with other (non-cosmetic) legislations.
3-4.6 SERIOUS EYE DAMAGE AND EYE IRRITATION
Serious eye damage is tissue damage in the eye, or serious deterioration of vision, following
application of a test substance to the anterior surface of the eye, which is not fully
reversible within 21 days of application (EC B.5; OECD 405).
Eye irritation is defined as the occurrence of changes in the eye following the application of a
test substance to the anterior surface of the eye, which are fully reversible within 21 days of
application (EC B.5; OECD 405).
An IATA of this endpoint is available. The evaluation of serious eye damage and eye irritation
should be carried out according to OECD Guidance (OECD 263).
A. NAMs
For serious eye damage testing and/or identification of chemicals not triggering
classification for eye irritation or serious eye damage, at present, there are five OECD
in vitro test guidelines adopted, which are subdivided in 3 groups (a, b, c). These are:
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51
a) organotypic test methods, making use of tissues obtained from slaughterhouses (OECD
2011b):
1) The Bovine Cornea Opacity Permeability (BCOP) test method measures the ability of
a test chemical to induce opacity and permeability in an isolated bovine cornea (EC
B.47; OECD 437). In 2020, TG 437 was updated to allow the use of a LaserLight-Based
Opacitometer (LLBO) next to the standard OP-KIT device that was used for opacity
measurements in the validation of the BCOP test method. Also, the list of proficiency
substances has been updated.
2) The Isolated Chicken Eye (ICE) test method evaluates the ability of a test chemical to
induce toxicity in an enucleated chicken eye (EU B.48; OECD 438). Since the revision
of TG 438 (June 2018), histopathological observations may also be used as an
additional endpoint to improve the prediction of some specific products i.e. non-
extreme pH (2<pH<11.5) detergents and surfactants. A modified version of the
decision criteria for chemicals requiring classification for eye hazard has also been
included.
Both the BCOP and ICE test methods are able to identify:
(i) Chemicals that induce serious eye damage {Cat. 1 according to the United Nations
Globally Harmonised System of Classification and Labelling of Chemicals (UN GHS)
definitions}.
(ii) Chemicals that do not require classification for eye irritation or serious eye
damage (No Category according to UN GHS definitions).
Two other organotypic assays, i.e. the Isolated Rabbit Eye and Hen's Egg Test-Chorio Allantoic
Membrane (HET-CAM), have been developed but not implemented as an OECD guideline and
may be useful in providing supportive evidence (JRC 2019, JRC 2020).
b) cytotoxicity and cell function-based in vitro tests, including 2 OECD guidelines:
3) The Short Time Exposure (STE) test method uses a rabbit corneal cell line to evaluate
the eye irritation potential of a chemical by measuring its cytotoxic effect (EU B.68,
OECD 491). The STE test method can be used to identify chemicals inducing serious
eye damage (Cat. 1) and chemicals not requiring classification for eye irritation or
serious eye damage. The STE test has limitations with respect to highly volatile
chemicals and solid chemicals other than surfactants.
4) The Fluorescein Leakage (FL) test measures the toxic effects after a short exposure
time of the test substance by an increase in permeability of sodium fluorescein through
the epithelial monolayer of MDCK kidney cells cultured on permeable inserts (OECD
460). The FL test is recommended as part of a tiered-testing strategy for regulatory
classification and labelling of severe eye irritants (Cat. 1), but only for limited types of
chemicals (i.e. water-soluble substances and mixtures; strong acids and bases, cell
fixatives and highly volatile chemicals have to be excluded).
For the Cytosensor Microphysiometer (CM) test method, the regulatory acceptance
procedure has been discontinued because of lower priority.
c) reconstructed human tissue (RhT)-based test methods:
5) The Reconstructed Human Cornea-like Epithelium (RhCE) test method (EU B.69, OECD
492), evaluates the ability of a test chemical to induce cytotoxicity via the MTT assay.
The adopted TG includes the HPLC/UPLC technique for measuring the formazan
formation, for the evaluation of chemicals which may interfere with MTT-formazan
measurement by direct reduction of MTT or colour interference. RhCE models can be
used as in vitro methods to identify chemicals not requiring classification and labelling
for eye irritation or serious eye damage. Consequently, these models are not suitable
_____________________________________________________________________________________________
52
for determining the potency of eye irritancy. At present, four validated eye irritation
test (EIT) methods using commercially available RhCE models have been adopted: the
EpiOcular™ EIT, the SkinEthic
TM
Human Corneal Epithelium (HCE) EIT, the LabCyte
CORNEA-MODEL 24 EIT and the MCTT HCE
TM
EIT.
6) The Vitrigel-EIT method (OECD 494) is an in vitro assay using a hCE model fabricated
in a Collagen Vitrigel Membrane (CVM) chamber. The eye irritation potential of the test
chemical is predicted by analyzing the ability of the chemical to induce damage to the
barrier function of the hCE model via measuring relative changes in TransEpithelial
Electrical Resistance (TEER) over time. The Vitrigel-EIT method can be used to identify
chemicals not requiring classification and labelling for eye irritation or serious eye
damage within the limited applicability domain of test chemicals having pH > 5.0
(based on 2.5% weight/volume (w/v) preparation).
d) in vitro macromolecular test method, including 1 OECD guideline:
7) The Ocular Irritection
(OI) assay (OECD 496) is an acellular biochemical assay that
evaluates the ocular hazard effects of test chemicals based on the premise that eye
irritation and corneal opacity after exposure to irritating substances is the result of
perturbation or denaturation of corneal proteins. The OI assay is recommended as part of
a tiered testing strategy for solid and liquid chemicals under certain circumstances and
with specific limitations (i.e. applicable to solid and liquid chemicals whose 10% solution
dispersion (v/v or w/v as appropriate) has a pH in the range 4 pH 9.
The available replacement alternatives for serious eye damage and eye irritation testing
cannot identify any mild eye irritancy potential.
So far, neither a single in vitro assay nor a testing battery has been validated as a stand-
alone replacement for the in vivo test. Different decision trees for eye irritation were put
forward (McNamee et al., 2009), but none can identify mild, moderate or non-eye irritancy
(McNamee et al., 2009; Scott et al., 2010).
New test systems are under development using stem cells. These could generate new
alternatives for in vitro ocular toxicity testing (Aberdam et al., 2017).
B. In vivo methods
The in vivo test (OECD 405; EU B.5) has been subject to refinement and reduction measures.
It was also indicated that histopathology is an additional endpoint in ocular safety testing.
The latest update has mainly focused on the use of analgesics and anesthetics. It is the only
in vivo test method to assess the potential of a substance to cause acute serious eye damage
/ irritation.
The results from this test should be provided if already available from a test that was
performed before the animal testing ban or if data were obtained for the purpose of
compliance with other (non-cosmetic) legislations, e.g., REACH.
3-4.7 SKIN SENSITISATION
A skin sensitiser is an agent that is able to induce specific immunological reactivity after
contact with the skin and penetration into the epidermis. Once a person is sensitised,
subsequent skin exposure at a sufficiently high concentration can provoke allergic contact
dermatitis.
A. NAMs
In the last years, several NAMs have been developed, validated and regulatory accepted
(Ezendam et al., 2016; Hoffmann et al., 2018) that address different KEs of the skin
_____________________________________________________________________________________________
53
sensitisation AOP (OECD, 2012) (Figure 6) (see introductory part of Section 3-4.3). This
AOP consists of four mechanistic key events (KEs):
MIE (KE1) is the covalent binding of the chemical to proteins of the skin, leading to an
immunogenic hapten-carrier complex in the epidermis. After this key event is triggered, two
cellular events take place: keratinocyte activation (KE2) and dendritic cell activation (KE3).
Dendritic cells recognise the hapten-carrier complex and mature to migrate out of the
epidermis to the local lymph node. There, the dendritic cells present the small peptides of
the hapten-carrier complex to the T cells, leading to T cell activation and proliferation (KE4).
A pool of memory T cells is generated, ultimately leading to skin sensitisation (adverse
outcome).
Figure 6: AOP Covalent Protein binding leading to Skin Sensitisation (taken from
https://aopwiki.org/aops/40) MIE: molecular initiating event.
An overview of the NAMs for skin sensitisation that are currently included in the OECD and/or
EU test guideline program is provided in Table 6. The OECD has clustered test methods that
address the same KE of the AOP in one test guideline. Currently, NAMs are available that
address MIE (442C), KE2 (442D) and KE3 (442E). There are currently no NAMs available in
the OECD test guideline program that address KE4 (T cell activation and proliferation) (van
Vliet et al., 2018).
Several NAMs for skin sensitisation are still being developed or validated (OECD, 2017b,
Ezendam et al., 2016, Hoffmann et al., 2018) (Table 6). Three of these have been included
in the work plan for the OECD Test Guidelines: the kinetic DPRA (kDPRA), the SENS-IS and
Genomic Allergen Rapid Detection test for skin (GARDskin).
kDPRA, is a modification of the standard DPRA (OECD TG 442C). In this test method,
several concentrations of the test substance are incubated with the synthetic peptide
for several incubation times. The reaction kinetics towards a synthetic cysteine-
containing peptide is evaluated to predict the potency of the test substance (Wareing
et al., 2017). A validation study for the kDPRA has been conducted and the outcome
was submitted to the OECD in 2019 (Wareing et al., 2020).
SENS-IS uses toxicogenomic analysis on 3D reconstituted epidermis (Episkin
®
RhE)
to measure skin sensitisation potency. SENS-IS provides information on hazard as well
as potency sub-categorisation (Cottrez et al., 2015). The SENS-IS assay has been
validated in an industry-led study (Cottrez et al., 2016) and is under evaluation by
EURL-ECVAM.
GARDskin is an in vitro model that measures KE3 using gene expression profiling in
the MUTZ-3 cell line (Johansson et al., 2011, 2014). The validation study is currently
ongoing.
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54
Table 6: NAMs for the assessment of skin sensitisation
AOP KE covered
OECD test guideline/ EU
test method
Test method
MIE (KE1): covalent binding
to skin proteins
OECD 442C (2020) / EC
B.59
In chemico skin
sensitisation
Direct Peptide Reactivity
Assay (DPRA)
Amino acid Derivative
Reactivity Assay (ADRA)
KE2: keratinocyte
activation
OECD 442D (2018) / EC
B.60
In vitro Skin Sensitisation
Assays addressing the KE
on keratinocyte activation
ARE-Nrf2 Luciferase
KeratinoSens
TM
Test Method
The ARE-Nrf2 luciferase
LuSens test method
KE3: dendritic cell
activation
OECD 442E (2018) / EC
B.72
In vitro Skin Sensitisation
Assays addressing the KE
on activation of dendritic
cells.
Human Cell Line Activation
test (h-CLAT)
U937 Cell line Activation
Test
(U-SENS™)
Interleukin-8 Reporter Gene
Assay (IL8-Luc assay)
MIE: molecular initiating event; AOP: adverse outcome pathway; KE: key event
The currently available NAMs for skin sensitisation address a single key event of the AOP and
are therefore often combined in testing strategies to cover multiple key events. In addition,
individual test methods have some known technical limitations, which may lead to false-
negative results. DPRA and ADRA, for example, have no metabolic capacity and are therefore
unable to identify prohaptens, sensitisers that require metabolism to be activated. The in
vitro assays that are currently available are capable of detecting prohaptens, hence, these
cell lines do possess metabolic capacity (Patlewicz et al., 2016). For abovementioned
reasons, a single alternative method cannot be used as a stand-alone assay for hazard
identification and potency sub-categorisation of skin sensitisers. It is therefore recommended
to combine these methods and other information sources (e.g., in silico tools) in an integrated
approach, such as a DA or IATA. The skin sensitisation AOP is often used in the development
of such integrated approaches (OECD, 2017b; Ezendam et al., 2016; Kleinstreuer et al.,
2018). Different DAs have been proposed, some of them only provide a binary outcome (skin
sensitiser or not), others provide information on potency subcategory or provide a surrogate
EC3 value. For the latter, quantitative parameters of NAMs are used to predict potency.
Additional work is ongoing to determine how well these in vitro concentration response data
can be exploited in integrated approaches to accurately predict human potency.
B. In vivo methods
Three regulatory accepted in vivo laboratory animal test methods have been used to evaluate
the potential of a substance to cause skin sensitisation, the Local Lymph Node Assay (LLNA),
the Magnusson Kligman Guinea Pig Maximisation Test (GPMT) and the Buehler test (Table
7). The GPMT and Buehler tests are able to provide results on induction and elicitation; the
LLNA and its variants only address induction.
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55
Table 7: In vivo laboratory test methods for evaluation of skin sensitisation
Species
Test method
Endpoint
Guideline
Mouse
LLNA
(radioactive method)
Cellular proliferation
SI≥3
OECD 429, EC B.42
Mouse
LLNA:DA
(non-radioactive
method)
Cellular proliferation
SI≥1.8
OECD 442A, EC B.50
Mouse
LLNA: BrdU-ELISA
(non-radioactive
method)
Cellular proliferation
SI≥1.6
OECD 442B, EC B.51
Guinea pig
GPMT
Score of erythema
and swelling
OECD 406, EC B.6
Guinea pig
Buehler test
Score of erythema
and swelling
OECD 406, EC B.6
LLNA: Local Lymph Node Assay; GPMT: Guinea Pig Maximisation Test; SI: Stimulation Index
LLNA: DA: nonradiolabelled LLNA, modified by Daicel Chemical Industries
LLNA: BrdU-ELISA: nonradioactive modification of LLNA based on cell proliferation measured by 5-
Bromo-2’-deoxyUridine
As presented in SCCP/0919/05, results from animal studies can be used to categorise skin
sensitisers in three groups according to their sensitising potency: extreme, strong and
moderate. The LLNA provides dose-response data that can be used to derive an EC3 value,
which is the estimated concentration of a chemical necessary to give a 3-fold increase in
lymph node cell proliferation compared to vehicle-treated controls (SI 3). This EC3 value
is used to subcategorise skin sensitisers (Table 8) (ECB, 2002; Basketter et al., 2005).
Table 8: Potency subcategorisation of skin sensitisers
Category
EC3 value (%)
Extreme
≤0.2
Strong
>0.2 - ≤ 2
Moderate
>2
Because the guinea pig test methods often do not provide dose-response data, the
intradermal induction concentration in the GPMT and the topical induction concentration in
the Buehler test are used for subcategorisation (ECB, 2002; Basketter et al., 2005). In the
absence of LLNA data, this subcategorisation can be used as indicative for potency.
3-4.7.1 SKIN SENSITISATION QUANTITATIVE RISK ASSESSMENT (QRA)
QRA has been developed for fragrance substances, only. The basic principles of the QRA are
presented in SCCP/1153/08. It is based on the dose of a sensitising chemical, not expected
to cause induction of sensitisation (No Expected Sensitising Induction Level or NESIL), which
may be derived from animal and human data. The NESIL is adjusted by a number of
uncertainty factors (Sensitisation Assessment Factors, SAFs) in order to calculate an
Acceptable Exposure Level (AEL). In addition, a Consumer Exposure Level (CEL) is calculated.
The AEL is then compared with the CEL, whereby, for an acceptable risk, the AEL should be
greater than or equal to the CEL. Within the IDEA project (https://www.ideaproject.info/)
_____________________________________________________________________________________________
56
the QRA was further refined by including aggregate exposure assessment and revising the
SAFs.
A technical dossier describing the revised QRA (QRA 2) was submitted by the fragrance
industry to the SCCS. After evaluation of the methodology, SCCS concluded that a lot of
progress had been achieved since the initial publication of the QRA. Recently, a peer-reviewed
publication on the QRA2 methodology was published (Api et al., 2020), summarising the
progress made in this field so far. The SCCS considers that it is not yet possible to use the
QRA2 to establish a concentration at which induction of sensitisation of a fragrance is unlikely
to occur. Several aspects of the methodology are not clear and the scientific rationale behind
the methodology needs to be better described. With some revision, this could be a useful
methodology not only for safety evaluation of fragrance allergens, but potentially also for
other cosmetic ingredients. SCCS/1589/17).
In particular, in the case of new substances, post-marketing surveillance would be essential
(see also SCCS/1459/11) to monitor that their use in cosmetics does not lead to allergic
contact dermatitis in consumers, in line with the SCCS Memorandum on use of human data
(SCCS/1576/15).
3-4.7.2 NEXT-GENERATION RISK ASSESSMENT APPROACH (NGRA)
NGRA developed for systemic toxicity of cosmetic ingredients (Berggren et al., 2017, see also
Fig 5 under 3-4.1) has been used as a framework for skin sensitisation safety assessment
(Gilmour et al., 2020), taking the same principles into consideration. A tiered workflow is
applied as illustrated in Fig 7 for skin sensitisation.
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57
Fig 7: Framework for skin sensitisation safety assessment (Gilmour et al., 2020). S/NS:
safe/not safe; DA: defined approach; WoE; weight of evidence; PoD: point of departure;
RA+/RA-: risk assessment positive/negative outcome. Taken from Regulatory Toxicology and
Pharmacology, 2020, Volume 116, Gilmour et al., with permission from Elsevier.
For the SCCS, NGRA is a novel conceptual approach that offers the possibility to integrate
existing data, read-across information and NAM information in a systematic iterative
approach. Until the NGRA is assessed and accepted to be valid by the SCCS, submissions
including NGRA for skin sensitisation will be evaluated by the SCCS on a case-by-case basis.
The key aspects of NGRA for skin sensitisation can be found in the publication by Gilmour et
al., 2020.
3-4.8 REPEATED DOSE TOXICITY
Repeated dose toxicity studies are performed to investigate toxicological effects (excluding
reproductive, genotoxic and carcinogenic effects) occurring as a result of repeated daily
dosing with, or exposure to, a substance for a specific part of the expected lifespan of the
test species.
A. NAMs
No validated alternative methods are available yet for determining the repeated dose toxicity
of a substance, which poses a problem for the introduction of new compounds e.g.
preservatives on the EU market as this assay usually provides the PoD of the compound under
investigation (necessary for MoS calculation). Efforts are being made by the cosmetic industry
to develop an NGRA strategy as an alternative for not having a PoD generated via in vivo
methodology (see 3-4 and 3-4.1). The topic was extensively discussed in the February 2019
SCCS methodology workshop with the aim to progress from concept to the practical use of
NGRA with a focus on systemic toxicity (Rogiers et al., 2020). Several case studies were
presented and progress has clearly been made, but more case studies and validated NAMs
are needed to create the necessary confidence that NGRA is protective for new compounds
and that unexpected side effects are not occurring.
B. In vivo methods
The following in vivo repeated dose toxicity studies with OECD guidelines are available:
1)
Sub-acute oral toxicity (28 days) (EC B.7, OECD 407)
Sub-acute dermal toxicity study (28 days) (EC B.9, OECD 410)
Sub-acute inhalation toxicity study (28 days) (EC B.8, OECD 412)
2)
Sub-chronic oral toxicity study: repeated dose 90-day
oral toxicity study in rodents (EC B.26, OECD 408)
Sub-chronic oral toxicity study: repeated dose 90-day
oral toxicity study in non-rodents (EC B.27, OECD 409)
Sub-chronic dermal toxicity study: repeated dose 90-day
dermal toxicity study using rodent species (EC B.28, OECD 411)
Sub-chronic inhalation toxicity study: repeated dose 90-day
inhalation toxicity study using rodent species (EC B.29, OECD 413)
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58
3)
Chronic toxicity studies (primarily rodents) (EC B.30, OECD 452)
Combined chronic toxicity/carcinogenicity studies (EC B.33, OECD 453)
(primarily rodents)
In the case of the development of cosmetic ingredients that will be in contact with human
skin and mucosae repeatedly, the SCCS is convinced that evaluation of the systemic toxicity
is a key element in safety assessment.
3-4.8.1 THE USE OF UNCERTAINTY FACTORS (UFS) FOR EXTRAPOLATION FOR STUDY DURATION
This type of UF is used to take account of probable differences between the experimental
setting from which the PoD is taken and the human real life situation (use scenario) in case
substance-specific information is lacking.
For some cosmetic ingredients, dermal repeated dose toxicity studies are submitted. These
studies, if of good quality, are taken into consideration by the SCCS as it is the most
commonly used application route for cosmetics. In practice, however, oral route studies are
often used for the MoS calculation to consider (worst case) systemic exposure. Oral repeated
dose toxicity studies can be either subacute (28 days), subchronic (90 days) or chronic
(taking 85% of lifetime).
The 90-day oral toxicity test in rodents was, historically speaking, the most commonly used
repeated dose toxicity test for cosmetic ingredients. Based on the exposure and the short
lifetime of cosmetic products (regularly changing ingredients and concentrations), the 90-day
test provides a good indication of the target organs and the type of systemic toxicity.
In case only a 28-day study is available, the SCCS recommends applying a factor to take
uncertainty into consideration to extrapolate from subacute (28 days) to subchronic (90 days)
toxicity. Different values are being proposed and the choice is made on a case-by-case basis
taking the strengths and weaknesses of the available studies into consideration. The SCCS
commonly uses for such extrapolation a conservative UF of 3. Recently, Escher et al. (2020)
provided data showing that in such a case a factor of 1.5 would be sufficient.
When a scientifically sound 90-day study is available which allows for the determination of a
clear PoD, the SCCS takes this study into account for calculating the MoS. An uncertainty
factor is only included when some doubt exists with respect to the quality of the subchronic
toxicity study and/or in the absence of further information supporting the PoD from the 90-
day study (e.g. availability of a chronic study). Escher et al. (2020) proposed a factor of 1.5.
In other domains (environmental, food, …) higher factors have been proposed, but these may
contribute to a higher variance. In any case, the use of additional UFs needs to be carefully
considered. Indeed, many authors warn that a composite UF may lead to over conservatism
(Simon et al., 2016; Escher et al., 2020). In particular, in the case of aggregate exposure,
using a deterministic exposure assessment multiplication of single UFs may lead to possibly
overly conservative estimates (EFSA, 2012a).
The inhalation route was only rarely used in repeated dose toxicity testing of cosmetic
ingredients due to the lack of relevance for the majority of cosmetic products. This exposure
route is, however, important where a cosmetic ingredient is volatile or a product is intended
to be used in an aerosolised, sprayable or powdered form that could lead to exposure of the
consumer via inhalation. Because of the likelihood of high uncertainty in regard to different
inhalable products and their modes of delivery, the SCCS recommends analysis of uncertainty
on a case-by-case basis).
When reproductive toxicity studies are used to determine the PoD, the uncertainty factors for
extrapolation for study duration are not used.
In sections 3.5.1.1 and 3.5.1.2 a number of default factors are discussed.
_____________________________________________________________________________________________
59
3-4.8.2 SELECTION OF POD
In repeated dose toxicity studies, the target(s) organ(s) and critical endpoint(s) may be
identified. The critical endpoint is defined as the first (in terms of dose level) adverse effect
associated with the substance. This effect should be biologically relevant for human health
and also in the context of cosmetic exposure. For example, local effects on the gastrointestinal
tract, sometimes observed with irritants after oral exposure, are not considered relevant by
the SCCS to be used for the MoS calculation. A BMD, NOAEL or LOAEL (PoD) is then derived
for each study and the most relevant study in terms of quality, duration of exposure, and
available PoD is then selected by the SCCS to be used for the safety evaluation. If the dose
regimen of a study was limited to 5 days treatment per week, the derived PoD will be
corrected by a factor of 5/7. In analogy, a correction will also be made for longer use
periods.
3-4.9 REPRODUCTIVE TOXICITY
The term "reproductive toxicity" is used to describe the adverse effects induced (by a
substance) on any aspect of mammalian reproduction. It covers all phases of the reproductive
cycle, including impairment of male or female reproductive function or capacity and the
induction of non-heritable adverse effects in the progeny such as death, growth retardation,
structural and functional effects.
A. NAMs
No validated alternative method is yet available for reproductive toxicity that covers all
different phases of the reproductive cycle (JRC 2019, JRC 2020).
Since the field of reproductive toxicity is very complex, it is expected that the various phases
cannot be mimicked using one alternative method and that a battery of tests is needed. Three
alternative methods, restricted to the embryotoxicity area, have been developed:
The Whole Embryo Culture test (WEC)
The MicroMass test (MM)
The Embryonic Stem Cell Test (EST)
The last two tests were considered scientifically valid by the ECVAM Scientific Advisory
Committee (ESAC) for placing a substance into one of the three following categories: non-
embryotoxic, weak/moderate-embryotoxic or strong-embryotoxic. The WEC test is still an
animal test and is considered scientifically valid only for identifying strong embryotoxic
substances (ESAC, 2001).
These three tests might be useful in the CMR strategy for screening out embryotoxic
substances. However, they cannot be used for quantitative risk assessment (Marx-Stoelting
et al., 2009).
The complex endpoint of reproduction toxicity is not covered by the above systems.
Several in vitro methodologies, each covering one of the three biological components of the
reproductive cycle (male and female fertility, implantation and pre- and postnatal
development), were developed under the EU project ReProTect.
The tests reflect various toxicological mechanisms such as effects on Leydig and Sertoli cells,
folliculogenesis, germ cell maturation, motility of sperm cells, steroidogenesis, the endocrine
system, fertilisation, and on the pre-implantation embryo. Neverthless, more information and
research are needed until regulatory acceptance can be envisaged (Schenk et al., 2010).
An extensive review of the actual situation can be found in a JRC report (JRC 2019, JRC
2020). In view of the utmost importance of consumer safety, toxicological evaluation against
some complex endpoints, such as reproductive toxicity, still necessitate the use of animals.
_____________________________________________________________________________________________
60
B. In vivo methods
The most commonly performed in vivo reproductive toxicity studies are:
1) Two-generation reproductive toxicity study (EC B.35, OECD 416)
2) Prenatal developmental toxicity study
7
- rodent and non-rodent (EC B.31, OECD 414)
A "Reproduction/Developmental Toxicity Screening Test" (OECD 421) also exsits, as well as
a "Combined Repeated Dose Toxicity Study with the Reproduction/Developmental Toxicity
Screening Test" (OECD 422).
The Extended One-Generation Reproductive Toxicity Study (EOGRTS) has been adopted by
the OECD (OECD 443) and a Guidance Document has been established (OECD 2018). It offers
several advantages compared to older OECD TGs and is extensively used:
Compared to OECD TG 416 a significant number of animals can be saved.
More parameters are addressed (e.g. clinical-chemical parameters as in repeated dose
studies; developmental immunotoxicity and neurotoxicity in case such cohorts are
included). Endocrine disruption endpoints are included- (e.g., nipple retention,
anogenital distance at birth, vaginal patency and balanopreputial separation)
Increased statistical power with respect to parameters for reproductive toxicity
Possibility for modification e.g., to include new endpoints for the assessment of
endocrine active chemicals disrupting the Hypothalamus-Pituitary-Gonad (HPG) axis,
the somatotropic axis, the retinoid signalling pathway, the Hypothalamus-Pituitary-
Thyroid (HPT) axis, the vitamin D signalling pathway and the Peroxisome Proliferator-
Activated Receptor (PPAR) signalling pathway
A study report on reproductive toxicity or on prenatal developmental toxicity is in general
only acceptable when it is based on tests that have been carried out before the animal testing
ban or when generated for compliance with other (non-cosmetic) legislative frameworks; see
Appendix 1, section 3 and Appendix 4).
3-4.10 MUTAGENICITY / GENOTOXICITY
3-4.10.1 DEFINITIONS
Mutagenicity: a mutation is defined as a permanent change in the amount or structure of
the genetic material. The terms ‘mutagenic’ and ‘mutagen’ are used for agents giving rise to
an increased occurrence of mutations in populations of cells and/or organisms and applies
both to heritable genetic changes that may be manifested at the phenotypic level and to the
underlying DNA modifications (including specific base pair changes and chromosomal
aberrations).
Germ cell mutations are those that occur during spermatogenesis/ovogenesis and appear in
the egg or sperm (germ cells) and therefore can be passed on to the organism's offspring.
Somatic mutations are those that occur in cells other than the germ cells, and they cannot
be transmitted to the next generation.
Genotoxicity: the more general terms ‘genotoxic’ and ‘genotoxicity’ apply to agents or
conditions that alter the structure, information content, or segregation of DNA, including
those which cause DNA damage by interfering with normal replication processes, or which
alter its replication in a non-physiological manner (temporarily)..
7
Often also named teratogenicity test
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61
3-4.10.2 MECHANISMS
There are several mechanisms that lead to genotoxicity. In general, DNA damage can arise
through either primary or secondary mechanisms (Schins et al., 2007, Magdolenova et al.,
2014, Evans et al., 2017). Primary genotoxicity can be either direct, where there is a direct
interaction of genotoxic agent with DNA, or indirect, where the genotoxic effect is exerted via
intermediate molecules (such as free radicals, as in oxidative stress). Secondary genotoxicity
is driven by oxidative stress arising from inflammation caused by activation/recruitment of
immune cells such as macrophages or neutrophils. Where the evidence suggests indirect
mechanism (oxidative stress), or secondary mechanisms (e.g. inflammation and oxidative
stress caused by overexpression of the immune cells) - a threshold may be derived from the
toxicological data for use in safety assessment.
Based on recommendations of international groups of scientific experts (Dearfield et al.,
2011), and in accord with EFSA (EFSA, 2011a) and the UK Committee on Mutagenicity (COM,
2011), the evaluation of the potential for mutagenicity of a cosmetic substance should include
information on 1) mutagenicity at the gene level, 2) chromosome breakage and/or
rearrangements (clastogenicity), and 3) numerical chromosome aberrations (aneuploidy). For
this task, genotoxicity tests, which measure irreversible mutation endpoints (gene or
chromosome mutations) should be used. Genotoxicity Indicator tests, which measure DNA
damage without taking into account the consequences of this primary damage, can contribute
to the weight of evidence approach but should not be used as stand-alone tests. Finally,
before undertaking any testing, a thorough review should be carried out of all available data
on the substance under assessment.
A. NAMs
(i) In silico methods for genotoxicity and carcinogenicity
- Genotoxic carcinogens (DNA reactive)
As explained in the testing strategy for mutagenicity/genotoxicity (Figure 8, section 3-4.10),
the use of structure-activity relationship based in silico models and read-across can provide
a useful indication of the mutagenic/genotoxic and carcinogenic potential of a cosmetic
ingredient.
The regulatory requirements for testing certain categories of chemicals have led to a large
database on genotoxicity over the past decades, in particular on bacterial reverse mutation
(Ames) test, as well as on in vitro and in vivo micronucleus tests, and chromosomal
aberration. As a result, there is a better understanding of the mechanisms of
mutagenicity/genotoxicity via direct or indirect interaction of chemical substances with the
genetic material, compared to certain other complex toxicity endpoints.
The knowledge deciphered from the available information has indicated that the chemicals
that can cause mutagenic/genotoxic effects through direct interaction with DNA are either
intrinsically electrophilic, or they can be transformed to electrophilic intermediates. However,
some non-electrophilic chemicals may also cause genotoxic effects directly through reaction
with nucleophilic moieties of proteins and nucleic acids or through direct or indirect DNA
alkylation, acylation or adduct formation, or indirectly through generation of reactive
oxyradicals. On the other hand, some chemicals may contain one or more structural alerts
for genotoxicity but may not cause genotoxic effects because of their (higher) molecular
weight, solubility, chemical reactivity, structural geometry, etc. (Plošnik et al., 2016).
The OECD QSAR Toolbox incorporates a number of databases on mutagenicity/genotoxicity
and carcinogenicity that provide a valuable resource for read-across.
- The toolbox on in vitro genotoxicity includes bacterial mutagenicity ISSSTY; ECHA REACH;
OASIS genotoxicity; EFSA pesticide genotoxicity.
- The databases on in vivo genotoxicity include ECHA REACH; ECVAM genotoxicity and
carcinogenicity; EFSA pesticide genotoxicity; ISSMIC Micronucleus; OASIS Micronucleus,
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62
Carcinogenic Potency Database (CPDB) (http://toxnet.nlm.nih.gov/cpdb/cpdb.html)
containing data on substances derived from long-term carcinogenicity tests on chemicals in
rats, mice, dogs, hamsters and non-human primates.
- in silico methods (structure-activity based) for the prediction of carcinogenicity of chemical
substances include the open-source tools LAZAR (https://openrisknet.org/e-
infrastructure/services/110/) and (Q)SAR models such Vega (www.vegahub.eu/).
The availability of large amount of data on mutagenicity/genotoxicity and carcinogenicity has
also enabled the identification of key molecular descriptors and structural alerts associated
with mutagenicity/genotoxicity (e.g. Ashby and Tennant, 1988; Benigni and Bossa, 2008;
Plošnik et al., 2016), and the development of several structure-activity based in silico (Q)SAR
models and read-across systems. A number of these systems have been developed using
high quality data and in accordance with the OECD (2014) criteria and were subjected to
stringent assessments to verify their reliability for use in regulatory risk assessments.
- Non-genotoxic carcinogens (DNA-non reactive)
In comparison to genotoxic carcinogens, the identification of Non-Genotoxic Carcinogens
(NGCs) is much more difficult because, unlike the direct or indirect interaction of genotoxic
substances with DNA, the carcinogenic effects of NGCs may manifest from a variety of
different mechanisms, not always relevant to humans, such as:
Peroxisomal proliferation that may lead to increased cell proliferation or decreased
apoptosis; inhibition of the gap junction intercellular communication, or DNA methylation
Induction of oxidative stress that may lead to induction of oxidative stress - either due to
increased production of oxyradicals, or decreased cellular antioxidant defences resulting
in DNA damage
Induction of hormonal imbalance
Agonistic and antagonistic interaction with Aryl hydrocarbon Receptor (AhR).
NGC are thought to have a safe exposure threshold or dose; thus, their use in society is
permitted provided that the exposure or intake levels do not exceed the threshold. For these
reasons, the in silico methods for the identification of NGCs are based on a limited number of
structural alerts that have so far been identified.
Examples of available in silico systems
8
As already mentioned in section 3-4.2, the EU project ANTARES has listed the available free-
access and commercial in silico models and tools on the project website (www.antares-
life.eu/).
The notable free access in silico systems for the assessment of mutagenicity/genotoxicity and
carcinogenicity (for which more information is present in APPENDIX 10) include:
The Danish QSAR database (http://qsar.food.dtu.dk/)
The OECD QSAR Toolbox (https://qsartoolbox.org/),
VEGA QSAR platform (www.vegahub.eu/)
The US-EPA’s Toxicity Estimation Software Tool (T.E.S.T.)
(www.epa.gov/nrmrl/std/qsar/qsar.html)
Toxtree (http://toxtree.sourceforge.net/) OpenTox for carcinogenicity
(http://apps.ideaconsult.net:8080/ToxPredict)
Lazar (https://lazar.in-silico.ch/predict)
OncoLogic (US EPA) (www.epa.gov/oppt/sf/pubs/oncologic.htm)
8
The list of in silico models/systems is not exhaustive, and the mention of any model/system here does not
constitute an approval of its quality, or recommendation for use by the SCCS.
_____________________________________________________________________________________________
63
A number of commercial systems are also available for the assessment of potential
mutagenicity/genotoxicity and carcinogenicity. These include QSAR based systems such as
SciQSAR
®
(SciMatics, Inc.) and TopKat
®
(Toxicity Prediction by Komputer Assisted
Technology); molecular fragment-based QSAR expert systems such as CASE-Ultra
®
(Multicase Inc.) and Leadscope
®
(Leadscope, Inc.); and expert knowledge-based systems
such as Derek Nexus
®
(Lhasa Ltd.).
Protocols for in silico assessment of genetic toxicity have been described by Hasselgren et al.
(2019) and a number of studies have assessed the reliability of the in silico methods for the
prediction of genotoxicity and carcinogenicity. The results have generally confirmed that a
number of the in silico systems can provide a high degree of reliability for the estimation of
genotoxic potential of chemicals (Serafimova et al., 2010; Bakhtyari et al., 2013;
www.antares-life.eu/files/antares_mutagenicity_qsar2012.pdf). More recently, Honma et al.
(2019) have tested 17 QSAR tools using a proprietary Ames mutagenicity database containing
12140 new chemicals, at least 85% of which were not included in publicly available or
commercial databases and had not been used in QSAR modelling under the Ames/QSAR
International Challenge Project. Their findings indicate that most tools achieved >50%
sensitivity (positive prediction among all Ames positives) and predictive power (accuracy) as
high as 80%, which is almost equivalent to the inter-laboratory reproducibility of the Ames
tests.
These assessments point out to the potential of in silico methods and models to generate
supporting evidence on the potential mutagenicity/genotoxicity of cosmetic ingredients to
support the WoE on their safety in conjunction with other (in vitro) data. As indicated in
section 3.4.2, the estimates derived from in silico models and read-across can provide useful
additional supporting evidence for hazard assessment, especially when the results are
integrated with other sources of evidence (e.g. in vitro data) into an overall weight of evidence
(WoE) for use in risk assessment of cosmetic ingredients.
(ii) From a 3-test in vitro battery to a 2-test in vitro battery:
Evaluation of several databases has demonstrated that an increase in the number of in vitro
tests performed results in an increase of the number of ‘unexpected positives’ while the
number of ‘unexpected negatives’ decreases (Kirkland et al., 2005). The sensitivities of the
2- and 3-test batteries seem quite comparable (Kirkland et al., 2011). Moreover, the
combination of the bacterial reverse mutation test and the in vitro micronucleus test allowed
the detection of all relevant genotoxic carcinogens and in vivo genotoxicants for which data
existed in the databases that were used (Kirkland et al., 2011). Consequently, EFSA and COM
(2011) recommended the use of these 2 tests as a first step in genotoxicity testing. According
to the REACH Regulation and ECHA Guidance (2017), in order to ensure that the necessary
minimum level of information is provided, at least one further test is required in addition to
the gene mutation test in bacteria, namely: an in vitro chromosome aberration test (OECD
TG 473), or an in vitro micronucleus test (OECD TG 487) using mammalian cells. Although in
vitro chromosome aberration test is considered as a possible alternative option to the in vitro
micronucleus test under REACH, it is now generally agreed that these tests are not equivalent
since the in vitro chromosome aberration test is not optimal formeasuring numerical
chromosome aberrations.
In line with this, the SCCS recommends two tests for the base level testing of cosmetic
substances, represented by the following test systems:
Bacterial Reverse Mutation Test (OECD 471) as a test covering gene mutations. Recently,
OECD TG 471 has been revised with CAS reference numbers of strain-specific positive
controls.
In vitro Micronucleus Test (OECD 487) as a test for both structural (clastogenicity) and
numerical (aneugenicity) chromosome aberrations.
The tests should be performed according to the OECD test guidelines.
_____________________________________________________________________________________________
64
Cells should be exposed to the test substance both in the presence and absence of an
appropriate metabolic activation system. The most commonly used system is a cofactor
supplemented S9-fraction prepared from the livers of rodents (usually rat) treated with
enzyme-inducing agents such as Aroclor 1254 or a combination of phenobarbital and β-
naphthoflavone. The choice and concentration of a metabolic activation system may depend
on the class of chemical being tested. In some cases, it may be appropriate to utilise more
than one activation system. For azo dyes and diazo compounds in the gene mutation test in
bacteria, the use of a reductive metabolic activation system is recommended
(SCCS/1532/14).
In cases where the bacterial reverse mutation test is not optimal for the measurement of
nanoparticles, biocidal compounds and antibiotics, a scientific justification should be given
and a gene mutation test in mammalian cells the Hprt/Xprt (OECD 476), or the thymidine
kinase Tk (OECD 490)} should be performed.
Additionally, when testing nanomaterials, evidence is needed to show that the nanoparticles
were in contact or internalized by the test system and entered in contact with DNA. For further
considerations of particle-related behavior of substances, the Applicants should refer to
SCCS/1611/19: Guidance on the Safety Assessment of Nanomaterials in Cosmetics.
(iii) Novel in vitro approaches in genotoxicity models:
The recommendations and conclusions from the International Workshops on Genotoxicity
Testing (IWGT) (Martus et al., 2020) concerning different methods are supported by the
SCCS:
- The Ames Test:
o critical issues to be considered to bring TG 471 up to date and make it
consistent with other OECD TGs have been identified (Williams et al., 2019;
Levy et al., 2019a and 2019b).
- The Mammalian Cell Gene Mutation Assays:
o In vitro TransGenic Rodent (TGR) mutagenicity assays, once validated, could
be employed for routine mutagenicity assessment, as they have endogenous
metabolic capacity and consequent ability to generate DNA-reactive
metabolites - properties lacking in cell lines frequently employed for in vitro
testing (White et al., 2019);
o In vitro mutagenicity assays based on immortalised cell lines or primary
hepatocytes from the MutaMouse or lacZ Plasmid Mouse are at an advanced
stage of validation;
o The Phosphatidylnositol glycan class A gene (Pig-a) mutagenicity assay is at
an early stage in terms of safety testing and hazard identification (Bemis and
Heflich, 2019);
o The sensitivity of the Mammalian Cell Gene Mutation Assay can be improved
by the use of XRCC1
/−
/XPA
−/−
TK6 cells (Ibrahim et al., 2020).
- Novel & Emerging in vitro Mammalian Cell Mutagenicity Test Systems:
o genome-wide loss-of-function screening, mutation characterisation by next
generation sequencing, and fluorescence-based mutation detection can be
promising methods (Evans et al., 2019a).
- The 3D Tissues in Genotoxicity Testing (Pfuhler et al., 2020):
o 3D tissue models simulate in vivo-like conditions regarding cell viability,
proliferation, differentiation, morphology, gene and protein expression. They
can complement classical 2D cell culture-based assays;
o 3D tissue-based genotoxicity assays can be used as 2
nd
tier assays to follow-
up on positive results from standard in vitro assays;
o For adoption of a tissue model as a 2
nd
tier assay, ability to detect the full range
of genotoxic damage (leading to mutagenicity, clastogenicity, aneugenicity)
should be demonstrated;
o The 72-hour protocol for the 3D Reconstructed human Skin MicroNucleus assay
(RSMN) has higher sensitivity than the 48-hour protocol;
o The 3D skin comet and MN assays are now sufficiently validated to move
towards individual OECD Test Guidelines, but an independent peer review of
the validation study is still needed.
_____________________________________________________________________________________________
65
- High Information Content assays:
o adductomics, global transcriptional profiling, error-reduced single-molecule
sequencing, and multiplexed phenotypic profiling are promising tools for
regulatory purposes (Dertinger et al., 2019).
(iv) In vitro models for secondary genotoxicity:
A significant knowledge gap exists in regard to which in vitro system(s) might be appropriate
for assessing secondary (inflammation-driven) genotoxicity (OECD, 2014). Several in vivo-
like in vitro models addressing inflammation driven genotoxicity have been developed,
ranging from a simple conditioned medium approach (e.g. exposing THP-1 derived
macrophages and then transferring the conditioned medium to bronchial cells) to more
complex co-culture models (Evans et al., 2017, 2019b; Åkerlund et al., 2019). The most
advanced models comprising either two or more different cell types co-cultured with immune
cells have been reviewed (Evans et al., 2017) and discussed during the 7th IWGT in Japan
2017 (Pfuhler et al., 2020; Martus et al., 2020). They encompass cell-to-cell interplay, which
promotes intracellular signalling and molecular crosstalk, representing more in vivo-like
conditions.
(v) Outcome of in vitro tests
If the results from both tests are clearly negative in adequately performed tests, it is very
likely that the substance has no mutagenic potential. Likewise, if the results from both tests
are clearly positive, it is very likely that the substance has mutagenic potential. In both
cases further testing is not necessary.
If one of the two tests is positive, the substance is considered an in vitro mutagen.
Further testing is needed to exclude potential in vivo mutagenicity (and/or
clastogenicity) of the substance under investigation.
A general scheme of mutagenicity testing of cosmetic ingredients is presented in Figure 8.
Additional information on the in vitro testing can be found in COM2011.
Different and potentially contradicting results may be available from the same test when
performed with non-standardized protocols and carried out by different laboratories. In such
cases, expert judgement should be used to evaluate and interpret the data. Further tests
may be necessary to reach an overall conclusion.
Special attention should be given for poorly soluble chemicals. The determination of solubility
in the culture medium prior to the experiment is mandatory. For such substances that are
not cytotoxic at concentrations lower than the lowest insoluble concentration, the highest
concentration analysed in culture medium should produce turbidity or a precipitate visible by
eye or with the aid of an inverted microscope at the end of the treatment with the test
chemical. Even if cytotoxicity occurs above the lowest insoluble concentration, it is advisable
to test at only one concentration producing turbidity or a visible precipitate because
inaccurate effects may result from the precipitate. At the concentration producing a
precipitate, care should be taken to ensure that the precipitate does not interfere with the
conduct of the test (e.g. staining or scoring).
(vi) Toolbox for further evaluation in a WoE approach
The comet assay in mammalian cells or on 3D reconstructed human skin can support
a WoE approach in the case of a positive or equivocal bacterial or mammalian gene
mutation test. In June 2020, the 3D reconstructed human skin comet assay has been
presubmitted to EURL ECVAM for assessment. The enzyme-linked comet assay for
detection of oxidized DNA bases can be useful for identification of a genotoxicity
involving oxidative stress. Standardisation and pre-validation of the method have been
conducted recently by the hCOMET consortium (Møller et al., 2020) and the application
for an OECD test guideline is in preparation.
_____________________________________________________________________________________________
66
To evaluate a positive or equivocal result, RSMN could be considered for dermally
applied compounds. The experimental phase of the validation has been finalised
(Phfuhler et al., 2020) and the RSMN has been pre-submitted to EURL ECVAM for
assessment. Another tool is the Hen’s Egg test for Micronucleus Induction (HET-MN)
which is currently under evaluation (JRC 2019, 2020; Reisinger et al., 2019).
Negative results from these alternative tests alone might not be sufficient to overrule the
positive results from a recommended test.
Mechanistic investigations (e.g. toxicogenomics) or internal exposure (toxicokinetics)
are tools that may be helpful in a WoE evaluation. Reporter gene assays based on
human, animal or bacterial cells are tools supporting a WoE approach. Among such
tests are the Green Screen HC™ used to screen the genotoxic and cytotoxic potential
of chemicals and ToxTracker
TM
, which when combined with Vitotox (a mutagenicity
test that can be used as a surrogate for an Ames test) showed a better performance
than observed in the official 2-test battery (Ates et al., 2016). ToxTracker
TM
was able
to accurately classify compounds as genotoxic or non-genotoxic, and could
discriminate between DNA-reactive compounds, aneugens and indirect genotoxicity
caused by oxidative stress (Brandsma et al., 2020).
The results obtained using a reporter gene assay provide mechanistic information at
the molecular level but cannot alone overrule a positive result from an in vitro battery
as the assay is based on a limited number of genes.
Another tool to potentially address a positive result in a 2-test battery (in one of the
two assays) is transcriptomics analysis in TK6 cells (Li et al., 2015), HepG2 cells
(Maghoufopoukou et al., 2012) or HepaRG™ cells (Ates et al., 2018), in which a higher
number of genes provide mechanistic information (Dertinger et al., 2019). The level
of phosphorylated form of H2AX histone (γH2AX) in cells exposed to a chemical can
indicate its potential for induction of DNA damage (Kopp et al., 2019). Assays that
simultaneously analyse different biomarkers (e.g., p53, γH2AX, phospho-histone H3
or polyploidy) are being developed to provide mechanistic information on the types of
biological damage induced by different classes of substances. Such promising assays
are MultiFlow and the Multi-Endpoint Genotoxicity Assay (MEGA-Screen system)
(Dertinger et al., 2019).
Despite the possibilities offered by the toolbox, expert judgement may be necessary to be
able to come to an overall conclusion.
Intensive work is being carried out on adapting current tests to high-throughput technologies
(e.g., micronucleus test, Comet assay, yH2AX assay, high content analysis and other assays)
(Collins et al., 2017).
Alternative tests for which no OECD test guideline is currently available should be performed
according to the general principles laid down in OECD test Guidelines (OECD 211).
In cases where a clear positive result cannot be overruled in a WoE approach even with
additional testing, the substance has to be considered a mutagen. A positive in vitro result in
genotoxicity testing is also seen as indicative for the carcinogenic potential of substances.
The SCCS has published an Addendum to the NoG (SCCS/1501/12), in which details such as
definitions, critical steps, crucial experimental conditions to be followed, etc. are described
(SCCS/1532/14).
_____________________________________________________________________________________________
67
Figure 8. Scheme of testing strategy for genotoxicity/mutagenicity of cosmetic ingredients
_____________________________________________________________________________________________
68
B. In vivo methods
Animal studies on mutagenicity or genotoxicity are acceptable when data are already
available from tests that have been carried out before the animal testing ban or when
generated for compliance with other legislative (non-cosmetic) frameworks (see Section 1).
When there is a positive result from an in vitro gene mutation test, adequate somatic cell in
vivo tests are:
-a Transgenic Rodent and Germ cell gene mutation assay (TGR) (OECD TG 488),
-an in vivo mammalian alkaline comet assay (OECD TG 489).
It is no longer recommended to perform an Unscheduled DNA Synthesis (UDS) test with
mammalian liver cells in vivo (OECD TG 486) (EFSA, 2017b).
Adequate somatic cell in vivo tests to investigate structural or numerical chromosome
aberrations are:
-a mammalian erythrocyte micronucleus test (OECD TG 474),
-a mammalian bone marrow chromosome aberration test (OECD TG 475)
-an in vivo alkaline comet assay (OECD TG 489).
An OECD guideline for the Pig-a in vivo assay is in progress. According to the experts from
the 7
th
IWGT, the assay can be valuable as a follow-up to in vitro positive results (Kirkland et
al., 2019).
EFSA concluded that target tissue exposure in in vivo studies should be demonstrated,
particularly in the bone marrow (e.g., mammalian erythrocyte micronucleus assay). Toxicity
to the bone marrow in itself provides sufficient evidence to allow concluding on the validity
of a negative outcome of a study. All other direct or indirect evidences of target tissue
exposure should be assessed within a weight-of-evidence approach.
The SCCS is aware of work being conducted in the development of new generation framework
for assessment of genomic damage (Steiblen et al., 2020; Luijten et al., 2020), however this
work is at preliminary stage and no guidance can be delineated at the moment.
3-4.11 CARCINOGENICITY
Substances are defined as carcinogenic if, after inhalation, ingestion, dermal application or
injection, they induce or increase the incidence of tumours, induce malignancy or shorten the
time before tumour occurrence (ECHA 2017).
Carcinogens are often differentiated as "genotoxic carcinogens" (DNA-reactive substances),
for which the most plausible mode of carcinogenic action is via genotoxic effects (i.e. point
mutations and structural chromosomal aberrations), and "non-genotoxic carcinogens", or
non-DNA reactive substances that are carcinogenic due to mechanisms other than direct
interactions with DNA (ECHA 2017).
A. NAMs
(i) In silico methods for carcinogenicity:
See under 3-4.10.2 (i): in silico methods for genotoxicty and carcinogenicity
_____________________________________________________________________________________________
69
(ii) In vitro methods
- Genotoxic carcinogens (DNA reactive)
At present validated alternative in vitro methods to determine the carcinogenic potential of
substances are not available as OECD test Guidelines. However, there are new in vitro
approaches which may be helpful in an overall WoE approach to indicate potential genotoxic
as well as NGC substances.
For genotoxic substances, in vitro mutagenicity tests are well developed. Due to the relation
between mutations and cancer, these genotoxicity tests can also be seen as a pre-screening
for carcinogenicity. A positive result in one of the in vitro mutagenicity/ genotoxicity testing
battery may be indicative for considering a substance as a putative carcinogen. This indication
may be further supported by a positive result in Cell Transformation Assays (CTAs, Guidance
documents No 214 and No 231).
Worldwide research is ongoing with regard to in vitro toxicogenomics for the detection of
mutagens, genotoxic carcinogens, and particularly NGC. By global gene expression profiling
via microarray technology, gene patterns covering diverse mechanisms of substance-induced
genotoxicity can be identified (Schmitz-Spanke, 2019).
These gene patterns/biomarkers can be further used as a follow-up of positive findings of the
standard in vitro mutagenicity/genotoxicity testing battery (Goodsaid et al., 2010; Doktorova
et al., 2012; Magkoufopoulou et al., 2012; Ates et al. 2018). In addition to in vitro
mutagenicity/genotoxicity tests (see above), data from in vitro tests combined with
toxicogenomics may also be considered in a WoE approach. A multiple-endpoint approach is
most probably a more reliable means of assessing carcinogenicity in vitro than traditional,
single-endpoint tests (Wilde et al., 2018).
- Non-genotoxic carcinogens (DNA-non reactive)
Genotoxic carcinogens either induce mutations in (short term) eukaryotic and prokaryotic
mutation assays or induce direct DNA damage in the target organ. Although it has been
estimated that 10-20% of recognised human carcinogens classified as Class 1 by IARC act
through NGC mechanisms (Hernandez et al., 2009), there are no specific requirements to
obtain information on NGC mechanisms of carcinogenicity. As such many NGC will remain
unidentified, and as a consequence their risks to human health will not be managed. The
overview of NGC mechanisms presented by Jacobs et al. (Jacobs et al., 2016) indicates that
assays with endpoints capturing early key event mechanisms may provide an individual
contribution to the WoE approach of NGC.
(iii) Development of integrated approach to testing and assessment (IATA) for NGC
Using the AOP concept, an OECD expert working group has elaborated a preliminary panel of
key hallmarks of NGC and representative international standardised tests that can address
IATA for NGC (Jacobs et al., 2020). Using a systematic review approach combined with assay
database mining, overall more than 100 in vitro assays have been identified so far, within 13
cancer hallmark assay blocks that address early, mid and later key events with consequent
increasing associations with adverse outcome. The assays are currently undergoing
evaluation by the group including assessment of their readiness for validation in the short,
medium and long term.
(iv) Cell Transformation Assays (CTA) as a possible alternative to animal models of
carcinogenicity testing
CTA can detect both genotoxic and NGC (Sasaki et al., 2014) and are able to highlight various
stages from early (initiation) to late (promotion) phases (OECD 2017, Serra et al., 2019,
Jacobs et al., 2020). They address several endpoints. They measure cell transformation,
which includes early key events such as transdifferentiation, acquisition of a peculiar
morphology, etc., reflecting stages in the multistep cancer process (for more information,
see Appendix 8, Table A.8). CTAs thus can be used as phenotypic anchoring for mechanistic
_____________________________________________________________________________________________
70
studies (Callegaro et al, 2017). They may provide additional information and may be used as
a follow-up for confirmation of in vitro positive results from genotoxicity assays, typically as
part of a WoE approach (Doktorova et al., 2012, Creton et al., 2012). When employed in
combination with other information, such as genotoxicity data, structureactivity analysis
and pharmaco/toxicokinetic information, CTAs could facilitate a relatively comprehensive
assessment of carcinogenic potential (Creton et al., 2012, Corvi et al., 2017, Mascolo et al.,
2018). Toxicogenomics in combination with in vitro CTAs allow the identification of the
transcriptionally activated pathways (Mascolo et al., 2018). This integrated approach has the
potential to be considered as part of an IATA for non-genotoxic carcinogenesis (Corvi et al.,
2017).
Validated CTAs are the BALB/c 3T3 CTA (EURL ECVAM, 2012), the Syrian Hamster Embryo
(SHE) CTA OECD Guidance Document No. 214 (OECD, 2015, Corvi et al., 2017) and the Bhas
42 CTA OECD Guidance Document No. 231 (OECD, 2017, Jacobs et al., 2020). These can be
used in a WoE approach in the testing of substances for carcinogenic potential. At present,
the carcinogenic potential of a substance cannot be derived from a stand-alone CTA.
B. In vivo methods
An in vivo carcinogenicity study is only acceptable by SCCS when based on tests that have
been carried out before the animal testing ban or when carried out for the purpose of
compliance with other (non-cosmetic) legislative frameworks.
Usually the carcinogenic potential of a substance is assessed using a 2-year bioassay (OECD
451: carcinogenicity studies). A combined chronic toxicity/carcinogenicity study can also be
performed to identify carcinogenic and the majority of chronic effects, and to determine dose-
response relationships following prolonged and repeated exposure (OECD 453: C-combined
chronic toxicity/carcinogenicity studies). It is now well recognised by the scientific and
regulatory community that the use of the rodent cancer bioassay has many limitations in
terms of reliability and relevance (Jacobs et al., 2020).
Utilising a mode of action analysis instead of performing the long-term rodent carcinogenicity
studies offers a more direct and rational basis for human cancer risk assessment. Such
analysis should be performed whenever possible, rather than simple hazard identification
(Berry 2018, Goodman 2018).
3-4.12 PHOTO-INDUCED TOXICITY
3-4.12.1 PHOTO-IRRITATION AND PHOTO-SENSITISATION
A. NAMs
The "3T3 Neutral Red Uptake Photo-toxicity Test (3T3 NRU PT)" is a validated in vitro method
(EC B.41, OECD 432), based on a comparison of the cytotoxicity of a chemical when tested
in the presence and in the absence of exposure to a non-cytotoxic dose of UV/VIS radiation.
Its use is mandatory for testing for phototoxic potential. It is not designed to predict other
adverse effects that may arise from combined actions of a chemical and light, e.g. it does not
address photoclastogenicity/ photomutagenicity, photo-allergy or photocarcinogenicity.
In the OECD 432 GD it is indicated that if the Molar Extinction/absorption Coefficient (MEC)
is less than 1000 L mol¹ cm¹ (measured in methanol), the chemical is unlikely to be
photoreactive and that such chemicals may not need to be tested.
EFSA (2016) concluded that for a light source emitting wavelengths mainly below 320 nm,
more guidance is needed on how to interpret the data and on how to perform the test with a
light source emitting between 290 and 320 nm. In the OECD TG, it is mentioned that
cytotoxicity increases 1000-fold as the wavelength ranges from 313 to 280 nm. Although the
data requirement in Reg. (EU) No. 283/2013 are for substances absorbing electromagnetic
radiation in the wavelength range 290-700 nm, there are difficulties in testing below 320 nm.
_____________________________________________________________________________________________
71
EFSA proposed that the phototoxicity test should not be performed if it has been
demonstrated that the test material only absorbs at wavelengths lower than 313 nm and if
there is insufficient absorption at longer wavelengths.
As a second tier, the biological effects can be further evaluated on a reconstructed human
skin model with some barrier properties (Kandarova, 2011). A positive control should always
be included. A negative result for the compound under consideration is usually accepted. To
enhance the chance of achieving correctly predicted results of phototoxic potential of
chemicals, a more complex screening using UV/VIS radiation spectral analysis and Reactive
Oxygen Species (ROS)/micellar ROS (mROS) assays could be used according to Nishida et
al., 2015.
Presently, no validated in vitro methods for the detection of photo-sensitisation are available.
Nevertheless, it is expected that chemicals showing photo-allergic properties are likely to give
positive reactions in the 3T3 NRU PT test. There is also work being conducted on some other
in vitro tests for photo-allergenic potential such as: photo-hCLAT, NCTC2455 assay, dendritic
cell-based assay, or photo-SH/NH2 test (Onoue et al., 2017).
For pharmaceuticals applied to the skin, it is stated in EMA 2012 (updated 2015) that
reconstructed human skin models can be used. Under adequate test conditions, a negative
result in a reconstructed human skin assay indicates that the direct phototoxicity potential of
the formulation can be regarded as low. In that case, generally no further phototoxicity
testing is recommended.
B. In vivo methods
At present, no official guideline-based protocols for photo-irritation and photo-sensitisation
testing in animals have been evaluated. Several industry reports describe test protocols. For
pharmaceuticals, guidance on such testing is available (FDA, 2015; EMA, 2012). These
documents do not, however, specify protocols for the testing of adverse effects of orally or
topically applied agents, nor do they give recommendations about the species to be used.
The SCCS guidance is as follows:
UV-VIS spectra of the compound along with the MEC, determined according to a harmonised
procedure, should be provided.
There is no requirement for phototoxicity testing of compounds with a MEC below 1000 L
mol−1 cm−1.
There is no requirement for in vitro phototoxicity testing if the test material only absorbs at
wavelengths lower than 313 nm and if there is insufficient absorption at longer wavelengths.
3-4.12.2 PHOTOMUTAGENICITY / PHOTOGENOTOXICITY
Photomutagenic or photogenotoxic chemicals are chemicals that absorb visible (VIS) light or
UV radiation and, through activation to a more reactive state or release of free radicals, cause
damage to DNA and induce gene mutations or chromosome aberrations.
The terms ‘‘photomutagenesis’’ or ‘‘photogenotoxicity’’ are used to describe the ‘indirect’
induction of gene mutations or chromosomal aberrations after transfer of energy or charge
from a light absorbing molecule other than DNA (Müller and Gocke, 2013). This includes the
genotoxic effects elicited by degradation products and/or radicals generated by VIS and UV
wavelengths.
(i) Current status of tests available for photogenotoxicity/photomutagenicity
assessment
A previous version of the Notes of Guidance (SCCNFP/0690/03) already mentioned that for
the detection of photochemical clastogenicity/mutagenicity, several assays had been adapted
_____________________________________________________________________________________________
72
to a combined treatment of chemicals with UV-VIS radiation (Averbeck et al., 1979; Dean et
al., 1991; Chetelat et al., 1993a,b, 1996; Gocke et al., 1998; Pflaum et al., 1998; Kersten et
al., 2002).
The existing principles and test methods in the field of photomutagenicity/photogenotoxicity
was summarised in the report of the Gesellschaft für Umweltmutationsforschung (GUM) Task
Force on photochemical genotoxicity (Brendler-Schwaab et al., 2004). The methods described
include the photo-Ames test, the photo HPRT/photomouse lymphoma assay, the photo-
micronucleus test, the photochromosome aberration test and the photo-Comet assay. In
many cases, the concurrent use of irradiation, while performing a standard
mutagenicity/genotoxicity study, does not significantly alter the existing OECD protocol
without irradiation. Therefore, the majority of the described photomutagenicity/photo-
genotoxicity tests are considered as being valid.
In addition to the conclusions of an international workshop (Lynch et al., 2011), a
comprehensive review (Müller and Gocke, 2013) concluded that “photomutagenicity is not
suitable for a general testing framework within cosmetic or pharmaceutical testing guidelines”
and suggested a case-by-case approach
(ii) Guidances for photogenotoxicity/photomutagenicity testing
The COM (COM 2013) recommended that photogenotoxicity testing does not need to be
undertaken routinely as part of a photosafety assessment and that photogenotoxicity testing
had a negligible impact in the overall assessment for potential of photocarcinogenicity.
Moreover, if there is a negative response from the phototoxicity test, no photomutagenicity
test is required. However, if the test is positive, no specific guidance is provided.
The International Conference on Harmonisation (ICH) guideline on photosafety evaluation of
pharmaceuticals (Step 4 of the ICH Process dated 13 November 2013) stated: ‘Note 2. Testing
for photogenotoxicity is not recommended as a part of the standard photosafety testing
program as in most cases, the mechanism by which compounds induce photogenotoxic effects
is identical to those that produce phototoxicity, and thus separate testing of both endpoints
is not warranted.
The ICH guideline has been adopted in EU by the Committee for Medicinal Products for Human
use (CHMP) in December 2015 and issued as EMA/CHMP/ICH/752211/2012 (EMA, 2015) as
well as in the USA by the FDA and issued as FDA/2013/D/0068 (FDA, 2015).
In 2016 the EFSA (2016) agreed that photomutagenicity testing is not required for the time
being, unless further guidance is provided. Additionally, they concluded that the concern
regarding positive results in the phototoxicity test should be raised to the risk managers in
the conclusion of the peer review.
In this regard, taking also into consideration the general recommendations regarding the
experimental conduct of tests for photogenotoxicity (Gocke et al., 2000), the SCCS
guidance is as follows:
- although the validity of photomutagenicity/photogenotoxicity testing is being questioned,
in specific cases when the structure of a molecule, its light absorbing potential or its
potential to be photo-activated may indicate a photomutagenic/photogenotoxic hazard,
then photomutagenicity tests should be provided, including gene mutations and
clastogenicity/aneugenicity endpoints; especially when the substance is liable to reach the
eyes or light-exposed areas of skin, either by direct contact or through systemic
distribution. Additionally, available alternative methods, for example scientifically
validated comet assay for detection of oxidized DNA lesions, or in silico methods, can be
considered.
- UV-VIS spectra of the compound along with the MEC, determined according to a
harmonised procedure, should be provided.
- the phototoxicity test should not be performed if the test material only absorbs at
wavelengths lower than 313 nm and if there is insufficient absorption at longer
wavelengths.
- no photomutagenicity tests are needed when the phototoxicity tests are negative.
_____________________________________________________________________________________________
73
- there is no requirement for a photomutagenicity test if the test material only absorbs at
wavelengths lower than 313 nm and if there is insufficient absorption at longer
wavelengths.
3-4.13 HUMAN DATA IN HAZARD ASSESSMENT
Tests in animals and alternative methods may have limited predictive value with respect to
the human situation. Therefore, when human data is available, this information is very
valuable. Human data can be obtained via various sources. For bioavailability and systemic
toxicology information, sources could be: post-marketing surveillance data, results from
biomonitoring programs (see Section 3-3.5.6), case reports, occupational surveillance data
and occupational disease registries (e.g. from production of the ingredient or when the
cosmetic ingredient is also used in non-cosmetic areas), poison centre information,
epidemiological studies, clinical studies, tests with human volunteers.
Tests with human volunteers (e.g. skin compatibility tests) confirm that there are no harmful
effects when applying a cosmetic product for the first time to human skin or mucous
membranes. If considered scientifically and ethically necessary, human tests can only be
envisaged, provided that the toxicological profiles of the components are available and no
concern is raised. A high degree of safety needs to be ensured. Finished cosmetic products
are usually tested in a small group of human volunteers to confirm skin and mucous
membrane compatibility, as well as cosmetic acceptability (fulfilment of in-use expectations).
Human studies might also become necessary to build up and validate PBPK models (see
Section 3-3.5.3).
The general ethical and practical aspects related to human volunteer compatibility studies on
finished cosmetic products, are described in SCCNFP/0068/98 (for skin irritancy) and
SCCNFP/0245/99 (for skin sensitisation). For skin sensitisation, human patch test data, if
available, have to be taken into account (SCCS/1567/15).
Predictive testing of potentially skin sensitising cosmetic (mixtures of) substances
(SCCNFP/0120/99) is more controversial than the irritancy testing, since these tests carry
the risk of inducing a long-lasting or permanent immunological sensitisation in the individual.
Therefore, serious ethical questions arise.
Despite many years of experience with human sensitisation tests, limited scientific
information is available regarding the consequences involved for human volunteers who have
developed sensitisation as a result of such testing.
Due to the uncertainties mentioned, the SCCS is of the opinion that predictive human
sensitisation tests should not be carried out.
The same ethical restrictions apply to human predictive tests on photosensitisation. For
photosensitisation, information can be obtained from published clinical studies and case
reports. There are no officially adopted guidelines or protocols, but in general the test
procedures are quite similar to those used in photo-patch testing in clinical settings
(Bruynzeel, 2004). Normally a UV-A dose of 5 10 J (and occasionally UV-B in appropriate
non-erythemogenic dose) is applied to a skin area that has been exposed to the product or
substance during the preceding 24 hours. Adequate control test areas, including a vehicle
exposed and an unexposed UV irradiated area, are essential. Readings must be performed at
least at 4, 24 and 48 hours after irradiation.
3-4.14 OTHER CONSIDERATIONS
When HBM in used in the safety evaluation of consumer product ingredients, the following
limitations apply:
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74
HBM is applicable to substances that are systemically taken up and where the half-life
of the biomarker enables sampling and analytical determination.
HBM is not appropriate when the relevant biomarker is an endogenously formed
substance, present in much higher concentrations than those caused by the uptake of
a substance from the environment or consumer products.
HBM is not appropriate when the relevant biomarker is non-specific (e.g., can be
formed by different parent compounds such as hippuric acid).
Various factors influence HBM results, including age, gender, lifestyle, consumer
habits, diet, place of residence, etc., as they modify the amounts of chemical
substances taken up. Inter-individual differences in the metabolism of chemical
substances, excretion of metabolites, health status as well as different compositions
of biological materials like varying dilutions of urine etc., even under identical
conditions of exposure, may provide different HBM results.
Other error sources are contamination of samples during collection and handling of
the biological samples (Calafat and Needham, 2009).
3-5 GENERAL PRINCIPLES FOR THE CALCULATION OF THE MARGIN OF SAFETY AND
THRESHOLD OF TOXICOLOGICAL CONCERN
3-5.1 CALCULATION OF THE MARGIN OF SAFETY OF A COSMETIC INGREDIENT
The last step in the safety evaluation of a cosmetic ingredient is the calculation of the MoS,
which is the ratio between a PoD
sys
(usually historical NOAEL or BMD values from oral studies)
and an estimate of the exposure (11).
Mostly, only a repeated dose toxicity study with oral exposure is available as a surrogate for
a study with dermal exposure. For comparison with the PoD
sys
, usually an SED for the dermal
route is derived as the exposure estimate. For calculation of SED, see 3-3.5.4.
Where possible, a BMD is used as PoD
sys
{see also 3-1 (3)}.
PoD
sys
MoS = (11)
SED
3-5.1.1 THE POD VALUE
As far as the determination of critical effects in repeated dose toxicity studies is concerned,
the available repeated dose toxicity data should be evaluated in detail for characterisation of
the health hazards upon repeated exposure. In this process, an assessment of all toxicological
effect(s), their dose-response relationships and possible thresholds should be taken into
account. The evaluation should include an assessment of the severity of the effect(s), whether
the observed effect(s) are adverse or adaptive, irreversible or not - and whether they are
precursors or not of significant effects or secondary to general toxicity. Correlations between
changes in several parameters (e.g. between clinical or biochemical measurements, organ
weights and (histo)pathological effects) will be helpful in the evaluation of the nature of the
effects. Further guidance on this issue can be found in several publications (WHO, 1994;
WHO, 1999; ECETOC, 2002; ECHA, 2012a).
3-5.1.1.1 DETERMINATION OF NOAEL
The NOAEL is defined as the highest dose or exposure level where no (adverse)
treatment-related findings are observed. For cosmetic ingredients, the NOAEL is mainly
_____________________________________________________________________________________________
75
derived from a 90-day repeated dose animal study or from a reproductive toxicity
animal study.
The BMD approach should preferentially be used as the dose descriptor for the PoD and the
MoS calculations (EFSA, 2009). When no BMD can be calculated, usually historical NOAEL
values are applied.
If a BMD or a NOAEL cannot be identified from the available data, other dose descriptors
such as the Lowest Observed (Adverse) Effect Level (LOAEL) may be used in the MoS
calculation.
See Section 3-1(3)(4).
3-5.1.1.2 DETERMINATION OF BMD
Although not limited to in vivo data, it involves first fitting a dose-response model to the data
and then interpolating to find the lowest dose that causes a statistically significant response
(or alternatively: the dose that corresponds to a low but measurable change in response
over the entire dose interval). That dose is defined as the BMD. To account for uncertainty,
a two-sided 90% confidence interval for the BMD interval, the BMDU (upper confidence limit
of BMD), is sometimes used to calculate the BMDU/BMDL (lower confidence limit of BMD)
ratio which provides an estimate of the uncertainty in the BMD value. The BMD/BMDL ratio
can also be used for this purpose but is less suitable as it is does not take the full uncertainty
in the BMD estimation into account (EFSA guidance, 2017c).
With quantal data, also referred to as dose-response data, the outcomes are incidences, e.g.
number and gender of animals with signs of toxicity. With such data the BMD is defined as
the dose associated with a specific change in the response, the Benchmark Response (BMR)
most often defined as either an increased additional risk or extra risk. An extra risk of 10%
is recommended as default for the BMR by both EFSA (EFSA, 2016) and US EPA (US EPA,
2010).
Body weight, organ weights and enzyme levels are typical continuous data, also referred to
as dose-effect data. For such data each animal has its own magnitude of effect and the
arithmetic or geometric means of the different dose groups are usually compared.
EFSA has proposed a preferred default 5% as a BMR, with modifications if required by
toxicological or statistical considerations (EFSA, 2017c).
3-5.1.1.3 CHOICE OF MODELS
The most well-known BMD software (BMDS) has been developed by the US EPA
(www.epa.gov/bmds) and the National Institute for Public Health and the Environment
(RIVM) (the PROAST software, www.rivm.nl/proast). Application of different models to the
same data will yield different values for the BMD and BMDL. As a consequence, there are
different methods that guide the choice of which BMD and BMDL to use. Current EFSA
guidelines suggest that the lowest BMDL among the models that pass a goodness-of-fit test
should be used as the PoD (EFSA, 2017c). EPAs guidelines are less conservative, suggesting
that the model with the lowest Akaike Information Criterion (AIC) should be used as the PoD,
unless there is a large difference between the BMDL values obtained with the different models
(US EPA, 2012).
The AIC takes the likelihood of the model fit into account, but penalizes models with many
parameters:
The SCCS considers that there are still practical considerations regarding the use of this
approach when evaluating cosmetic ingredients and its application requires a level of expert
judgement and modelling expertise.
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76
3-5.1.1.4 ADJUSTMENT FACTORS TO THE POD
Dependent on dosing regimen, adjustment to daily exposure should be performed. For
example, if the dose regimen in such a study was only 5 days treatment per week, a PoD
corrected by a factor of 5/7 should be used for the MoS calculation (ECHA, 2012a).
When the PoD is based on a LOAEL, often an additional assessment factor of 3 is
added in the calculation of the MoS. However, a higher assessment factor of up to 10
may be decided on a case-by-case basis, taking into account the dose spacing in the
performed repeated dose toxicity test, the shape and slope of the dose-response curve (and
in some cases the extent and severity of the effect(s) seen when LOAEL values are used). In
some cases, the study cannot be used for safety assessment.
In case a 90-day repeated dose toxicity study is not available, a NOAEL or BMDL from a 28-
day repeated dose toxicity study can be used in the MoS calculation for a cosmetic ingredient.
In this case, a default assessment factor of 3 for exposure duration may be used in the
calculation of the MoS.
3-5.1.2 THE PODSYS VALUE
If the absorption by the oral route is 100%, then the external and internal doses of the oral
route are the same. If the absorption by the oral route is less than 100%, which is often the
case, the procedure may underestimate the risk of the exposure of the non-oral route.
It is considered that not more than 50% of an orally administered dose is systemically
available. Thus, in the absence of data, 50% of the administered dose is used as the
default oral absorption value for a cosmetic ingredient and the PoDsys is derived from the
PoD by dividing with a factor 2. If there is information to suggest poor oral bioavailability,
a default value of 10% oral absorption could be considered. However, whenever oral
absorption data are available, these should be used, also when using other dose descriptors.
Also, any other available kinetic data should be considered.
For chemicals with a high first-pass metabolism in the gut or liver, the situation is even more
complex and, in addition, the target organ for toxicity has to be taken into consideration and
route-to-route extrapolation may not be adequate.
In the case of oral to inhalation extrapolation, a default factor of 2
9
is also proposed
(default absorption oral route: 50%; inhalation 100%; ECHA, 2012a).
3-5.1.3 MOS ANALYSIS
The calculated MoS is compared with a reference MoS, which is comparable to the
uncertainty/assessment factor used in risk and safety assessments to extrapolate from a
group of test animals to an average human being, and subsequently from average humans
to sensitive subpopulations (see Figure 9). A default value of 100 (10x10) accounting for
inter- and intraspecies differences is generally accepted and a MoS of at least 100 therefore
indicates that a cosmetic ingredient is considered safe for use.
9
Besides the default value of 50% for oral absorption, in this guidance, another default value of 50% for dermal
absorption should be distinguished if no adequate dermal absorption data is available {see Section 3-3.5.2}.
_____________________________________________________________________________________________
77
Figure 9: Schematic representation of the extrapolation from animal to man
(Renwick, 1998).
As shown in Figure 9, the default value of 100 consists of a factor of 10 for the extrapolation
from test animals to an average human being (interspecies extrapolation) and another factor
of 10 taking into account the variations within the human population (intra-species
extrapolation). These factors can be further subdivided as indicated in Figure 10.
When considerable qualitative/quantitative toxicokinetic differences are observed between
test animals and humans, as well as within human individuals, e.g. from relevant toxicokinetic
data for rat and/or humans (SCCS/1443/11, SCCS/1479/12), the interspecies and/or intra-
species toxicokinetic default factor (see Figure 10) can be increased/decreased (case-by-
case evaluation).
Regarding substance-specific information for variations in toxicodynamics, deviation from the
default value is possible if sufficiently justified. For instance, in case of different susceptibility
to HPT-axis disturbances in rats and humans, a change of the interspecies toxicodynamic
default factor of 2.5 may be required (SCCS/1481/12).
Figure 10: Further subdivision of the uncertainty/assessment factor, taking toxicokinetics
and toxicodynamics into account (based on WHO, 1994).
* including historical NOAEL values
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78
Additional considerations:
i. Some cosmetic substances are not used on a daily basis, although their NOAEL values
have been obtained in studies after daily administration of the substances. Combining
these NOAEL values with daily exposures therefore results in a clear overestimation of the
risk. The comparison of a NOAEL resulting from a daily exposure study with the SED of a
certain cosmetic ingredient is therefore accepted as a conservative estimate, even if it is
only applied e.g. once per week or once per month. However, the daily amount for product
categories with low frequencies of application may not be adjusted by the frequency (i.e.
not divided by 30, if applied once per month), as justified by: "The actual daily dose is
independent of the exposure frequency. This means that if, for a certain scenario, worker
or consumer exposure is only for a number of days per year, the exposure value is the
actual dose on the exposure days, and not the daily dose averaged out (and thus divided!)
over the whole year" (ECHA, 2012a). This reasoning, however, may be changed for
example in the case of hair dyes (e.g. oxidative hair dyes only applied once per month)
and a MoS slightly below 100. One could consider a substance as being safe due to the
occasional use and the built-in conservatism of assessment but only after expert
judgement.
ii. When there is sufficient evidence that the dermal absorption of a cosmetic ingredient is
very low, systemic exposure may be negligible and the calculation of a MoS may not be
justified or applicable (see Sections 3-6.11 and 3-5.2). See also for example UV filter
HAA299 SCCS/1533/14.
iii. The SCCS will decide upon the relevance of MoS calculations on a case-by-case basis,
taking into account the general toxicological profile of the substance under consideration,
its toxicokinetic properties and its intended use.
iv. With regard to rounding and number of digits given for the MoS, this should be based on
the precision of the underlying data. The biological variability of toxicity data in vivo
generally is > 10%. The indication of more than decimal digits in the final MoS is therefore
not recommended.
3-5.2 THE THRESHOLD OF TOXICOLOGICAL CONCERN (TTC)
3-5.2.1 GENERAL CONCEPT OF TTC IN RISK ASSESSMENT
The use of the TTC approach as a risk assessment tool for cosmetics and consumer products
has been evaluated by the SCCS/SCHER/SCENHIR (SCCP/1171/08) as it is a pragmatic tool
that is based on the principle of establishing human exposure threshold values for all
chemicals below which there is a very low probability of an appreciable risk of systemic
adverse effects to human health.
Use of the TTC concept for chemicals with specific data requirements for their regulatory
approval under a specific European regulation is currently not acceptable as an alternative to
a chemical-specific evaluation.
Nevertheless, the TTC concept has been acknowledged to be a science-based prioritisation
and risk assessment tool by different organisations such as WHO IPCS, EFSA, SCCS, SCHER,
Health Canada (Joint FAO/WHO Expert Committee on Food Additives, 1996; SCCS, SCHER,
2012; EFSA, 2016a & 2019a; SCCS NoG 2016; Health Canada, 2016).
EFSA (EFSA, 2012 & 2019a) concluded that the TTC approach should not be used for the
following (categories of) chemicals: high potency carcinogens (i.e. aflatoxin-like, azoxy- or
N-nitroso-compounds, benzidines and also hydrazines); inorganic chemicals; metals and
organometallics; proteins; steroids; chemicals that are known or predicted to bioaccumulate;
nanomaterials; radioactive chemicals and mixtures of chemicals containing unknown chemical
structures.
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79
So far, this approach has been used in a regulatory context for food contact material migrants,
food flavourings, fragrances, genotoxic constituents in herbal preparations and for pesticide
metabolites in groundwater.
The TTC approach aims to screen and prioritise chemical compounds for which the chemical
structure and exposure data are known, but for which no or limited toxicity data is available,
using an algorithm developed by Cramer (Cramer, 1978) where the substances, depending
upon their chemical structure, are grouped into three structural classes (low, medium, high
safety concern) in comparison with the toxicity data from available databases.
A database containing carcinogenicity data from animal studies for more than 3500
carcinogenicity experiments (Carcinogen Potency Database) (Gold et al., 1984) and a
database containing 613 chemicals based on toxicity other than carcinogenicity (Munro
database) (Munro et al., 1996) were available when the TTC approach was developed. Both
are based on systemic effects after oral exposure.
As with any risk assessment tool, application of the TTC approach requires a high level of
confidence in: 1) the quality and completeness of the databases; 2) the reliability of the
exposure data for the intended uses of the compound under study; and 3) the
appropriateness of any extrapolations.
3-5.2.2 TTC APPROACH FOR HUMAN HEALTH RISK ASSESSMENT OF CHEMICAL SUBSTANCES AND
COSMETIC SUBSTANCES
a) Systemic toxicity
The Scientific Committees (SCs) consider the TTC approach, in principle, scientifically
acceptable for human health risk assessment of systemic toxic effects caused by chemicals
present at very low levels. The application of the TTC should, however, be done on a case-
by-case basis and requires expert judgement. The TTC approach is also not applicable for a
number of chemical classes, which are indicated in detail in SCCP/1171/08 (adopted in 2012).
Practical application of the TTC approach to chemicals with no genotoxicity alert is usually
done by analysing the chemical structure and using Cramer classification as an indicator of
systemic toxicity. A small number of misclassifications of compounds when using the Cramer
decision tree in its present form have been revealed. Misclassification may also result in a
classification to a higher toxicity class. (Bhatia et al., 2015; Yang et al., 2017) and hence still
be conservative for safety evaluation.
The SCs concluded that the TTC value of Cramer Class II is not supported by the available
databases and these substances should be treated as Class III substances. The SCs also
accepted in principle the division of substances into Cramer Classes I or III (EFSA, 2016a).
When assigning a chemical to the lowest toxicity Class I, 1800 μg/person/d
corresponding to 30 μg/kg bw/d the classification should be carefully considered and
justified. If classification in Class I cannot be justified, the SCs recommended a general default
value equivalent to Class III compounds, being 90 μg/person/d, corresponding to
1.5 μg/kg bw/d for substances without genotoxicity alerts.
All the scientific information available today should be used to define the various toxicity
classes before expanding their number, i.e. the classification scheme should be modified
based on up-to-date toxicological knowledge (Boobis et al., 2017).
The SCCS agreed that, the default value of 0.15 μg/person/d, corresponding to
0.0025 µg/kg bw/d can be used for chemicals with genotoxicity alerts and hence
possible DNA reactive carcinogens but recommends its scientific basis to be strengthened.
This could be achieved by e.g., extending the database, analysing all available carcinogenicity
_____________________________________________________________________________________________
80
studies, using allometric adjustment factors and/or using the BMD
5
or BMD
10
as PoD for linear
extrapolation.
Usually, TTC values are expressed as an amount per person per day. In order to be applicable
to the entire population, including all age groups, it is advised to express TTC values in an
amount per kg body weight per day and give special consideration to infants under the age
of 6 months because of the potentially immature metabolism for some chemicals structures,
in particular when the estimated exposure is close to tolerable exposures defined by the TTC
values.
In the EU SEURAT-1 project COSMOS, work has been done on the TTC substances with non-
genotoxic alerts that are used for cosmetic purposes. The COSMOS TTC dataset, which was
quality controlled, contained 552 chemicals (495 cosmetic ingredients) with 219, 40, and 293
chemicals in Cramer Classes I, II, and III, respectively, to expand the chemical space and to
provide more robust thresholds for cosmetic-related chemicals. A TTC of 7.9 µg/kg bw/d was
suggested for Cramer Class III (which is 5-fold higher than the corresponding TTC value
derived by Munro et al., 1996). Cramer Class II was insufficient for derivation of a robust TTC
value. For Cramer Class I, a moderately increased TTC of 42 µg/kg bw/d was proposed. When
considering the COSMOS-plus-Munro i.e. federated” dataset, values of 2.3 µg/kg bw/d
and 46 µg/kg bw/d were derived for Cramer Class III and I, respectively (Yang et
al., 2017). Although the TTC values are based on general toxicity data, it seems that datasets
specific for reproductive-developmental endpoints (Laufersweiler et al., 2012; van
Ravenzwaay et al., 2017) are adequately covered (Rogiers et al., 2020). Furthermore, work
of Patel et al. (2020) whereby 238, 76 and 162 fragrance chemicals in Cramer class I, II and
III of the RIFM TTC-database were integrated in the federated dataset, resulted in TTC values
for Cramer class I, II and III of 49.1, 12.7 and 2.9 µg/kg bw/ day, respectively. The different
values reported are taken up in Table 9 (PoDs used for derivation of TTCs are taken up in
APPENDIX 13).
It is important to note that an appropriate exposure assessment is essential for the
application of the TTC approach.
TTC thresholds are external dose-based values referring to oral systemic toxicity. For
cosmetics, the main exposure route is dermal. In the proposal from Kroes et al. (2007), an
external exposure value was converted to an internal exposure value by use of an adjustment
factor for percutaneous absorption. The latter value was then compared to the TTC value as
if the TTC value is also an internal exposure value. This is the case under the assumption of
100% oral bioavailability, which in many cases is an overestimation. For proper route-to-
route extrapolation, the NOAELs from the Munro database need to be corrected for oral
absorption. It should, however, be mentioned that in only few cases quantitative information
on absorption after oral administration is available.
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81
Table 9: Overview of Threshold of toxicological concern (TTC) values (μg/kg bw/day).
Cramer
class
SCCP/1171/08
(Munro et al.
1996)
Cosmos-TTC
(SEURAT-1;
European
commission,
2009)
Cosmos/Munro/
Federated DB
(Yang et al., 2017)
RIFM/Munro/Cosm
os/Federated DB
(Patel et al., 2020)
Genotoxic
compounds
0.0025
I*
30
42
46
49.1
II*
Not supported**
-
Not supported**
12.7
III*
1.5
7.9
2.3
2.9
*Non-genotoxic compounds
**Chemicals of Cramer class II should be treated as Class III substances.
Values in bold are those currently recommended by the SCCS for use for cosmetics-related
substances.
For botanical extracts, Kawamoto et al. (2019) reported that the Cramer class III TTC value
of 90 µg/person/d might be adequately conservative. For potentially genotoxic substances a
TTC value of 10 µg of plant material on a dry weight basis/person per day has been proposed
(Mahony et al., 2020). These values are not taken up in the Table 9 as plant materials are
composed of mixtures.
TTC thresholds are external dose-based values referring to oral systemic toxicity. For
cosmetics, the main exposure route is dermal. In the proposal from Kroes et al. (2007), an
external exposure value was converted to an internal exposure value by use of an adjustment
factor for percutaneous absorption. The latter value was then compared to the TTC value as
if the TTC value was also an internal exposure value. This is the case under the assumption
of 100% oral bioavailability, which in many cases is an overestimation. For proper route-to-
route extrapolation, the NOAELs from the Munro database need to be corrected for oral
absorption. It should, however, be mentioned that only in a few cases is quantitative
information on absorption after oral administration available.
The SCCS considers that at present the thresholds proposed by the ‘federated Yang et
al. (2017)’ data set of 2.3 µg/kg bw/d and 46 µg/kg bw/d for Cramer classes III
and I respectively, are appropriate for use in relation to cosmetics-related
substances.
b) Inhalation toxicity
For inhalation exposure TTC, only limited information is available (Carthew et al., 2009;
Escher et al., 2010; Schüürmann et al., 2016). Compared to the existing oral database, the
pool of available repeated dose inhalation exposure studies is scarce (about 400 rodent
studies and even fewer with accompanying local respiratory effects observations) (RIFM
database). The development of inhalation TTC is not yet mature enough to be considered as
a valid risk assessment tool.
3-5.2.3 ITTC APPROACH
For cosmetic ingredients any risk assessment as well as the TTC approach should be based
on internal doses (Partosch et al., 2014). Therefore, when the TTC approach is applied for
cosmetic ingredients, an adjusted internal TTC value has to be defined considering both
dermal and oral absorption. As such, several attempts have been made to arrive to an
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82
internal TTC (iTTC) by adjusting the external NOAEL values of substances by in silico
estimates of oral bioavailabilty (Partosch et al., 2015, Reilly et al., 2019). However, the
estimates were still based on external dose and not an internal exposure metric such as
plasma concentration.
Within the framework of a multi-stakeholder project, further work is currently ongoing
towards the development of a set of robust iTTC values that could be utilised in human safety
assessment. It is, however, clear that developing an iTTC database is complex and more
research is required beyond current attempts where NOAELs were only adjusted for by
applying in silico tools (Ellison et al., 2019; Rogiers et al., 2020). While work is ongoing to
develop robust iTTC thresholds, an interim conservative iTTC of 1 μM plasma concentration
for chemicals in consumer products has been proposed, which is supported by the published
experience of the pharmaceutical industry, a literature review of non-drug chemical/receptor
interactions, and analysis of ToxCast™ data. This is, however, with the additional exclusion
to the original TTC exclusion criteria of the estrogen and androgen receptors as targets of
concern for low dose exposures.
Efforts are still ongoing to further extend/ refine the TTC framework for inhalation TTC and
internal TTC. From the point of view of NAMs, it is clear that the TTC and/or iTTC concepts
will be of great value in the future.
3-6 SPECIAL CONSIDERATION FOR CERTAIN COSMETIC INGREDIENTS
3-6.1 MULTI-CONSTITUENT NATURAL INGREDIENTS
Many cosmetic ingredients can be mixtures of multiple substances of natural origin, e.g.
essential oils and fragrances; they often can considerably vary in their composition depending
on their geographical origin, conditions of harvest, storage, further technical processing etc.
In such cases, the cosmetic ingredient should contain the following information:
qualitative identification and semi-quantitative concentrations of the substances in the
mixture (e.g. <5%) using the preferred terminology as indicated in Section II of the
Inventory of Cosmetic Ingredients and the INCI/CIN name if available;
for mixtures of variable composition, an indication of the range and the maximum
levels of components which may be present in the mixture, taking into account batch
to batch variation;
a clear indication of the cosmetic product category in which the mixture may be used
and at what maximum concentration.
Case by case, in the final safety evaluation, reference should be made to the semi-
quantitative composition of the multi-constituent ingredient and the toxic potential of
components should be considered.
Specific labelling to reduce the incidence of contact-allergic reactions in fragrance-
sensitive consumers has been foreseen by the inclusion of 26 potentially sensitising
fragrance substances in Commission Regulation (EU) 2019/831 amended Annex III to
Regulation (EC) No 1223/2009.
More specifically, the presence of these substances must be indicated in the list of substances
on the label when their concentrations in the final product exceed 0.001% in leave-on
products or 0.01% in rinse-off products (2003/15/EC).
The SCCS has adopted an Opinion on fragrance allergens in cosmetic products which enlarges
the list of fragrance allergens considered relevant for consumers and which makes it possible
to derive a general threshold for substances with a higher number of recorded cases
(SCCS/1459/11).
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3-6.2 IDENTIFICATION OF MINERAL, ANIMAL, BOTANICAL AND BIOTECHNOLOGICAL INGREDIENTS
IN A COSMETIC PRODUCT
The nature and preparation of some substances may affect the type and amount of data
necessary for their identification. The following points indicate the advised requirements for:
a) Complex substances of mineral origin
starting material
description of:
- the preparation process: physical processing, chemical modifications, possible
purification,
- characteristic elements of the composition: characteristic components, known toxic
components (%).
physical and chemical specifications
microbiological quality
preservatives and/or other additives added.
b) Complex substances of animal origin
When animal-derived cosmetic substances are used, this should be clearly mentioned (see
3.6.3)
species (bovine, ovine, crustacean, …)
organs, tissues, biological liquids (placenta, serum, cartilage, ...)
country of origin
description of:
- the preparation process: conditions of extraction (solvent, pH, temperature, …); type
of hydrolysis (acidic, enzymatic, …); other chemical modifications; possible purification;
- commercial form: powder, solution, suspension, freeze-dried,
- characteristic elements of the composition: characteristic amino acids, total nitrogen,
proteins, polysaccharides, molecular mass,
physical and chemical specifications
microbiological quality including relevant viral contamination
additional external contamination
preservatives and/or other additives added.
c) Complex substances of botanical origin
common or usual names of the plant, alga or macroscopic fungus
name of variety, species, genus, and family
in case more than one variety of source of a given species is used, each should be specified
organoleptic, macroscopic and microscopic evaluation
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84
morphological and anatomical description (including gender, if applicable) and a
photograph of the plant or plant part, alga, or macroscopic fungus used
natural habitat and geographical distribution of the plant, alga, or macroscopic fungus
current sources of the plant, alga, or macroscopic fungus, including its geographical
location and whether it is cultivated or harvested from the wild
description of:
- preparation process: collection, washing, drying, extraction, distillation, destructive
distillation, possible purification, preservation procedures, …;
- handling, transportation, storage;
- commercial form: powder, solution, suspension, …;
- characteristic elements of the composition: identification of characteristic components,
known toxic components (%);
physical and chemical specifications
microbiological quality including relevant fungi
additional external contamination
preservatives and/or other additives added.
d) Complex substances derived from biotechnology
For special biotechnologically derived substances, where a modified microorganism or a
potential toxic substance has not been fully removed, specific data must be available, which
can comprise:
description of organisms involved: donor organisms, recipient organisms, modified
microorganisms
host pathogenicity
toxicity, and when possible, identity of metabolites, toxins produced by the organisms
fate of viable organisms in the environment-survival-potential for transfer of
characteristics to e.g. natural bacteria
physical and chemical specifications
microbiological quality
additional external contamination
preservatives and/or other additives added.
3-6.3 ANIMAL-DERIVED COSMETIC SUBSTANCES
When animal derived cosmetic substances are used, this should be clearly mentioned.
Entry no. 419 in Commission Reg. (EU) 2019/831 amended Annex II of Reg. 1223/2009/EU
specifies several substances for which some concern exists for human health with respect to
Transmissible Spongiform Encephalopathy (TSE).
419. Category 1 material and Category 2 material as defined in Articles 8 and 9, respectively
of Regulation (EC) No 1069/2009 of the European Parliament and of the Council of 21
October 2009 and substances derived therefrom
10
.”
10
OJ L 300, 14.11.2009, p. 1
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85
As indicated, tallow derivatives of bovine origin are considered as an exception and are
accepted as cosmetic substances provided they undergo a number of specific treatments.
At present, there is no evidence that TSE may be transmitted by topical exposure.
Finally, taking into account EC Regulation No 1069/2009 laying down health rules concerning
animal by-products not intended for human consumption, the SCCP was of the opinion that
substances derived from category 1 (inter alia specific risk material) and category 2 (inter
alia 'fallen stock') material raise concern in terms of biological risk for human health and
therefore must not be present in cosmetic products (SCCP/0933/05). Category 3 material is
not intended for human consumption, but it may be used as cosmetic substance in accordance
with Regulation 1069/2009, Article 33.
Non-animal derived supplements for in vitro testing should be used wherever possible. The
chemically defined/serum-free cell culture media can be found in several in vitro test methods
for skin corrosion, skin irritation and eye irritation testing (OECD 431, 439 and 492) (van der
Valk et al., 2017).
3-6.4 SUN PROTECTION SUBSTANCES
For sunscreen lotion, an amount of 18.0 g/day is used in the MoS calculation. It is used
as a standard exposure value in the safety evaluation carried out by the SCCS but is not
meant as a recommended amount to be applied by the consumer (SCCNFP/0321/02).
To reach a comparable level as indicated by the Sun Protection Factor (SPF), sunscreen
products have to be applied in quantities similar to the ones used for SPF testing, i.e. 2
mg/cm
2
(total amount of approx. 36 grams) for the body of an average adult person
(2006/647/EC). The quantity of 2 mg/cm
2
, however, is the amount necessary to obtain
reproducible SPF results under laboratory conditions. It is higher than the amount usually
applied by consumers.
This observation has been reported frequently: when consumers use their own sun products
(lotions, alcoholic solutions, gels, creams, sprays,…) and apply the products on the whole
body surface, values for use of products between 0.5 - 1.3 mg/cm² have been found
(Stenberg et al., 1985; Bech-Thomsen et al., 1993; Diffey, 1996; Gottlieb et al., 1997; Autier
et al., 2001 and 2007). The values seem to depend on the study protocol used, the location
on the body measured and several other factors. More recent publications still come to
comparable values in the range of 0.39-1 mg/cm² (Danish Protection Agency No. 151, 2016,
Ficheux et al., 2016a, Gomez-Berrada et al., 2017). When the product is applied only to the
face, then the amount applied might be higher than 2 mg/cm
2
(Gomez-Berrada et al., 2017).
The amount used by the SCCS in safety calculations reflects actual consumer use and takes
the whole body area (17500 cm
2
) into account. The average exposed skin area of sunscreen
users according to the recent report of the Danish authorities is 14,700 cm
2
.
The use of 18g/d sunscreen corresponds with the values reported by Biesterbos et al.
(Biesterbos et al., 2013), who found a mean use amount of 9.2 g/application, derived on the
basis of pictures. If two applications are considered, this is about 18 g/d. Unpublished data
by von Goetz (von Goetz, 2018) from a small-scale pilot study with weighing also provided a
mean of 9 g for whole-body application (5 applications by 2 persons).
If a sun protection substance is applied in a sprayable product that may give consumer lung
exposure by inhalation, other considerations should be taken into account (see 3-3.4.1.3).
For lipcare products, 100% absorption of the substance should be considered for safety
assessment.
3-6.5 ENDOCRINE ACTIVE SUBSTANCES (EAS)
3-6.5.1 DEFINITIONS
Some natural and synthetic chemical substances can interact, interfere or disrupt the function
of the endocrine system that regulates various metabolic and developmental functions in the
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86
body (WHO/IPCS, 2002; UNEP/WHO, 2012). The endocrine system comprises a complex
array of signalling and feedback mechanisms, the disruption of which has been linked to
various adverse health effects, such as reproductive effects, metabolic disorders, cognitive
deficits and cancers. However, the endocrine system also involves numerous cycles and
feedback loop mechanisms and adaptive responses that together regulate the secretion of
hormones and maintain homeostasis. A substance interfering with the endocrine system may
affect hormone secretion or other cellular factors, but it is possible that such perturbations
remain within the homeostatic or metabolic detoxification capacity and therefore do not result
in adverse effects in the intact organism. Some effects linked to endocrine disruption have
also been shown to have critical window(s) of susceptibility, e.g. increased susceptibility of
an organism within a certain developmental period.
-The definition of Endocrine Disrupters (EDs) endorsed at the European level
11
is the same as
proposed by WHO/IPCS (WHO/IPCS, 2002) and is as follows: An endocrine disruptor is an
exogenous substance or mixture that alters function(s) of the endocrine system and
consequently causes adverse health effects in an intact organism, or its progeny, or
(sub)populations”.
-The OECD's revised conceptual framework (OECD TG 150) also has a prerequisite to identify
the adverse effect in an intact organism for regarding a substance an endocrine disruptor.
Thus, whilst a chemical may be regarded an EAS on the basis of activity/interaction towards
one or more components of the endocrine system (e.g., a hormone receptor), it can only be
regarded as an ED if there is evidence for a biologically-plausible causal relationship between
the endocrine perturbation/activity and the adverse effect(s) in an intact organism.
-The joint EFSA/ECHA/JRC draft guidance (EFSA and ECHA, JRC, 2018) has defined endocrine
activity as 'Interaction with the endocrine system which can potentially result in an effect on
the endocrine system, target organs and tissues'
3-6.5.2 IDENTIFICATION OF EDS AND REGULATORY CONSEQUENCES
A number of chemicals have been identified, or are suspected, as EDs. However, "only a small
fraction of these chemicals has been investigated in tests capable of identifying overt
endocrine effects in intact organisms" (WHO-UNEP report, 2012).
Under REACH, EDs can be identified as Substances of Very High Concern (SVHC) alongside
chemicals known to cause cancer, mutations and toxicity to reproduction. There are several
substances identified as SVHC for their endocrine disrupting properties in the Candidate List
of SVHC for authorisation (https://echa.europa.eu/candidate-list-table).
Amongst other actions, the Commission launched the Fitness Check: https://eur-
lex.europa.eu/legal-content/EN/TXT/?qid=1553617067256&uri=CELEX:52018DC0734 and
regulated ED substances in specific areas, including chemicals (Regulation EC 1907/2006),
Pesticides (Regulation EC 1107/2009), Biocides (Regulation EU 528/2012), Water quality
(Water Framework Directive 2000/60/EC).
3-6.5.3 STEPWISE APPROACH FOR COSMETICS AND THEIR INGREDIENTS
For cosmetics, the Commission adopted a review of the Cosmetics Regulation regarding
substances with endocrine disrupting properties
12
. It was concluded that adequate tools are
available to regulate the use of cosmetic substances that present a potential risk for human
12
Commission Regulation (EU) 2018/605 of 19 April 2018 amending Annex II to Regulation (EC) No 1107/2009 by
setting out scientific criteria for the determination of endocrine disrupting properties. OJ L 101, 20.4.2018, p. 33
36.
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87
health, including when displaying ED properties. For environmental concerns, application of
the REACH Regulation’ is considered.
The SCCS is following this process closely and is actively engaged in the safety assessment
of potential ED substances used in cosmetics.
Due to the animal testing ban under the Cosmetics Regulation, it is now out of scope to test
cosmetic ingredients in vivo for endocrine disruption. Cosmetic ingredients therefore can be
assessed for endocrine activity in a stepwise approach using data generated outside the
cosmetic field or for a new cosmetic ingredient, using NAMs (in silico models, read across, in
vitro assays, other mechanistic techniques such as 'omics').
Among the various endocrine modalities, Estrogen (E), Androgen (A), Thyroid (T) and
Steroidogenic (S) - (EATS) pathways are the best characterised, whereas retinoid signalling
and hypothalamo-pituitary-thyroid axis are poorly investigated (Kortenkamp et al., 2011;
UNEP/WHO, 2012).
The OECD 150 guideline provides tools on how to assess endocrine properties of a substance.
The general approach taken by this GD is primarily to consider the possible results that might
be obtained from each endocrine disruption-responsive assay and to provide guidance about
how these results might be interpreted in light of data that may or may not already be
available from other in vitro or in vivo assays. This should include all available data such as
publications in the peer-reviewed literature as well as TGs. In order to inform this
interpretation, background data on the assays addressed, non-testing approaches and other
considerations relevant to the assays are discussed. These include cross-species
extrapolations, read-across and multiple Modes of Action (MoA). The nature, quantity and
quality of the existing and new data in each of the scenarios for the endocrine disruption-
responsive assays should be evaluated systematically in a WoE approach. There is generally
no single “right” answer. Use of other technologies (e.g. omics” data) may help in
understanding the link between endocrine-related mechanisms and a WoE approach. This GD
should therefore be used flexibly in light of local regulatory needs. The key questions
addressed concern likely mechanisms of endocrine action and any resulting apical effects that
can be attributed to such action. In Table 10 the conceptual framework for testing and
assessment of EDs as provided in OECD guideline 150 is shown.
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Table 10: OECD conceptual framework for testing and assessment of EDs
QSARS = Quantitative Structure Activity Relationship;
For a new cosmetic ingredient, due to the animal testing ban, characterisation will, however,
be limited to the study of endocrine activity at level 1 (existing data and using in vivo data
if they have been generated before the animal ban or for another regulatory purpose than
cosmetics) and level 2 (in vitro assays) of the OECD's revised Conceptual Framework as
described below.
Lines of evidence level-1 (existing data and non-test information):
The first level of evidence for endocrine activity of a substance may be provided by: physical
and chemical properties (e.g., MW, reactivity, volatility, biodegradability), all available
(eco)toxicological data from standardised or non-standardised tests, read-across, chemical
categories, QSARs and other in silico predictions, and ADME model predictions for a new
compound intended for use in a cosmetic product, the use of in silico models and read-across
tools, together with physicochemical data.
A number of in silico models and tools are available for the estimation of a substance's
potential for binding with hormone receptors, such as the Estrogen Receptor (ER), the
Androgen Receptor (AR), and the Pregnane X Receptor (PXR). These include commercial
programmess such as ADMET Predictor™ and MetaDrug™, as well as publicly available tools
such as VEGA and Online Chemical Modeling Environment (OCHEM). Another open source
docking tool, Endocrine Disruptome, is also available for virtual screening of EDs (see EFSA
and ECHA, JRC, 2018).
In addition, databases are available that provide some information on endocrine properties
of chemical substances
13
. These may be subject to some criticism (e.g., inaccurate
information, some entries not enough documented). Endocrine Disruptor Screening Program
(EDSP) Tier 1 screening assay results and the dataset from Collaborative Estrogen Receptor
13
Endocrine active substances information system (EASIS) (EC JRC); ToxCast (US EPA); ToxCast ER prediction
model (US EPA); SIN List (International chemical secretariat); The endocrine disruption exchange (TEDX);
Endocrine disruptor screening program, EDSP21 (US EPA); Endocrine disruptor knowledge base, EDKB database
(US FDA); Estrogenic activity database, EADB (US FDA); Toxicology data network (Toxnet); Developmental and
Reproductive Toxicology database (DART); NURSA (nuclear receptor signalling atlas); OECD (Q)SAR toolbox
(OECD, ECHA); AOP knowledge base (OECD); ToxRefDB (US EPA); eChem portal (OECD); COSMOS database -
cosmetic ingredients; Danish (Q)SAR Database; (Q)SAR Data Bank
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89
Activity Prediction Project (CERAPP) are also reported in Mansouri et al., 2016. These
databases may also enable read-across for endocrine activity and provide a basis for further
development of structure-activity based predictive models. Some of these databases also
contain in vivo experimental data.
Amongst the available in silico tools, the OECD QSAR Toolbox offers a major software platform
that incorporates several databases comprising chemical data, experimental
(eco)toxicological data, and estimated values from QSAR tools, together with incorporated
QSAR modelling tools and Expert Systems. For example, it contains:
- The OASIS Estrogen Binding Database, consisting of diverse compounds with relative
Endocrine Receptor Binding Assay (ERBA) data. The Toolbox allows in silico screening of
a compound’s endocrine activity through Danish EPA's Relative ERBA (Q)SAR, which is
based on ER binding in vitro.
- QSAR models, including MultiCASE ERBA QSAR, which is based on a hierarchical statistical
analysis of a training set composed of ER binding data on a variety of chemical structures
that are inactive, weak, or powerful ER binders.
- Structural-alert based ER-binding profiler to classify chemicals as non-binders or binders
(weak, moderate, strong and very strong binders) depending on their MW and structural
characteristics.
- Structural-alert based expert systems, such as the US EPA's rtnER expert system based
on binding to the rainbow trout estrogen receptor.
The OECD QSAR Toolbox also provides a major platform for read-across between chemicals
that share structural and/or functional similarities, using a substantial set of high quality
databases. If compounds in the database are identified with the required structural and alert
profile similarities to the target compound, they may be used as read-across candidates for
the prediction of the ER binding of the target compound.
Other in silico systems based on molecular docking tools and 3D-(Q)SAR models are also
available that allow virtual screening of chemical substances for affinity/binding with hormone
receptors (Jacobs, 2004; Vedani et al., 2012; Galli, 2014). The identification of
affinity/binding to a hormone receptor by virtual screening, however, needs to be seen in the
context of the scoring function used for each target, because a universally applicable scoring
function is not yet available (Vuorinen et al., 2013). Also, whilst in silico models can reliably
predict simple endpoints, such as the binding free energy toward the receptor binding, they
have a limitation for the prediction of more complex endocrine related in vivo endpoints, such
as reproductive and developmental toxicity.
The available experimental data are still too scarce to allow comparison between the success
rates of the results from different in silico methods (Vuorinen et al., 2013). The topic has
been recently reviewed by Schneider et al. (2019), who highlighted that whilst in silico
prediction approaches provide first stage indication of ED properties, further modeling of
intermolecular interactions and cellular behavior is also essential to understand the potential
effects on the endocrine system.
Lines of evidence level-2 (in vitro assays providing data about selected
endocrine mechanism(s)/ pathways(s) (mammalian and non-mammalian
methods).
The currently available in vitro methods include estrogen, androgen, or steroidogenic receptor
binding assays, whilst methods relevant to thyroid hormone are not sufficiently sensitive to
completely exclude effects due to disruption of thyroid-related functions. A validation study
on 17 methods for the detection of thyroid disruptors was launched by EURL ECVAM (JRC
2017). The available in vitro methods are listed below:
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90
- Estrogen (OECD TG 493) or androgen receptor binding affinity (US EPA TG OPPTS
890.1150) (OPPTS stands for Test guidelines for pesticides and toxic substances).
- Estrogen receptor transactivation (OECD TG 455),
- Yeast estrogen screen (ISO 19040-1,2&3)
- Androgen receptor transcriptional activation (OECD TG 458)
- Steroidogenesis in vitro (OECD TG 456)
- Aromatase Assay (US EPA TG OPPT 890.1200)
- Thyroid disruption assays (e.g., thyroperoxidase inhibition, transthyretin binding)
- Retinoid receptor transactivation assays
- Other hormone receptors assays as appropriate
- High-throughput screens (See OECD GD No. 211 describing Non-Guideline In vitro Test
Methods: OECD 2014c)
Whilst the results from Levels 1 and 2 approaches can be indicative of endocrine activity of a
cosmetic ingredient, they will not definitively inform whether the substance will cause adverse
effect(s) in the intact organism to be regarded an ED. In view of this limitation, it is important
that all the evidence from physicochemical properties, available literature, in silico models,
read-across, in vitro assays, and other techniques (such as -omics”) is integrated in a
systematic manner to generate sufficient WoE to exclude the potential toxicity of a cosmetic
ingredient through the endocrine related effects. The integration of in silico methods and
computational systems biology has been proposed as a means to more critically assess the
endocrine activity of chemical substances (Ruiz et al., 2017). Some key characteristics of EDs
have also been proposed following an expert consensus statement as a basis for hazard
identification (Merill et al., 2020).
3-6.5.4 COSMETIC INGREDIENTS SUSPECTED TO HAVE ED PROPERTIES
As yet there is no harmonised approach towards health risk assessment procedures for EDs
within the different regulatory frameworks in the EU. The SCCS has issued a memorandum
(SCCS/1544/14) to clarify its position on substances with potential ED properties when used
as cosmetic ingredients. In the context of the animal testing ban, it is not possible for the
SCCS to fulfill the criteria as laid out under the OECD Conceptual Framework for the
identification of EDs for cosmetic ingredients in the context of the animal testing ban.
In the view of the SCCS, these substances should be treated like other substances of concern
for human health and therefore be subject to risk assessment and not only hazard
assessment.
This is in agreement with the past and current evaluations by the SCCS in regard to the safety
assessment of cosmetic ingredients with suspected ED properties e.g., parabens
(SCCP/1017/06, SCCP/1183/08, SCCS/1348/10, SCCS/1446/11, SCCS/1514/13), triclosan
(SCCP/1192/08, SCCS/1414/11), homosalate (SCCP/1086/07), benzophenones, 4-
methylbenzylidene camphor and 3-benzylidene camphor (SCCNFP/0483/01, SCCP/1183/08,
SCCS/1513/13), melatonin (SCCS/1315/10), resorcinol (SCCS/1270/09), cyclomethicone
(SCCS/1241/10), decamethylcyclopentasiloxane (cyclopentasiloxane) (SCCS/1549/15).
Ingredients with potential endocrine disrupting properties used in cosmetic products are taken
up in a list of 28 compounds to be considered by the SCCS for safety evaluation. 14
substances of this list are considered high priority and are currently being assessed by the
SCCS. These are benzophenone-3, kojic acid, 4-methylbenzylidene camphor, propylparaben,
triclosan, resorcinol, octocrylene, triclocarban, butylated hydroxytoluene (BHT),
benzophenone, homosalate, benzyl salicylate, genistein and daidzein,
Another way forward could be to demonstrate what could be considered as biologically
irrelevant exposure. For instance, in the case of melatonin, topical application (in real use
conditions) did not perturb endogenous hormone levels in humans due to low systemic
exposure (SCCS/1315/10). Toxicokinetic studies and PBPK modelling could help to bridge the
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91
gap between in vivo and in vitro evidence by providing data on (internal) exposure in relation
to concentrations that were found to be active in in vitro assays (Coecke et al., 2013; Bessems
et al., 2014).
It also needs to be highlighted that the SCCS only assesses cosmetic ingredients in relation
to safety of consumers' health, and as such they are not assessed for effects on the
environment. Data generated on the environmental effects may, however, be also useful to
support EA/ED mode of action but not their potency. For example, some ecotox tests may be
informative for the assessment of endocrine activity of a compound in humans or thyroid
effects (e.g. Xenopus Eleutheroembryonic Thyroid Assay (XETA) (OECD 248), Amphibian
Metamorphosis Assay (AMA) (OECD Test 231), Larval Amphibian Growth and Development
Assay (LAGDA) (OECD Test N° 241).
A recent review has indicated a high degree of confidence in the conservation of the HPG-
axis between fish and mammals, and the HPT-axis between amphibians and mammals
(McArdle et al., 2020).
An ongoing EU project ERGO (https://ergo-project.eu/) is looking into the scientific basis that
could bridge the current divide between human health and the environment in terms of non-
mammalian testing for the identification of EDs (with a focus on the thyroid system) for the
chemicals that affect endocrine axes across vertebrate classes.
3-6.6 CMR SUBSTANCES
Based on their inherent properties, hazardous chemicals are classified accordingly on a world-
wide (Globally Harmonised System) and European level (Regulation 1272/2008). Special
attention is given to substances that are carcinogenic, germ and somatic cell mutagenic or
toxic for reproduction for which three hazard classes exist according to these frameworks,
i.e. Category 1A, 1B and 2. Cat 1A means that the substance is known to have the respective
potential in humans, Cat 1B means that the substance is presumed to have the respective
potential in humans, and Cat. 2 means that the substance is suspected to have the respective
potential in humans.
CMR 1A, 1B and 2 substances are prohibited for use in cosmetics, unless the specific criteria
set in Cosmetics Regulation (EC) No 1223/2009 are fulfilled, whereby criteria are stronger
for CMR 1A and 1B substances compared to CMR 2 substances
CMR 2 substances may be used in cosmetics where they have been evaluated by the SCCS
and found safe. These substances could be allowed to be used as cosmetic substances within
Europe under specific conditions. Examples for CMR2 substances include trisodium
nitriloacetate (SCCS/1391/10), trimethylbenzoyldiphenylphosphine oxide (TPO)
(SCCS/1528/14) polyaminopropyl biguanide (PHMB) (SCCS/1581/16), lysmeral
(SCCS/1591/17), salicylic acid (SCCS/1601/18), pigmentary TiO
2
(SCCS/1617/20).
CMR 1A or 1B substances may be used in cosmetics exceptionally where (1) they comply
with the European food safety requirements
14
, (2) they cannot be replaced by suitable
alternatives, (3) the application is made for a particular use of the product category with a
known exposure and (4) the substances were evaluated and found safe by the SCCS for use
in cosmetic products, in particular in view of exposure to these products and taking into
consideration the overall exposure from other sources, taking particular account of vulnerable
population subgroups (2009/1223/EC). Examples for CMR 1B substances include boron
compounds (SCCS/1523/13), formaldehyde in nail hardener (SCCS/1538/14) and zinc
pyrithione (SCCS/1614/19).
A guidance document has been developed by the EU Commission with the aim of enabling a
harmonised approach to the development and use of aggregate exposure estimates in
assessing the safe use of CMR substances as cosmetic ingredients (see Appendix 5).
14
Regulation (EC) No. 178/2002
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92
However, as clarification and as agreed by the Commission, whereas the applicant is
responsible for providing the exposure data on CMR substances, the procedure described in
No. 16-19, 21 and 22 of the Guidance, is only foreseen in case that the applicant for any
reason cannot obtain the data from the owner of the data required.
3-6.7 LIFETIME CANCER RISK (LCR)
In the safety assessment of carcinogenic substances, an appropriate dose descriptor, BMDL10
or T25, should be identified, whenever sufficient information is available (ECHA, 2019; EFSA,
2019b; COC, 2020). The SCCS recommends that, where possible, the BMD approach should
be used for deriving a POD, as a starting point for human health risk assessment, including
carcinogenicity by a genotoxic or non-genotoxic mode of action. This view is also supported
by other bodies including the EFSA and the Committee on Carcinogenicity of Chemicals in
Food, Consumer Products and the Environment (COC). In the absence of dose-response data
allowing for the application of the BMD approach, the T25 is a simplified method to estimate
the carcinogenic potency of a given substance.
The T25 (expressed as mg/kg bw/d) is defined as the dose which leads to the development
of tumours at a specific tissue site in 25% of the animals after correction for spontaneous
incidence and within the standard lifetime of the species (Dybing et al., 1997). The
determination of BMDL10 (expressed as mg/kg bw/d) uses mathematical curve fitting
techniques to calculate the lower 95% confidence level at a 10% benchmark response. Both
BMDL10 and T25 can be used as starting points to determine an additional LCR or to calculate
a MoE, which represents the ratio between a dose descriptor and the estimated human
exposure dose. Basic steps in LCR calculations based on T25 are provided in Appendix 12.
Some countries and international organisations have considered that the LCR in the general
population of less than 10
-5
is considered tolerable (SCCS/1486/12). Under REACH, the
"indicative tolerable cancer risk level" for the general population is 10
-6
(ECHA 2012a). It
should be noted that the tolerable LCR is a risk management issue and outside the scope of
the mandate of the SCCS.
3-6.8 NANOMATERIALS
3-6.8.1 DEFINITION OF NANOMATERIAL
Regulation (EC) No 1223/2009 specifically covers the use of nanomaterials in cosmetic
products. The Regulation provides a definition of nanomaterial, as well as a mechanism for
notification, labelling, and safety evaluation of cosmetic products containing nanomaterials.
Under Article 2 (1) (k), nanomaterial” means an insoluble or bio-persistent and intentionally
manufactured material with one or more external dimensions, or an internal structure, on the
scale from 1 to 100 nm”.
The Regulation therefore covers mainly those nanomaterials that are intentionally produced
and are insoluble/poorly-soluble or biopersistent (e.g., metals, metal oxides, carbon
materials, etc.), and not those that are either completely soluble or degraded and are not
persistent in biological systems (e.g., liposomes, oil/water emulsions, etc.).
When dealing with the question of solubility, as provided in the current definition, it is
important to note that any nano-specific risk may change (even diminish) when a
nanomaterial is dissolved. But it is the time period during which the dissolution happens that
determines the considerations for risk assessment based on either particle risk or soluble
substance risk. Partial dissolution over a long period of time may lead to the mistaken claim
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that the material is 'soluble', and therefore not a nanomaterial under the scope of the current
definition provided in the Cosmetic Regulation (EC) No 1223/2009.
3-6.8.2 POTENTIAL SAFETY ISSUES OF NANOMATERIALS
The use of nanomaterials in cosmetics is subject to a high level of protection of human health
under the EU Cosmetics Regulation. This is because nano forms of some substances may
differ from their conventional (bulk) forms in terms of physicochemical properties, biokinetic
behaviour, and/or biological effects. Any intended use of nanomaterials (other than
colourants, preservatives and UV filters and not otherwise restricted by the EU Cosmetics
Regulation) in cosmetic products must be notified to the Commission by the RP through the
Cosmetic Product Notification Portal (CPNP) at least six months prior to placing them on the
market, except if they were already on the market before 11 January 2013. In case of a
safety concern over a nanomaterial, the Commission shall request the SCCS for a scientific
Opinion on the safety of the nanomaterial for use in relevant categories of cosmetic products
in consideration of the reasonably foreseeable consumer exposure.
The SCCS was recently mandated by the Commission to provide scientific advice to facilitate
the identification of any safety concerns relating to the nanomaterials intended for use in
cosmetic products, so that they can be prioritised for safety assessment. The advice has
recently been published (SCCS/1618/2020), which provides the key scientific aspects of a
nanomaterial that should trigger consumer safety concerns, and therefore the need for further
evidence-based safety assessment.
Although there are currently no hard and fast rules for identifying the safety concerns for
nanomaterials, as a general principle, each of the following attributes should add a further
degree of safety concern. For example, where:
1. The nanomaterial has constituent particles that have sizes in the lower range of the
nanoscale.
2. The nanomaterial is insoluble, or only partially soluble.
3. The chemical nature of the nanomaterial suggests the potential for a toxicological hazard.
4. The nanomaterial has certain physical/morphological features (e.g. needle shape, rigid
long fibres) that point to the potential for harmful effects.
5. The nanomaterial has surface reactivity in terms of catalytic (including photocatalytic)
activity, potential for radical formation, or other surface properties (e.g. potential
allergenicity due to proteinaceous surface).
6. The nanomaterial has a different biokinetic behaviour than the conventional equivalent.
For example, a surface modification/coating (e.g. hydrophobic coatings, encapsulation)
has been applied to core nanoparticles to alter their ADME properties and as a result make
them more accessible systemically, compared to the neat nanoparticles and/or their
conventional chemical forms.
7. The nanomaterial is used as vehicle to carry other substances that have not been assessed
for safety as individual components, or together in the form of nano-scale entity.
8. There is a likelihood of systemic exposure of the consumer to nanoparticles through the
use of final products. The frequency of use, and/or the amounts of the relevant consumer
product are relatively high.
9. There is evidence for persistence/accumulation of nanoparticles in the body.
10. Nanoparticles have other distinctive properties not present in conventional form of the
same material, or have a new activity/function (e.g. a smart/functional nanomaterial).
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11. The nanomaterial is so novel that it does not have a conventional comparator to allow
assessment of changes in properties, behaviour or effects.
12. The nanomaterial is used in a product that is inhalable (taken up by inhalation into
respiratory tract and lung), and the particles are respirable (can reach respiratory
epithelium i.e. alveoli).
13. The assessment of genotoxicity is performed inadequately, e.g. in vitro studies are without
information on stability of the test suspension, or evidence of cell exposure
(internalisation).
Whilst this section only provides a brief guidance on nanomaterials in cosmetics, the SCCS
has published a more detailed specific Guidance on Risk Assessment of Nanomaterials
(SCCS/1611/19), which is an update of a previous guidance published in 2012
(SCCS/1484/12), a Memorandum on the Relevance, Adequacy and Quality of the Data
Expected in Safety Dossiers on Nanomaterials (SCCS/1524/13, Revision of 27 March 2014),
and a checklist for the applicants submitting dossiers on nanomaterials as cosmetic
ingredients (SCCS/1588/17).
Safety assessors need to consult these documents to ensure that any testing to generate
evidence on the safety of nanomaterials is carried out with special considerations of the nano-
size related characteristics of the materials, and in compliance with the ban on animal testing
of cosmetic ingredients. In this regard, it is important to note that, as indicated in the
memorandum (SCCS/1524/13, Revision of 27 March 2014), the SCCS will only consider data
that are relevant to the nanomaterial(s) under evaluation, are sufficiently complete, and are
of appropriate quality to support the safety assessment.
The SCCS has also published a number of scientific opinions in the past few years on the
nano-form of different materials. These include 1,3,5-triazine, 2,4,6-tris[1,1’-biphenyl]-4-yl-
(ETH50)
(SCCS/1429/11, revision of 13/14 December 2011); zinc oxide (SCCS/1489/12
revision of 11 December 2012); titanium dioxide
(SCCS/1516/13, revision of 22 April 2014);
carbon black
(SCCS/1515/13, revision of 15 December 2015), 2,2’-methylene-bis-(6-(2H-
benzotriazol-2-yl)-4-(1,1,3,3-tetramethylbutyl)phenol), MBBT (SCCS/1460/11), silica
(SCCS/1545/15), hydroxyapatite (SCCS/1566/15); additional coatings for titanium dioxide
(SCCS/1580/16); and titanium dioxide in sprays (SCCS/1583/17). Styrene/Acrylates
copolymer (nano) and Sodium styrene/Acrylates copolymer (nano) (SCCS/1595/18);
Colloidal Silver (SCCS/1596/18); Solubility of Synthetic Amorphous Silica (SAS)
(SCCS/1606/19). These opinions can provide further information on the type of scientific
evidence needed in a safety dossier on nanomaterials intended for use as cosmetic
ingredients.
In general, a number of reviews have concluded that the existing risk assessment paradigm,
in use for conventional chemicals, should in principle be also applicable to engineered
nanomaterials. However, it has also been pointed out that the current testing methods may
need certain adaptations to take account of the special features of nanomaterials (Rocks et
al., 2008; SCENIHR, 2009; OECD, 2009c; SCCS, 2012; EC, 2012; ECHA, 2017; EFSA, 2018).
Special features of nanomaterials:
i. Due to high surface energies, nanoparticles have a tendency to stick together to form
agglomerates and aggregates, and/or bind with other moieties on the particle surface.
This particle behaviour can change in the presence of certain stabilising/dispersing agents.
Characterisation of nanomaterials, prior to and during a test, is therefore a key to ensuring
that results obtained are valid.
ii. Most of the currently available test methods were developed for conventional substances
that can be solubilised. In contrast, nanomaterials generally comprise insoluble or poorly
soluble nanoparticles that are dispersed in a test medium in the form of a nano-suspension
rather than a solution. The applied concentration of a nanomaterial may therefore drop
during the test due to particle agglomeration, sedimentation, binding with other moieties
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in the medium, or sticking to the sides of the glass/plastic ware. This could lead to only a
partial or no exposure of the test systems during the test. Nanomaterials are known to
adsorb or bind different substances on their surfaces, including proteins (Šimon and Joner,
2008; Lynch and Dawson, 2008; Monopoli et al., 2012; Moore et al., 2015). They may also
bind other substances in the test medium and carry them into the exposed test systems,
leading to artefacts in the results.
iii. The toxicological hazards of chemical substances are currently measured and expressed in
terms of weight or volume units (such as mg/kg, or mg/l). These conventional metrics
may not be fully adequate to account for nanomaterial toxicity. It is therefore important
that tests on nanomaterials are not only evaluated in terms of weight/volume
concentration, but that results are also expressed in other dose-describing metrics, such
as particle number concentration, surface area etc.
iv. Due to the insoluble particulate nature, and the nano-dimensions, nanomaterials may show
an altered uptake and biokinetic profile in a biological system compared to equivalent
conventional forms e.g. transport of insoluble particles across biological membrane
barriers is not driven by concentration-gradient based diffusion partitioning, but by other
mechanisms such as endocytosis and/or active (energy-driven) uptake and transport.
v. Currently, there are uncertainties in regard to whether the endpoints identified by the
current testing methods will be sufficient to identify and characterise all the hazards that
may be associated with a nanomaterial.
3-6.8.3 REQUIRED INFORMATION FOR NANOMATERIALS
The information required by the SCCS for the evaluation of nanomaterials as cosmetic
ingredients is described in SCCS/1588/17 and SCCS/1611/19.
The following aspects deserve special attention:
i. Although most analytical methods used routinely for chemical substances have not yet
been validated for nanomaterials, a careful choice of mainstream method(s) should provide
sufficient means to gather adequate characterisation data for nanomaterials. The use of
more than one method generally adds more confidence to the measured values e.g. for
the measurement of particle size distribution, additional imaging by electron microscopy
has been recommended by both SCCS (SCCS/1611/19) and EFSA (EFSA, 2011b; EFSA,
2018).
ii. Where there is evidence for systemic absorption, further investigations are required to
confirm whether the absorbed material was in a nanoparticle form or in
solubilised/ionic/metabolised form. Where the absorption of nanoparticles cannot be ruled
out either by experimental measurements or justified on the basis of solubility/degradation
of the nanomaterial, the SCCS may apply a default approach and assume that 100% of
the absorbed material was in nano form.
iii. Surface modification/surface coating may bring about profound changes in a nanomaterial
in regard to certain physicochemical properties and potentially the toxic effects.
iv. Therefore, a full dataset would be preferable. As a minimum, in addition to safety data on
the core nanomaterial, the SCCS would require the following:
Information/data on each material used for surface modification/coating of the
nanomaterial to indicate that it is safe for use in the intended cosmetic product.
Data on physicochemical properties of the surface-modified/coated nanomaterial
to show that they have not significantly changed compared to either the same
material when uncoated, or with a different surface modification/coating that has
already been assessed safe by the SCCS.
Data on dermal penetration, stability of the surface modification/coating, and
(photo)catalytic activity, where relevant.
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3-6.9 HAIR DYES AND HAIR DYE COMPONENTS
In April 2003 the Commission, together with the Member States, agreed on a step-by-step
strategy to regulate all hair dyes listed as substances in cosmetic products. The main element
of the strategy was a tiered, modular approach, requiring industry to submit by certain
deadlines safety dossiers for hair dye components and possible mixtures. This strategy was
supported by SCCNFP (SCCNFP/0807/04) through its "Opinion on hair dyes without file
submitted", in which the experts clearly expressed the demand for a safety dossier for all hair
dyes, irrespective whether they had already been taken up in one of the annexes of the
cosmetic legislation. Differentiation was made between temporary, semi-permanent and
permanent hair dyes (SCCP/0959/05).
To ensure the safety of hair dye products, the Commission decided to ban all permanent,
semi-permanent and temporary hair dyes for which industry did not submit any safety files
and those for which the SCCP had given a negative opinion (IP/06/1047).
In 2013, the SCCS confirmed the views expressed in an earlier Memorandum (SCCP, 2006),
that hair dye substances which fulfil the criteria for classification as Skin Sens 1, H317
(according to CLP) may not be safe for consumers and that this is particularly so for hair dye
substances categorised as extreme and strong sensitisers (SCCS/1509/13).
3-6.9.1 MOS CALCULATIONS FOR HAIR DYE FORMULATIONS
Intermittent exposure and MoS calculations: hair dyes are not intended to be applied on a
daily basis. However, the MoS is calculated by dividing the PoD for daily application by the
SED for a single application. Although this approach can be debated, this is used as a
conservative approach.
Thus, the daily dose should not be averaged over the whole year (ECHA, 2012a).
3-6.9.2 ASSESSMENT OF OXIDATIVE HAIR DYE SUBSTANCES AND REACTION PRODUCTS
The SCCS is focused on the overall consumer health risk caused by ingredients as well as
products and intermediates of oxidative hair dyes formed during hair dyeing processes
(including their potential mutagenic/genotoxic/carcinogenic properties). The following
conclusions were drawn in the SCCS’s opinion on reaction products of oxidative hair dye
ingredients formed during hair dyeing processes (SCCS/1311/10):
- Precursors and couplers with a variety of substituents such as hydroxy, amino, imino
carbonyl, hydroxyethyl, hydroxyethoxy and alkyl groups were included.
- The use of oxidative hair dye formulations results in consumer exposure to precursors and
couplers as well as to their reaction products. Exposure to these reaction products is
considered generally lower compared to that from precursors and couplers since dimers
and trimers are formed with higher molecular weight. No exposure to intermediates or
self-coupling products was detected under experimental conditions. Therefore, in the risk
assessment of reaction products, toxicity is not considered a concern due to the low and
intermittent exposure (on average once per month).
- The dermal absorption rates in the in vitro skin penetration studies of the 14 representative
reaction products evaluated ranged from 3.27 to 717.79 ng/cm
2
(mean + 1 SD). This
corresponds to 1.9 to 416 µg absorbed dose (i.e. dose potentially bioavailable) per hair
dye application (i.e. 0.03 to 6.9 µg/kg bw).
- As no data were made available for sensitisation risk of the reaction products, this endpoint
was not specifically addressed.
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- The use of (Q)SAR in the case of reaction products is of limited value so far since the
arylamine structure, a structural element of many hair dye precursors and reaction
products, is automatically identified as an alert. It is desirable to use or to develop in the
future SAR for in vivo genotoxicity which satisfies the OECD principles and has a known
applicability domain.
- Although for precursors, couplers and reaction products, positive results are commonly
observed in in vitro genotoxicity assays there is no clear evidence of genotoxicity in vivo
(in case in vivo data are available). It is possible that genotoxic effects can only be found
at concentrations where the N-acetylation (detoxifying) capacity of the cells is
overwhelmed, indicating that a ‘first-pass’ effect in skin could be taken into account for
risk assessment of the topically applied aromatic amines (Zeller and Pfuhler, 2014;
Nohynek et al., 2015).
- The structures of the primary intermediates and trimer molecules reveal that they contain
an aromatic secondary amino group, which if exposed to a nitrosating agent may form an
N-nitroso derivative (Lewis et al., 2013). Although, such transformation is theoretically
possible, no evidence was provided under real exposure conditions.
For all the above reasons, the SCCS performs the safety assessment of oxidative hair dyes
based on the toxicological evaluation of the ingredients (i.e. precursors and couplers) and not
the reaction products.
With regard to the animal testing ban for cosmetic ingredients, see Section 3-1 and the
scheme in Appendix 4.
3-6.10 COSMETIC INGREDIENTS FOR BABY AND CHILDREN PRODUCTS
In certain cases it may be necessary to calculate the MoS of cosmetic ingredients for a specific
subpopulation such as babies and children, e.g. exposure to leave-on cosmetic products
designed for application on the nappy area or products intended for children with a higher
sensitivity for certain endpoints. Also, differentiation between premature babies and full-
term neonates must be made since important structural and functional skin differences are
present. In particular, the barrier function in premature babies is impaired (Visscher et al.,
2015, 2020a, 2020b). Also, pH differences play a prominent role (Fluhr and Darlenski 2018;
Proksch 2018) which may be important for baby care products that are used often, such as
wet wipes (Rodriguez 2020; Gustin et al., 2020).
Here, only intact skin of full-term babies has been considered.
In light of potential differences in metabolism between newborns/infants up to six months
and adults, the question may be raised whether cosmetic ingredients would require a MoS
higher than 100 to cover exposure for these groups.
3-6.10.1 DEFINITIONS
“Children” are defined as developing human beings who are at various stages of immaturity
and maturation for up to nearly two decades, with age-dependent different susceptibilities
and sensitivities (Makri et al., 2004; Lemper et al., 2009) compared to adults.
Terms usually covered by the word “children” include:
- full-term neonate < 1 week
- newborn 1 week 2 months
- early infant 2 6 months
- crawler/toddler 6 months 2 years
- child/pre-adolescent 2 12 years
- adolescent 12 18 years
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3-6.10.2 AGE-RELATED SUSCEPTIBILITIES/SENSITIVITIES
The calculation of the MoS for children was discussed when the question was raised whether
it would be advisable to adjust the default assessment factor of 100 for children by multiplying
this factor by the difference in Skin Surface Area over Body Weight ratio (SSA/BW) between
adults and children (SCCNFP/0557/02). In these calculations, the bodyweight values available
at that time were used. Afterwards, updated values became available (EFSA, 2012b).
The ratio between the SSA/BW ratios of children and adults changes from 0 to 10 years and
is as follows (Renwick, 1998):
2.3 at birth,
1.8 at 6 months,
1.6 at 12 months,
1.5 at 5 years,
1.3 at 10 years.
The ratio between the SSA/BW children of 0 to 1 year of age and that of adults is at maximum
2.3. A factor of 3.2 is generally applied by the WHO and also covers variability in human
kinetics (see Section 3-5.1.3). Consequently, the inter-individual variation in SSA/BW is
covered by the generally accepted default value of 100 for intact skin (Figure 10 in Section
3-5.1.3). However, for specific compounds under consideration the potential differences in
metabolism between newborns/infants up to six months and adults could require extra
consideration.
In general, the SCCS is of the opinion that there is no need for an additional UF for children
when intact skin is considered (SCCNFP/0557/02).
For more information on UFs, see 3-4.8.1.
Risk assessment in the specific case of children” has been discussed for parabens as
preservatives in cosmetic products (SCCS/1446/11) and for phenoxyethanol
(SCCS/1575/16).
The rationale of additional UFs for different age groups beyond the usual factor of 100 has
been discussed in the scientific literature (e.g., Renwick et al., 1998 and 2000; Nielsen et al.,
2001; Makri et al., 2004; ECHA, 2012a).
A number of potential risk factors may exist for newborns and early infants. They are reviewed
in Annexes 2 and 4 of SCCS/1446/11. As dermal exposure in children is a topic of high
importance for several cosmetic substances, the most important points are summarised here.
An overview of potential risk factors for baby care products and their ingredients is also
available in Desmedt et al., 2014).
3-6.10.2.1 DERMAL EXPOSURE OF THE NEWBORN AND EARLY INFANT
15
- When born at full-term, the skin possesses all skin structures of adult skin, and
anatomically these structures do not undergo dramatic changes after birth. The dermal
absorption in skin of newborns is similar to that observed in adult skin, when the skin
is intact (see SCCS/1446/11) (Visscher et al., 2009 and 2015).
- Differences between newborns during their first weeks and months and adults are
described below:
(I) The surface area/body weight ratio (mentioned above) is 2.3-fold higher in newborns than
in adults, changing to 1.8- and 1.6-fold at 6 and 12 months, respectively. This is in general
covered by the intra-species factor of 10 (3.2 x 3.2) used in the calculation of MoS.
(II) Toxicokinetic parameters may differ between various age groups of children and adults
and can result in reduced metabolism, clearance and/or longer half-life that might either
15
The considerations in this section refer to neonates born at full-term and not to premature babies still under
medical care.
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increase or decrease the potential risk of an adverse reaction in newborns, depending on the
substance (Renwick et al., 2000; Nielsen et al., 2001, Felter et al., 2015). For the CYP450s
in the liver, lower activities in newborns/early infants as compared to adults have been
described (Johnson, 2003). These data suggest that the extent of bioactivation or metabolic
detoxification in children between one and ten years will in generally be lower than that in
adults. It is also known that detoxification of xenobiotic substances or metabolites by phase
II enzymes may be lower in newborns and infants compared to adults due to yet incomplete
development of Xenobiotic Metabolising Enzymes (XME) in the liver (e.g., UDP
GlucuronosylTransferase-1 (UGT1A1) and some esterases; see SCCS/1446/11). Therefore,
depending on the cosmetic ingredient in question, the balance between activating and
inactivating XME activities may be crucial for systemic exposure and should be considered
case by case. In general, however, it is assumed that a specific assessment factor for age-
related differences in toxicokinetics is not required (SCCS/1446/11). With respect to skin
metabolism, it is recognised that some metabolic enzymes seem to be less expressed in the
skin of children, in particular under the age of 1 year. Hence, neonates, newborns and early
infants might have higher internal exposure to certain cosmetic ingredients after dermal
application than adults. For a sound risk assessment, relevant human data regarding
metabolism are necessary. These data could for instance be gained by an approach combining
in vitro data on the metabolism of the cosmetic ingredient under investigation and PBPK/PBTK
modelling. For such toxicokinetic modelling of the biotransformation in humans of different
age groups, relevant in vitro data regarding phase I and phase II biotransformation are
needed both in human skin and liver (SCCS/1446/11).
(III) In-use conditions of topical products should be considered in exposure-based risk
assessment of the finished product. It should be noted that no comprehensive exposure data
for newborns and early infants, representative for Europe, are available in the open literature.
CoE is preparing aggregate exposure data for babies and children for different baby care
cosmetics used in Europe (more information, see Table A.7, Appendix 7).
Some information is available for the Netherlands at the RIVM, ConsExpo Fact Sheet (2006).
Data for French children have been published by Ficheux et al., 2017, 2019. Exposure data
for wipes used for Korean babies are available (Lee et al., 2017); also for the USA, DE and
UK,deterministic as well as probabilistic modelling has been carried out to determine the
transfer of wipes in babies and children (Dey et al., 2016a). Data for disposable diapers are
available from the same authors (Dey et al., 2016b).
(IV) The nappy area: the skin barrier function in the nappy area and non-nappy regions are
indistinguishable at birth but show differential behaviour over the first 14 days, with the
nappy region having a higher pH and increased hydration. With respect to skin hydration in
the nappy zone, newborns tend to have a somewhat higher water content in the horny layer
than observed for early infants and crawlers/toddlers up to one year. Also, the variations in
water content are higher. Skin pH is usually between 5-6, which is similar to the skin pH
measured for adult skin. However, the nappy area is susceptible to inflammation and the
buffering capacity is compromised (nappy dermatitis). This results in episodic acute skin
inflammation (mean duration 2 to 3 days) caused as well by physical, chemical andenzymatic
microbial factors in the nappy environment, for example acute skin inflammation of the nappy
zone occurs during changes in diet (breast feeding, bottle feeding, solid food) and may occur
in particular between 6-12 months of age.
See below for cosmetic products used in the nappy area.
(V) Susceptibility against microorganisms: this is in particular the case in the nappy area and
is a consequence of changes in the barrier function when the skin is damaged. Therefore,
baby cosmetics should be adequately preserved (as is the case for all cosmetics) and
formulated with an appropriate buffered pH.
With respect to points (I) to (III), there is generally no need for an additional assessment
factor for children when intact skin is involved. However, an additional assessment
factor might be relevant when the skin in the nappy area is damaged and substance-
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specific data clearly demonstrate that inter-individual variability would result in a value higher
than the default value of 10.
3-6.10.2.2 COSMETIC PRODUCTS USED IN THE NAPPY AREA
In the nappy area, special circumstances are present resulting from the close confining
clothes and nappies, uncontrolled urination and defecation and resulting problems with
potential damage of the skin in the nappy zone. Modern nappy technology has shown to
provide increasingly good skin compatibility, leading to a decline in the frequency and severity
of nappy dermatitis. In silico modeling of skin under the diaper has shown that healthy
diapering practices will ensure there is no significant impact on skin health and barrier
properties (Staadatmand et al., 2017). However, irritant nappy dermatitis cannot be
completely avoided and might have an impact on dermal absorption of substances.
As cosmetic products are meant to be used on intact skin, medical consultation is necessary
in the case of real skin damage and pharmaceutical products (and not cosmetics!) should be
used.
For the development of baby cosmetic products and the safety evaluation of the products
intended to be used in the nappy area, the potential impact of irritation on dermal absorption
of the ingredients needs to be considered by the safety assessor. It is known that the physico-
chemical properties of the substances under consideration also play a role.
A tiered quantitative approach to take the potential for diaper rash into consideration when
doing a safety evaluation for products used in the nappy area has been proposed by Felter et
al. (Felter et al., 2017).
3-6.11 SUBSTANCES WITH VERY LOW DERMAL ABSORPTION
In the case where a cosmetic ingredient is a substance with a very low dermal absorption
{see Section 3-3.5.1.1(c)}, some studies could be waived since systemic exposure via dermal
absorption is expected to be minimal. In such a case, the following minimum set of data
should be made available in order to assess the safety of cosmetic ingredients with very low
bioavailability:
- Experimentally determined physicochemical data
- Local toxicity
- Mutagenicity/Genotoxicity
- High quality in vitro dermal absorption study, according to the SCCS Basic Criteria {3-
3.5.1.1 (b}.
In these cases, the experimental mean value will be used for decision making.
3-7 FURTHER REMARKS FOR APPLICANTS
- When preparing a safety dossier, it would be useful if Applicants follow the same format
as adopted in the SCCS opinions (example given in Appendix 3).
- Whenever study results are submitted, a declaration should be made that the tests
involved were conducted using a cosmetic ingredient with a comparable purity/impurity
profile and physical and chemical characteristics of that to be included in the finished
cosmetic product.
- For multi-constituent natural ingredients, with variable composition, it is essential that
Applicants provide clearly defined specifications in view of the range of variability of the
components e.g. batch-to-batch.
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- Stability of the test substance under experimental conditions is of prime importance for
the interpretation of test results.
- The stability of the test material under conditions of use should also be reported.
- The Applicant should ensure that files submitted for evaluation are complete and signed.
Data should be obtained by means of studies conducted in accordance with test guidelines
reported in Regulation (EC) No 440/2008 (2008/440/EC) and amending ATP (Adaptation
to Technical and scientific Progress) Regulations, as well as the OECD test guidelines, and
complying with the principles of Good Laboratory Practice (GLP). All possible deviations
from validated methods or from GLP must be indicated, explained and scientifically
justified. There may be cases for which it is either not necessary or technically not possible
to provide some of the information mentioned above: in such cases a scientific justification
must be given by industry and/or relevant agencies.
- Together with the relevant experimental investigations, the following information should be
provided:
- for in vivo studies: the study date (whether in line with the Cosmetic
Regulation) and/or the regulatory context for which the study has been
performed;
- any report on epidemiological and/or observational experiences
(cosmetovigilance data);
- an appraisal of all relevant published literature, along with a description of the
bibliographical methods used; any information from "grey material" available.
Any other relevant findings by the Applicant and/or other industry/agencies,
should also be transmitted to the Commission for review.
- In their dossiers, the Applicants should indicate whether they consider any of the
data/tables/substances names, etc. confidential (typically impurities etc.) for commercial
reasons and provide relevant codes that can be used by the SCCS to anonymise the
confidential information.
- Safety data must relate to the same form of ingredients as present in a product for final
use keeping in mind that the formulation or preparation of the final product may change
the nature of the ingredients (e.g. permanent hair dye preparation).
- In case there is a negative SCCS Opinion, the Applicant must consider whether sufficient
new and relevant information is available to justify a resubmission. When a dossier is
resubmitted, it is mandatory to provide it in the form of a full dossier (including references)
and clearly indicate what is new compared to the previous submission(s).
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4. REFERENCE LIST
Regulations and Decisions from the Commission are ordered by year.
67/548/EEC - Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws,
regulations and administrative provisions relating to the classification, packaging and labelling
of dangerous substances. Official Journal P 196, 16/08/1967 p.1.
76/768/EEC - Council Directive 76/768/EEC of 27 July 1976 on the approximation of the
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EC A.1 -Melting / freezing temperature Council Regulation (EC) No 440/2008 of 30 May 2008
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Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction
of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.4.
EC A.2 - Boiling temperature Council Regulation (EC) No 440/2008 of 30 May 2008 laying
down test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament
and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.14.
EC A.3 - Relative density Council Regulation (EC) No 440/2008 of 30 May 2008 laying down
test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.21.
EC A.4 - Vapour pressure Council Regulation (EC) No 440/2008 of 30 May 2008 laying down
test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.26.
EC A.6 - Water solubility Council Regulation (EC) No 440/2008 of 30 May 2008 laying down
test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.57.
EC A.8 - Partition coefficient Council Regulation (EC) No 440/2008 of 30 May 2008 laying
down test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament
and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.67.
EC A.9 - Flash-point Council Regulation (EC) No 440/2008 of 30 May 2008 laying down test
methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the
Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
Official Journal L 142, 31/05/2008, p.80.
EC A.15 - Auto-ignition temperature (liquids and gases) Council Regulation (EC) No 440/2008
of 30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.104.
EC B.1- Acute toxicity (oral) - Commission Directive 92/69/EEC of 31 July 1992 adapting to
technical progress for the seventeenth time Council Directive 67/548/EEC on the
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EC B.1 bis - Acute oral toxicity - Fixed Dose Procedure Council Regulation (EC) No 440/2008
of 30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.145.
EC B.1 tris - Acute oral toxicity - Acute toxic class method Council Regulation (EC) No
440/2008 of 30 May 2008 laying down test methods pursuant to Regulation (EC) No
1907/2006 of the European Parliament and of the Council on the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008,
p.158.
EC B.2 Acute toxicity (inhalation) Council Regulation (EC) No 440/2008 of 30 May 2008
laying down test methods pursuant to Regulation (EC) No 1907/2006 of the European
Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction
of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.174.
EC B.3 - Acute toxicity (dermal) Council Regulation (EC) No 440/2008 of 30 May 2008 laying
down test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament
and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.178.
EC B.4 - Acute toxicity: dermal irritation / corrosion Council Regulation (EC) No 440/2008 of
30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.182.
EC B.5 - Acute toxicity: eye irritation / corrosion Council Regulation (EC) No 440/2008 of 30
May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.191.
EC B.6 - Skin sensitisation Council Regulation (EC) No 440/2008 of 30 May 2008 laying down
test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.202.
EC B.7 - Repeated dose (28 days) toxicity (oral) Council Regulation (EC) No 440/2008 of 30
May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.210.
EC B.8 - Repeated dose (28 days) toxicity (inhalation) Council Regulation (EC) No 440/2008
of 30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.216.
EC B.9 - Repeated dose (28 days) toxicity (dermal) Council Regulation (EC) No 440/2008 of
30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.221.
EC B.26 - Sub-chronic oral toxicity test: repeated dose 90-day oral toxicity study in rodents
Council Regulation (EC) No 440/2008 of 30 May 2008 laying down test methods pursuant to
Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the
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Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Official Journal
L 142, 31/05/2008, p.302.
EC B.27 - Sub-chronic oral toxicity test: repeated dose 90-day oral toxicity study in non-
rodents. Council Regulation (EC) No 440/2008 of 30 May 2008 laying down test methods
pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the Council on
the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Official
Journal L 142, 31/05/2008, p.308.
EC B.28 - Sub-chronic dermal toxicity study: 90-day repeated dermal dose study using
rodent species Council Regulation (EC) No 440/2008 of 30 May 2008 laying down test
methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the
Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
Official Journal L 142, 31/05/2008, p.314.
EC B.29 - Sub-chronic inhalation toxicity study: 90-day repeated inhalation dose study using
rodent species Council Regulation (EC) No 440/2008 of 30 May 2008 laying down test
methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the
Council on the Registration, Evaluation, Authorisation an Restriction of Chemicals (REACH).
Official Journal L 142, 31/05/2008, p.318.
EC B.30 - Chronic toxicity test Council Regulation (EC) No 440/2008 of 30 May 2008 laying
down test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament
and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.323.
EC B.31 - Prenatal developmental toxicity study Council Regulation (EC) No 440/2008 of 30
May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.329.
EC B.33 - Combined chronic toxicity / carcinogenicity test Council Regulation (EC) No
440/2008 of 30 May 2008 laying down test methods pursuant to Regulation (EC) No
1907/2006 of the European Parliament and of the Council on the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008,
p.344.
EC B.35 - Two-generation reproduction toxicity test Council Regulation (EC) No 440/2008 of
30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.355.
EC B.36 Toxicokinetics Council Regulation (EC) No 440/2008 of 30 May 2008 laying down
test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 142, 31/05/2008, p.365.
EC B.40bis - In vitro skin corrosion: Human skin model test Council Regulation (EC) No
440/2008 of 30 May 2008 laying down test methods pursuant to Regulation (EC) No
1907/2006 of the European Parliament and of the Council on the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008,
p.394.
EC B.41 - In vitro 3T3 NRU phototoxicity test Council Regulation (EC) No 440/2008 of 30
May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.400.
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EC B.42 - Skin sensitisation: Local Lymph Node Assay Commission Regulation (EU) No
640/2012 of 6 July 2012 amending, for the purpose of its adaptation to technical progress,
Regulation (EC) No 440/2008 laying down test methods pursuant to Regulation (EC) No
1907/2006 of the European Parliament and of the Council on the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH). Official Journal L 193, 20/07/2012, p. 3.
EC B.42 - Skin sensitisation: Local Lymph Node Assay Council Regulation (EC) No 440/2008
of 30 May 2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.414. Amended by OJ
L193:
EC B.44 - Skin absorption: In vivo method Council Regulation (EC) No 440/2008 of 30 May
2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the European
Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction
of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.432.
EC B.45 - Skin absorption: In vitro method Council Regulation (EC) No 440/2008 of 30 May
2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the European
Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction
of Chemicals (REACH). Official Journal L 142, 31/05/2008, p.438.
EC B.46 - In vitro skin irritation: Reconstructed human epidermis model test Commission
Regulation (EC) No 761/2009 of 23 July 2009 amending, for the purpose of its adaptation to
technical progress, Regulation (EC) No 440/2008 laying down test methods pursuant to
Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Official Journal
L 220, 24/08/2009, p.24. Amended by OJ L193
EC B.46 In vitro skin irritation: Reconstructed human epidermis test method Commission
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technical progress, Regulation (EC) No 440/2008 laying down test methods pursuant to
Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Official Journal
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EC B.47 Bovine corneal opacity and permeability test method for identifying ocular
corrosives and severe irritants. Commission Regulation (EC) No 761/2009 of 23 July 2009
amending, for the purpose of its adaptation to technical progress, Regulation (EC) No
440/2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the
European Parliament and of the Council on the Registration, Evaluation, Authorisation and
Restriction of Chemicals (REACH). Official Journal L 324, 09/12/2010, p. 14.
EC B.48 Isolated chicken eye test method for identifying ocular corrosives and severe
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purpose of its adaptation to technical progress, Regulation (EC) No 440/2008 laying down
test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of
the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH). Official Journal L 324, 09/12/2010, p. 14.
EC B.50 Skin sensitisation: Local Lymph Node Assay: DA Commission Regulation (EU) No
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Regulation (EC) No 440/2008 laying down test methods pursuant to Regulation (EC) No
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Authorisation and Restriction of Chemicals (REACH). Official Journal L 193, 20/07/2012, p.
46.
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EC B.51 Skin sensitisation: Local Lymph Node Assay: BrdU-ELISA Commission Regulation
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progress, Regulation (EC) No 440/2008 laying down test methods pursuant to Regulation
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OECD 229 - OECD (2012), Test No. 229: Fish Short Term Reproduction Assay, OECD
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OECD 231 OECD (2009), Test No. 231: Amphibian Metamorphosis Assay. OECD Guidelines
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OECD 233 - OECD (2018), Users’ Handbook Supplement to the Guidance Document for
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OECD 240 - OECD (2015), Test No. 240: Medaka Extended One Generation Reproduction
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Paris, https://doi.org/10.1787/9789264242258-en.
OECD 241 OECD (2015), The Larval Amphibian Growth and Development Assay (LAGDA),
OECD Guidelines for the Testing of Chemicals, Section 2, OECD Publishing, Paris,
https://doi.org/10.1787/9789264242340-en.
OECD 248 OECD (2019), Test No. 248: Xenopus Eleutheroembryonic Thyroid Assay
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OECD 255 - OECD (2017a), Guidance Document on the Reporting of Defined Approaches to
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OECD 256 OECD (2017), Guidance Document on the Reporting of Defined Approaches and
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OECD 263 - OECD (2019), Second Edition - Guidance Document on Integrated Approaches
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https://doi.org/10.1787/84b83321-en.
OECD 267 - OECD (2017), OECD Validation report for the international validation study on
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OECD 401 OECD 1987, Test No. 401: Acute Oral Toxicity, OECD Guidelines for the Testing
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OECD 402 - OECD (2017), Test No. 402: Acute Dermal Toxicity, OECD Guidelines for the
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https://doi.org/10.1787/9789264070585-en.
OECD 403 - OECD (2009), Test No. 403: Acute Inhalation Toxicity, OECD Guidelines for the
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OECD 404 - OECD (2015), Test No. 404: Acute Dermal Irritation/Corrosion, OECD Guidelines
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OECD 405 - OECD (2020), Test No. 405: Acute Eye Irritation/Corrosion, OECD Guidelines
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https://doi.org/10.1787/9789264185333-en.
OECD 406 - OECD (1992), Test No. 406: Skin Sensitisation, OECD Guidelines for the Testing
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OECD 407 - OECD (2008), Test No. 407: Repeated Dose 28-day Oral Toxicity Study in
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https://doi.org/10.1787/9789264070684-en
OECD 408 - OECD (2018), Test No. 408: Repeated Dose 90-Day Oral Toxicity Study in
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https://doi.org/10.1787/9789264070707-en
OECD 409 - OECD (1998), Test No. 409: Repeated Dose 90-Day Oral Toxicity Study in Non-
Rodents, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070721-en
OECD 410 - OECD (1981), Test No. 410: Repeated Dose Dermal Toxicity: 21/28-day Study,
OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070745-en.
OECD 411 - OECD (1981), Test No. 411: Subchronic Dermal Toxicity: 90-day Study, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070769-en
OECD 412 - OECD (2018), Test No. 412: Subacute Inhalation Toxicity: 28-Day Study, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070783-en.
OECD 413 - OECD (2018), Test No. 413: Subchronic Inhalation Toxicity: 90-day Study, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070806-en
OECD 414 - OECD (2018), Test No. 414: Prenatal Developmental Toxicity Study, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070820-en.
OECD 416 - OECD (2001), Test No. 416: Two-Generation Reproduction Toxicity, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070868-en.
OECD 417 - OECD (2010), Test No. 417: Toxicokinetics, OECD Guidelines for the Testing of
Chemicals, Section 4, OECD Publishing, Paris, https://doi.org/10.1787/9789264070882-en.
OECD 420 - OECD (2002), Test No. 420: Acute Oral Toxicity - Fixed Dose Procedure, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264070943-en
OECD 421 - OECD (2016), Test No. 421: Reproduction/Developmental Toxicity Screening
Test, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264264380-en
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OECD 422 - OECD (2016), Test No. 422: Combined Repeated Dose Toxicity Study with the
Reproduction/Developmental Toxicity Screening Test, OECD Guidelines for the Testing of
Chemicals, Section 4, OECD Publishing, Paris, https://doi.org/10.1787/9789264264403-en.
OECD 423 - OECD (2002), Test No. 423: Acute Oral toxicity - Acute Toxic Class Method,
OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071001-en.
OECD 425 - OECD (2008), Test No. 425: Acute Oral Toxicity: Up-and-Down Procedure, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071049-en.
OECD 427 - OECD (2004), Test No. 427: Skin Absorption: In Vivo Method, OECD Guidelines
for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071063-en.
OECD 428 - OECD (2004), Test No. 428: Skin Absorption: In Vitro Method, OECD Guidelines
for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071087-en.
OECD 429 - OECD (2010), Test No. 429: Skin Sensitisation: Local Lymph Node Assay, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071100-en.
OECD 430 - OECD (2015), Test No. 430: In Vitro Skin Corrosion: Transcutaneous Electrical
Resistance Test Method (TER), OECD Guidelines for the Testing of Chemicals, Section 4, OECD
Publishing, Paris, https://doi.org/10.1787/9789264242739-en.
OECD 431 - OECD (2019), Test No. 431: In vitro skin corrosion: reconstructed human
epidermis (RHE) test method, OECD Guidelines for the Testing of Chemicals, Section 4, OECD
Publishing, Paris, https://doi.org/10.1787/9789264264618-en
OECD 432 - OECD (2019), Test No. 432: In Vitro 3T3 NRU Phototoxicity Test, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071162-en.
OECD 433 - OECD (2018), Test No. 433: Acute Inhalation Toxicity: Fixed Concentration
Procedure, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264284166-en
OECD 435 - OECD (2015), Test No. 435: In Vitro Membrane Barrier Test Method for Skin
Corrosion, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264242791-en.
OECD 436 - OECD (2009), Test No. 436: Acute Inhalation Toxicity Acute Toxic Class
Method, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264076037-en.
OECD 437 - OECD (2020), Test No. 437: Bovine Corneal Opacity and Permeability Test
Method for Identifying i) Chemicals Inducing Serious Eye Damage and ii) Chemicals Not
Requiring Classification for Eye Irritation or Serious Eye Damage, OECD Guidelines for the
Testing of Chemicals, Section 4, Éditions OCDE, Paris, 26 June 2020,
https://doi.org/10.1787/9789264203846-en.
OECD 438 - OECD (2018), Test No. 438: Isolated Chicken Eye Test Method for Identifying i)
Chemicals Inducing Serious Eye Damage and ii) Chemicals Not Requiring Classification for
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Eye Irritation or Serious Eye Damage, OECD Guidelines for the Testing of Chemicals, Section
4, OECD Publishing, Paris, https://doi.org/10.1787/9789264203860-en.
OECD 439 - OECD (2020), Test No. 439: In Vitro Skin Irritation: Reconstructed Human
Epidermis Test Method, OECD Guidelines for the Testing of Chemicals, Section 4, Éditions
OCDE, Paris, June 20, 2020, https://doi.org/10.1787/9789264242845-en.
OECD 440 - OECD (2007), Test No. 440: Uterotrophic Bioassay in Rodents: A short-term
screening test for oestrogenic properties, OECD Guidelines for the Testing of Chemicals,
Section 4, OECD Publishing, Paris, https://doi.org/10.1787/9789264067417-en.
OECD 442A - OECD (2010), Test No. 442A: Skin Sensitization: Local Lymph Node Assay:
DA, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264090972-en
OECD 442B - OECD (2018), Test No. 442B: Skin Sensitization: Local Lymph Node Assay:
BrdU-ELISA or FCM, OECD Guidelines for the Testing of Chemicals, Section 4, OECD
Publishing, Paris, https://doi.org/10.1787/9789264090996-en.
OECD 442C - OECD (2020), Test No. 442C: In Chemico Skin Sensitisation : Assays
addressing the Adverse Outcome Pathway key event on covalent binding to proteins, OECD
Guidelines for the Testing of Chemicals, Section 4, Éditions OCDE, Paris, June 26, 2020,
https://doi.org/10.1787/9789264229709-en.
OECD 442D - OECD (2018), Test No. 442D: In Vitro Skin Sensitisation: ARE-Nrf2 Luciferase
Test Method, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264229822-en.
OECD 442E - OECD (2018), Test No. 442E: In Vitro Skin Sensitisation: In Vitro Skin
Sensitisation assays addressing the Key Event on activation of dendritic cells on the Adverse
Outcome Pathway for Skin Sensitisation, OECD Guidelines for the Testing of Chemicals,
Section 4, OECD Publishing, Paris, https://doi.org/10.1787/9789264264359-en
OECD 443 - OECD (2018), Test No. 443: Extended One-Generation Reproductive Toxicity
Study, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264185371-en.
OECD 451 - OECD (2018), Test No. 451: Carcinogenicity Studies, OECD Guidelines for the
Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071186-en.
OECD 452 - OECD (2018), Test No. 452: Chronic Toxicity Studies, OECD Guidelines for the
Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071209-en
OECD 453 - OECD (2018), Test No. 453: Combined Chronic Toxicity/Carcinogenicity Studies,
OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264071223-en
OECD 455 OECD (2016), Test No. 455: Performance-Based Test Guideline for Stably
Transfected Transactivation In Vitro Assays to Detect Estrogen Receptor Agonists and
Antagonists, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264265295-en
OECD 456 - OECD (2011), Test No. 456: H295R Steroidogenesis Assay, OECD Guidelines
for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264122642-en.
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131
OECD 460 OECD (2017), Test No. 460: Fluorescein Leakage Test Method for Identifying
Ocular Corrosives and Severe Irritants, OECD Guidelines for the Testing of Chemicals, Section
4, OECD Publishing, Paris, https://doi.org/10.1787/9789264185401-en.
OECD 471 - OECD (2020), Test No. 471: Bacterial Reverse Mutation Test, OECD Guidelines
for the Testing of Chemicals, Section 4, Éditions OCDE, Paris, June 26, 2020,
https://doi.org/10.1787/9789264071247-en
OECD 487 - OECD (2016), Test No. 487: In Vitro Mammalian Cell Micronucleus Test, OECD
Guidelines for the Testing of Chemicals, Section 4, OECD Publishing, Paris,
https://doi.org/10.1787/9789264264861-en.
OECD 488 OECD (2020), Test No. 488: Transgenic Rodent Somatic and Germ Cell Gene
Mutation Assays, OECD Guidelines for the Testing of Chemicals, Section 4, OECD Publishing,
Paris, https://doi.org/10.1787/9789264203907-en.
OECD 491 - OECD (2020), Test No. 491: Short Time Exposure In Vitro Test Method for
Identifying i) Chemicals Inducing Serious Eye Damage and ii) Chemicals Not Requiring
Classification for Eye Irritation or Serious Eye Damage, OECD Guidelines for the Testing of
Chemicals, Section 4, Éditions OCDE, Paris, June 26, 2020,
https://doi.org/10.1787/9789264242432-en.
OECD 492 - OECD (2019), Test No. 492: Reconstructed human Cornea-like Epithelium
(RhCE) test method for identifying chemicals not requiring classification and labelling for eye
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SCCP/1192/08
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SCCS/1311/10 (Scientific Committee on Consumer Safety), Opinion on reaction products
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SCCS/1443/11 (Scientific Committee on Consumer Safety), Opinion on p-
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SCCS/1446/11 (Scientific Committee on Consumer Safety), Clarification on Opinion
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cosmetic products intended for children under three years of age, 10 October 2011,
SCCS/1446/11
SCCS/1459/11 (Scientific Committee on Consumer Safety), opinion on fragrance allergens
in cosmetic products, 13-14 December 2011, SCCS/1459/11
SCCS/1479/12 (Scientific Committee on Consumer Safety), Opinion on toluene-2,5-
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SCCS/1481/12 (Scientific Committee on Consumer Safety), Opinion on kojic acid, 26-27
June 2012, SCCS/1481/12
SCCS/1484/12 (Scientific Committee on Consumer Safety), Guidance on safety assessment
of nanomaterials in cosmetics, adopted by the SCCS at its 15th plenary meeting of 26-27
June 2012, SCCS/1484/12
SCCS/1486/12 (Scientific Committee on Consumer Safety), Opinion on NDELA in cosmetic
products and nitrosamines in balloons, adopted at its 15
th
plenary meeting on 26-27 June
2012, SCCS/1486/12
SCCS/1501/12 (Scientific Committee on Consumer Safety), The SCCS's Notes of Guidance
for the testing of cosmetic ingredients and their safety evaluation - 8
th
revision, adopted by
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th
plenary meeting of 11 December 2012, SCCS/1501/12
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138
SCCS/1509/13 (Scientific Committee on Consumer Safety), Memorandum on hair dye
Chemical Sensitisation, adopted by the SCCS at its 18th Plenary meeting of 26 February
2013, SCCS/1509/13
SCCS/1512/13 (Scientific Committee on Consumer Safety), Opinion on Zinc pyrithione, 18
June 2013, revision of 18 June 2014, SCCS/1512/13
SCCS/1513/13 (Scientific Committee on Consumer Safety), Opinion on 3-Benzylidene
camphor (Colipa S61), adopted by the SCCS during the 2nd plenary meeting of 18 June
2010, SCCS/1513/13
SCCS/1514/13 (Scientific Committee on Consumer Safety), Opinion on Parabens - Updated
request for a scientific opinion on propyl-and butylparaben (Colipa no P82), adopted by
written procedure on 3 May 2013, SCCS/1514/13
SCCS/1524/13 (Scientific Committee on Consumer Safety), Memorandum on "Relevance
and Quality of Data in Safety Dossiers on Nanomaterials", 12 December 2013, revision of 27
March 2014, SCCS/1524/13
SCCS/1532/14 (Scientific Committee on Consumer Safety), Addendum to the SCCS's Notes
of Guidance (NoG) for the Testing of Cosmetic Ingredients and their Safety Evaluation, 8th
Revision, adopted by the SCCS by written procedure on 9 April 2014, revision of 22 October
2014, SCCS/1532/14
SCCS/1533/14 (Scientific Committee on Consumer Safety), Opinion on 2-(4-(2-(4-
Diethylamino-2-hydroxy-benzoyl)-benzoyl)-piperazine-1-carbonyl)-phenyl)- (4-
diethylamino-2-hydroxyphenyl)-methanone (HAA299) as UV filter in sunscreen products.
The SCCS adopted this opinion at its 6th plenary meeting, revision of 23 September 2014,
SCCS/1533/14
SCCS/1538/14 (Scientific Committee on Consumer Safety), Opinion on the safety of the
use of formaldehyde in nail hardeners, written procedure 7 November 2014, revision of 16
December 2014, SCCS/1538/14
SCCS/1539/14 (Scientific Committee on Consumer Safety), Opinion for clarification of the
meaning of the term "sprayable applications/products" for the nano forms of Carbon Black CI
77266, Titanium Oxide and Zinc Oxide, adopted by the SCCS at its 7th plenary meeting on
23 September 2014, SCCS/1539/14
SCCS/1544/14 (Scientific Committee on Consumer Safety), Memorandum on Endocrine
Disruptors, 16 December 2014, SCCS/1544/14
SCCS/1546/15 (Scientific Committee on Consumer Safety), Opinion on 2,2’-methylene-
bis-(6(2H-benzotriazol-2-yl)-4-(1,1,3,3-tetramethylbutyl)phenol), 25 March 2015,
SCCS/1546/15
SCCS/1567/15 (Scientific Committee on Consumer Safety), Memorandum on use of Human
Data in risk assessment of skin sensitization, 15 December 2015, SCCS/1567/15
SCCS/1578/16 (Scientific Committee on Consumer Safety), Memorandum on the use of In
silico Methods for Assessment of Chemical Hazard, 6 October 2016, SCCS/1578/16
SCCS/1589/17 (Scientific Committee on Consumer Safety) Opinion on Skin Sensitisation
Quantitative Risk Assessment for Fragrance Ingredients (QRA2), 30 July 2018,
SCCS/1589/17
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139
SCCS/1594/18 (Scientific Committee on Consumer Safety), Opinion on the safety of
cosmetic ingredients Phenylene Bis-Diphenyltriazine (CAS No 55514-22-2) - S86 -Submission
II, preliminary version of 21-22 February 2018, final version of 30 July 2018, SCCS/1594/18
SCCS/1595/18 (Scientific Committee on Consumer Safety), Final Opinion on
Styrene/Acrylates copolymer (nano) and Sodium styrene/Acrylates copolymer (nano), 22
February 2019, SCCS/1595/18
SCCS/1596/2018 (Scientific Committee on Consumer Safety), Opinion on Colloidal Silver,
24-25 October 2018, SCCS/1596/2018
SCCS/1602/18 (Scientific Committee on Consumer Safety), The SCCS's Notes of Guidance
for the testing of cosmetic ingredients and their safety evaluation - 10
th
revision, adopted by
the SCCS during the plenary meeting of 2’-25 October 2018, SCCS/1602/18
SCCS/1606/2019 (Scientific Committee on Consumer Safety), Opinion on solubility of
Synthetic Amorphous Silica (SAS), 20-21 June 2019, SCCS/1606/2019. Corrigendum of 6
December 2019.
SCCS/1611/19 (Scientific Committee on Consumer Safety), Guidance on the Safety
Assessment of Nanomaterials in Cosmetics, 30-31 October 2019, SCCS/1611/19
SCCS/1613/19 (Scientific Committee on Consumer Safety), Scientific advice on the safety
of aluminium in cosmetic products, plenary meeting 3-4 March 2020, submission II,
SCCS/1613/19
SCCS/1617/20 (Scientific Committee on Consumer Safety), Scientific advice on the safety
of titanium dioxide used in cosmetic products that lead to exposure by inhalation, written
procedure 6 October 2020, SCCS/1617/20
SCCS/1618/2020 (Scientific Committee on Consumer Safety), Scientific advice on the
safety of nanomaterials in cosmetics, 6 October 2020, SCCS/1618/2020
SCCS/1627/21 (Scientific Committee on Consumer Safety), Scientific advice on the safety
of octocrylene in cosmetic products, adopted by written procedure on 15 January 2021,
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APPENDIX 1: INFORMATION ON REGULATION (EC) NO 1223/2009
AND THE SCCS
1. INTRODUCTION TO COSMETIC REGULATION (EC) No 1223/2009
Since July 2013, Regulation (EC) No 1223/2009 harmonises the safety of cosmetics within
the Member States, simplifies procedures and streamlines terminology. The most significant
changes introduced by the Cosmetic Regulation include:
(1) Strengthened safety requirements for cosmetic products Manufacturers need to
follow specific requirements in the preparation of a product safety report prior to
placing a product on the market.
(2) Introduction of the notion of a “responsible person” (RP)
Only cosmetic products for which a legal or natural person is designated within the EU
as a “responsible personcan be placed on the market. The Cosmetics Regulation
allows the precise identification of the RP and clearly outlines his/her obligations.
(3) Centralised notification of all cosmetic products placed on the EU market
The RP (mostly the manufacturer) will need to send the
Product notification only once via the EU Cosmetic Product Notification Portal (CPNP).
(4) Introduction of reporting serious undesirable effects
(SUE)
A RP and a distributor have the obligation to notify serious undesirable effects to
national authorities. The authorities will also collect information coming from end
users and health professionals. They will be obliged to share the information with
other EU countries. More information on reporting of SUE.
(5) New rules for the use of nanomaterials in cosmetic products
(6) A set of requirements for CMR (carcinogenic, mutagenic, toxic for reproduction)
substances
According to Article 2.1 (a) of Regulation (EC) No 1223/2009, a cosmetic product means
any substance or mixture intended to be placed in contact with the external parts of
the human body (epidermis, hair system, nails, lips and external genital organs) or with the
teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to
cleaning them, perfuming them, changing their appearance, protecting them,
keeping them in good condition or correcting body odours.
“Substance” is defined by Article 2.1 (b) of this Regulation as a chemical element and its
compounds in the natural state or obtained by any manufacturing process, including any
additive necessary to preserve its stability and any impurity deriving from the process used
but excluding any solvent which may be separated without affecting the stability of the
substance or changing its composition, whereas Article 2.1 (c) defines “mixture” as a
mixture or solution composed of two or more substances.
Article 3 of the Cosmetics Regulation specifies that a cosmetic product made available on the
market shall be safe for human health when used under normal or reasonably
foreseeable conditions of use. In practice, cosmetic products have rarely been associated with
serious health hazards, which, however, does not mean that cosmetics are safe in use per
se. Particular attention is needed for long-term safety aspects, since cosmetic products may
be used extensively over a large part of the human lifespan and sensitive groups of the
population may be involved. Therefore, the safety-in-use of cosmetic products has been
established in Europe by controlling the substances, their chemical structures, toxicity
profiles, and exposure patterns.
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2. THE SCIENTIFIC COMMITTEE ON CONSUMER SAFETY, SCCS
2-1 Historical background
The Scientific Committee on Cosmetology (SCC) was established on 19 December 1977 by
Commission Decision 78/45/EEC; the purpose was to assist the European Commission in
examining the complex scientific and technical problems surrounding the drawing up and
amendment of European Union (EU) rules governing the composition, manufacturing,
packaging and labelling of cosmetic products marketed in EU countries. The Committee was
to be renewed every three years.
In 1997, the Scientific Committee on Cosmetic Products and Non-Food Products intended for
consumers (SCCNFP), was established. It was composed of independent scientists from
different fields of competence, collectively covering the widest possible range of expertise.
In 2004, the SCCNFP was replaced by the Scientific Committee on Consumer Products
(SCCP), as part of a larger-scale reorganisation of the EU Scientific Committees in the field
of consumer safety, public health and the environment.
Three scientific committees were established:
i. Scientific Committee on Consumer Products (SCCP)
ii. Scientific Committee on Health and Environmental Risks (SCHER)
iii. Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR)
The coordination between the SCCP, the SCHER and the SCENIHR was done by the Inter-
Committee Coordination Group (ICCG).
In 2008, the three above-mentioned Scientific Committees were renewed
16
and the SCCP's
name was changed into SCCS. In addition to the SCCS, SCENIHR and SCHER, a Pool of
scientific advisors on risk assessment was also established, with the specific task to assist the
members of the Scientific Committees in their work. In 2013, the three above-mentioned
Scientific Committees were renewed.
17
Finally, a new Commission Decision C (2015)5383
18
was adopted on 7 August 2015,
establishing two scientific committees: the (SCCS); the Scientific Committee on Health,
Environmental and Emerging Risks (SCHEER). The composition of both Committees was
renewed on April 2016, for a period of 5 years until 2021, and extended until the end of 2026
due to the Covid-crisis, which postponed the launch of the call for experts/members.
2-2 Mandate
The mission of the Scientific Committees is defined in Commission Decision C(2015)5383
19
,
which states that they shall 'provide the Commission with scientific advice and risk
assessment in the areas of public health, consumer safety, environmental risks, including,
when relevant, identification of research needs to address critical information gaps,
assessment of proposed future research actions and of research results'.
16
Commission Decision 2008/721/EC of 5 September 2008 setting up an advisory structure of Scientific Committees
and experts in the field of consumer safety, public health and the environment and repealing Decision 2004/210/EC.
Official Journal L 241, 10/09/2008 p.21
17
Commission Decision 2013/1297 of 11 March 2013 on the appointment of the members of the Scientific
Committees set up by Commission Decision 2008/721/EC.
http://ec.europa.eu/health/scientific_committees/docs/com_2013_1297_en.pdf
18
http://ec.europa.eu/health/scientific_committees/docs/call_2015_5383_decision_with_annexes_en.pdf
19
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/call_2015_5383_decision_with_annexe
s_en.pdf
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147
The SCCS on request of Commission services shall provide opinions on questions concerning
health and safety risks, notably chemical, biological, mechanical and other physical risks, of:
(a) non-food consumer products such as:
- cosmetic products and their ingredients, including nanomaterial, hair dyes, fragrance
ingredients;
- personal care and household products such as detergents; and toys, textiles, clothing, etc.
(b) services such as tattooing, artificial sun tanning, etc.
In addition, the Commission may request from the Committee:
- advice on any matter of particular relevance to consumer safety and public health;
- rapid advice on the state of scientific knowledge concerning specific risks in case of urgent
risks;
- the identification of research needs to address critical information gaps, to assess proposed
future research and to assess research results in relation to the subject areas covered by
its fields of competence;
- to be part of thematic networks or events with other Union bodies or scientific
organisations, in order to monitor and contribute to the development of scientific
knowledge in the fields of competence.
Also, upon its own initiative, the Committees shall draw the Commission's attention to a
specific or emerging problem falling within its remit, if it is considered to pose an actual or
potential risk to consumer safety, public health or the environment.
Finally, in agreement with the Commission, the Committees shall adopt their methodology
for performing and providing risk assessment and keep it under review to reflect all relevant
scientific factors. They shall ensure that the methodology reflect current risk assessment
practice.
The work of the SCCS can be divided in two main domains, namely matters related to
cosmetic substances and products and those related to other non-food consumer products.
Whenever cosmetic substances are concerned, the consultation of the SCCS is compulsory
20
,
whereas it is not compulsory in the domain of other non-food products.
In the preamble of Regulation (EC) No 1223/2009, different tasks for the SCCS are mentioned
in several recitals:
(28)
safety assessment of hair colorants (annex III)
(30)
providing guidance in cooperation with relevant bodies on test methodologies which take
into account specific characteristics of nanomaterials,
(32)
continuously reviewing the safety of CMR substances, so that substances clarified as CMR
2 or CMR 1A or 1B can be used in cosmetics under well-restricted conditions when such use
for CMR 1A and 1B has been found safe by the SCCS,
(34)
taking into account the exposure of vulnerable population groups,
(35)
giving opinions on the safety of use of nanomaterials in cosmetic products,
(42)
consultation by the Commission as regards the applicability of validated alternative
methods to the field of cosmetic products,
(49)
identification of substances likely to cause allergic reactions in order that their use can
be restricted and/or certain conditions can be imposed,
20
See Article 31 of Regulation (EC) No 1223/2009
_____________________________________________________________________________________________
148
(61)
providing assistance to the Commission as an independent risk assessment body.
The compulsory consultation of the SCCS is taken up under:
Art. 15, 2(d) and 3 for substances classified as CMR substances
Art. 16, 4 and 5 for nanomaterials
Art. 18, 2 for animal testing methodology
Art. 20, 2 for setting criteria for product claims
Art. 27, 3 for determination whether the provisional measures taken with respect to the safe
clause are justified or not
Art. 31, 1 for amending Annexes II to VI for safety concerns
Art. 31, 2 for amending Annexes II to VI, VIII for technical and scientific progress
Art. 31, 3 for amending Annex I to ensure the safety of cosmetic products placed on the
market.
Newly introduced modifications and improvements in the current structure and working
procedures of the SCCS and the other Scientific Committee can be found in Commission
Decision C(2015)5383
21
of 7 August 2015.
2-3 Rules of Procedure
The Rules of Procedure
22
of the SCCS and SCHEER were jointly adopted by the Scientific
Committees on 28 April products. These were amended according to the Commission Decision
C(2015)5383.
In order to efficiently fulfil its extensive mandate, the SCCS sets up working groups on
particular subjects of interest. These subgroups operate independently under an appointed
chairperson (SCCS member) and consist of SCCS members complemented with external
experts (either from the Database of Experts
23
or via a specific call
24
). Working groups, for
example, deal with: Cosmetic Substances (individual substance evaluations), Methodologies
(alternative methods and Notes of Guidance), Nanomaterials and other topics according to
the needs.
The mandate on a specific substance or other issue is officially adopted by the members
during a plenary meeting (or by written procedure) and published
25
.
A Rapporteur is nominated (SCCS member or external expert). Once the participants of the
Working Groups have agreed on a final version of their opinion/scientific report(s), they
present it to the next SCCS plenary meeting where members adopt the texts. In particular
cases, an opinion may also be adopted by written procedure. The adopted preliminary
opinions, once edited, are published on the Commission’s website
26
for a commenting period
of a minimum of eight weeks to allow the applicant, and other stakeholders as well, to send
their comments that are subsequently considered by the SCCS and, when considered
appropriate, incorporated in a revised version of the opinion. The revised version becomes
the final opinion once adopted at the next SCCS plenary meeting (or by written procedure)
and is published on the website
27
, with the date of the adoption of the final text. The final
opinion replaces the preliminary opinion and informs about changes made in the first pages.
The final opinions are not subject to further comments or revision requests. SCCS is not
21
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/call_2015_5383_decision_with_annexe
s_en.pdf
22
https://ec.europa.eu/health/sites/health/files/scientific_committees/docs/rules_procedure_2016_en.pdf
23
http://ec.europa.eu/health/scientific_committees/experts/database/index_en.htm
24
http://ec.europa.eu/health/scientific_committees/open_consultation/index_en.htm
25
https://ec.europa.eu/health/scientific_committees/consumer_safety/requests_en
26
https://ec.europa.eu/health/scientific_committees/consumer_safety/opinions_en#fragment0
27
https://ec.europa.eu/health/scientific_committees/consumer_safety/opinions_en#fragment2
_____________________________________________________________________________________________
149
responding to comment submitted outside the commenting period. Any new data should be
submitted directly to the responsible Commission unit mandating the SCCS for a new opinion.
This method of working with Working Groups not only lightens the workload of the members
of the SCCS, but equally and importantly, facilitates discussion of the individual topics with
the appropriate experts in the field of interest, thus enhancing the scientific quality of the
opinions issued.
2-4 Opinions
Before 1997, the opinions adopted by the Scientific Committee on Cosmetology at the
Commission’s request were included in EC-Reports (EUR 7297, 8634, 8794, 10305, 11080,
11139, 11303, 14208). Between 1997 and 2004, all SCCNFP opinions were published on the
Internet and can be accessed through the Committee's website
28
. All SCCP / SCCS opinions
can easily be located through the ingredient's substance category and the adoption date.
It must be emphasised that the SCC(NF)P / SCCS opinions and statements not only refer to
cosmetic substances included in Annexes II, III, IV, VI and VII of Council Directive
76/768/EEC or Annexes II, III, IV, V and VI of the Cosmetic Regulation (EC) No 1223/2009,
but also to a broad range of scientific issues related to the safety of cosmetic substances and
finished products.
3. COMPLYING WITH THE TESTING AND MARKETING BANS
The safety evaluation of cosmetic ingredients is exposure-driven and is historically based on
toxicological data, which were obtained by using experimental animals. The testing and
marketing bans in Regulation (EC) No 1223/2009 make the use of validated alternative
replacement methods compulsory. Guidance on how to comply can be found in:
i. Recital 50 and article 18 of the Regulation,
ii. Commission Communication on the animal testing and marketing ban and on the state
of play in relation to alternative methods in the field of cosmetics (COM/2013/135
29
),
iii. a factsheet of ECHA (2014a) and
iv. the 2017 ECHA report (ECHA 2017) on the use of alternatives to testing on animals.
I. Recital 50 of Regulation (EC) No 1223/2009 states the following: In the safety
assessment of a cosmetic product it should be possible to take into account results
of risk assessments that have been carried out in other relevant areas. The use of
such data should be duly substantiated and justified.” The prohibitions in Article
18 of the Regulation
30
are triggered when the animal testing in question is done
in order to meet the requirements of this [the Cosmetics] Regulation”. Article 18
of the Regulation (EC) No 1223/2009 creates, therefore, a relationship between
the animal testing bans and the intention to meet the requirements of this
Regulation;It is possible that animal testing needs to be conducted on ingredients
28
https://ec.europa.eu/health/scientific_committees/consumer_safety/opinions/sccnfp_opinions_97_04_en
29
COMMUNICATION on the animal testing and marketing ban and on the state of play in relation to alternative
methods in the field of cosmetics (COM(2013) 135 final).
30
Article 18 of Regulation (EC) No 1223/2009 contains four prohibitions, two relating to the performance of animal
testing (on finished cosmetic products and on ingredients of cosmetic products) and two relating to the placing on
the market of cosmetic products (where the final formulation or an ingredient of a cosmetic product has been the
subject of animal testing). However, an option for derogation from the animal testing ban is foreseen in Article 18,
No 2, paragraph six In exceptional circumstances, where serious concerns arise as regards the safety of an existing
cosmetic ingredient, a Member State may request the Commission to grant a derogation from paragraph 1. The
request shall contain an evaluation of the situation and indicate the measures necessary. On this basis, the
Commission may, after consulting the SCCS and by means of a reasoned decision, authorise the derogation. That
authorisation shall lay down the conditions associated with this derogation in terms of specific objectives, duration
and reporting of the results”.
_____________________________________________________________________________________________
150
to be used in a cosmetic product for the purpose of complying with other regulatory
framework (e.g., food, medicines, biocides).
II. In this respect, Commission Communication COM/2013/135 further elucidates: “If
animal testing was involved and took place after the 2013 deadline, the product
information file should allow verification on whether the testing was carried out in
order to meet the requirements of the Regulation or for other purposes. To this
end the file should contain documentation on any use of the substance in products
other than cosmetic products (product examples, market data etc.), as well as
documentation on compliance with other regulatory frameworks (e.g. REACH or
other legal frameworks) and a justification of the need for the animal testing under
that other framework (e.g. testing proposal under REACH)” . As regards the use
of data from animal testing conducted to ensure compliance with non-cosmetics
related legislative frameworks, two different scenarios can occur:
a. With respect to ingredients that are equally in use in other consumer and
industrial products, such as in pharmaceuticals, detergents and food, animal
testing may be necessary to ensure compliance with the legal frameworks
applicable to these products. In this case, the Commission considers that the
resulting animal testing data should not trigger the marketing ban and could
subsequently be relied on in the cosmetics safety assessment. Reliance on such
data is subject to its relevance for the cosmetics safety assessment and its
compliance with data quality requirements”. However, the Commission
Communication COM/2013/135 also adds that it is for Member States to assess
and decide whether such testing for compliance with other frameworks is
considered to be falling in the scope of the 2013 marketing ban;
b. Conversely, animal testing conducted on ingredients that have been specifically
developed for cosmetic purposes and are exclusively used in cosmetic products
would in the Commission's view always be assumed to be carried out in order to
meet the requirements of the Regulation (EC) No 1223/2009
31
, i.e. would always
be assumed to fall under the scope of the Article 18 ban. It would not be possible,
therefore, to use the results of such animal testing to prove safety of cosmetic
ingredients.
III. With respect, in particular, to the interaction between REACH requirements and
animal testing, ECHA published a factsheet
32
aimed at clarifying the practical
meaning and implications of the Commission Communication COM/2013/135 in
the context of REACH. The interface between REACH and the Regulation (EC) No
1223/2009 has been illustrated in a scheme, see Appendix 4. It has to be noted
that animal testing under REACH is not restricted, if: a) this testing is required for
environmental endpoints; or b) the substance is also registered for non-cosmetic
uses. Even if a substance is registered exclusively for cosmetic use, the animal
testing requirements continue to apply to tests needed to assess the risks from
exposure to workers in the Chemical Safety Assessment (ECHA, 2014a
33
). For the
first time, on 18 August 2020, the Board of Appeal (BoA) of ECHA took two
31
Testing carried out for cosmetics relevant endpoints on ingredients that have been specifically developed for
cosmetic purposes and are exclusively used in cosmetic products would in the Commission's view always be
assumed to be carried out 'in order to meet the requirements of this Directive/Regulation'” (Commission
Communication COM/2013/135, Page 8).
32
https://echa.europa.eu/documents/10162/13628/reach_cosmetics_factsheet_en.pdf
33
Workers” in this context are to be understood as persons who are actively involved in a particular activity of a
production or manufacturing site where they may be exposed directly or indirectly to chemical substances. On the
other hand, professional users who use the cosmetic products as part of their professional activity (e.g. hairdressers)
and consumers shall not be considered as “workers”. In Regulation (EC) No 1223/2009 the term ‘end user’ means
either a consumer or professional using the cosmetic product (Article 2, Definitions 1.
_____________________________________________________________________________________________
151
compliance check decisions
34
on registration dossiers (for homosalate and 2-
ethylhexyl salicylate, both UV filters used exclusively in cosmetics) (ECHA 2020a
and 2020b) where it confirmed that, according to scientific evidence, ECHA may
conclude that studies on vertebrate animals must be provided by the applicant to
comply with REACH, even if the substance is used exclusively as an ingredient in
cosmetics. This said, the considerations under point II above would apply, meaning
that, as regards ingredients that have been specifically developed for cosmetic
purposes and are exclusively used in cosmetic products, the results of a study on
vertebrate animals required under REACH could not be relied upon in the cosmetic
product safety report in order to demonstrate the safety for end users, as these
would fall under the Article 18 ban.
However, such results will be available to the authorities for scrutiny in the cosmetic product
information file under Article 11 of the Regulation (EC) No 1223/2009 and might call into
question the safety of cosmetic products containing a registered substance, contradicting the
cosmetic product safety report. In this case, as mentioned by the ECHA BoA in case A-010-
2018
35
if the safety of cosmetic products containing the substance can no longer be
established, then it is possible that cosmetic products containing the substance in question
as an ingredient can no longer be placed on the market” (paragraph 112). The need to take
into account the consequence of the results of that study would be justified under Article 3 of
the Regulation (EC) No 1223/2009, which provides that a cosmetic product made available
on the market must be safe for human health when used under normal or reasonably
foreseeable conditions of use.
IV. Additional information regarding the REACH legislation in the context of alternative
methods can be found in the three reports on “The Use of Alternatives to Testing
on Animals for the REACH Regulation”, in the 3
rd
report under Article 117(3),
available online
(https://echa.europa.eu/documents/10162/13639/alternatives_test_animals_20
17_en.pdf)
The question of the interpretation of the animal testing ban as regards animal testing
performed in third countries to comply with the cosmetics legislation of a third country was
referred to the European Court of Justice in case C-592/14
36
. The Court concluded that: ''the
results of animal tests, carried out outside the European Union in order to market cosmetic
products in third countries, the results of which are used to prove the safety of those products
for the purpose of their being placed on the EU market, must be regarded as having been
carried out ‘in order to meet the requirements [of that regulation][…]. ''Article 18(1)(b) of
Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November
2009 on cosmetic products must be interpreted as meaning that it may prohibit the placing
on the European Union market of cosmetic products containing some ingredients that have
been tested on animals outside the European Union, in order to market cosmetic products in
third countries, if the resulting data is used to prove the safety of those products for the
purposes of placing them on the EU market''.
The information provided in the NoG relates to the assessment of cosmetic ingredients from
a general chemical safety point of view. However, safety assessment of chemical substances
in certain physicochemical forms may need additional specific considerations, for example,
the use of nanomaterials in cosmetics (SCCS/1611/19).
34
https://echa.europa.eu/about-us/who-we-are/board-of-appeal
35
https://echa.europa.eu/documents/10162/23010712/a-010-2018_decision_en.pdf/46612b84-29af-29ea-9192-
b2506f33c8ce
36
Judgment of 21 September 2016, European Federation for Cosmetic Ingredients, C-592/14, ECLI:EU:C:2016:703.
_____________________________________________________________________________________________
152
APPENDIX 2: LISTS OF SUBSTANCES
1. INTRODUCTION
Regulated cosmetic substances can be found as Annexes II, III, IV, V and VI to Regulation
(EC) No 1223/2009. These annexes lay down clear limitations and requirements for the
cosmetic substances concerned.
Another important list of cosmetic substances is the INCI (International Nomenclature
Cosmetic Ingredient) inventory (96/335/EC) or CIN (2009/1223/EC), identifying a large
number of substances with their possible function(s) in finished cosmetic products and with
the nomenclature that needs to be used on the label of finished cosmetic products. DG GROW
(Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs) has built up
a free to use database of cosmetic substances called CosIng,
http://ec.europa.eu/consumers/cosmetics/cosing
(Cosmetic ingredients) which combines INCI names and synonyms of the listed substances
with useful regulatory information. CosIng database is regularly updated with information on
new cosmetics ingredients. The information contained in CosIng is indicative and does
not have any legal value.
Finally, this section briefly mentions Annex I to the Dangerous Substances Legislation
(67/548/EEC), since the "7
th
Amendment" of Directive 76/768/EEC (2003/15/EC) and the
Recast (2009/1223/EC) directly refer to that list when excluding CMR Cat.1 & Cat.2 chemicals
from cosmetic use (see 3-6.6). With the European Regulation on classification and labelling
(2008/1272/EC), however, Annex I to Dir. 67/548/EEC now needs to be referred to as ‘Part
3 of Annex VI to Regulation (EC) No 1272/2008’, in which all existing European classifications
are converted into new harmonised classifications using the new criteria.
It must be emphasised that none of the above lists reflects the complete set of substances
used in cosmetic products.
2. ANNEXES II, III, IV, V AND VI TO THE COSMETIC PRODUCTS REGULATION
The Cosmetic Products Regulation defines Annexes II, III, IV V and VI, which have been
described in Section 3-1.
3. INVENTORY OF SUBSTANCES USED IN COSMETIC PRODUCTS
Article 33 of Regulation (EC) No 1223/2009 states that the Commission shall compile and
update a glossary of common ingredient names (CINs) employed in cosmetic products
(2003/1223/2009).
On 8 May 1996, the European Commission established an Inventory and a common
nomenclature of the substances employed in cosmetic products (96/335/EC, part of which
amended by 2006/257/EC). This list was subdivided into 2 sections:
Section I: Inventory of ingredients employed in cosmetic products
Section II: Perfume and aromatic raw materials
The Inventory is indicative and does not constitute a list of substances authorised for use in
cosmetic products. If an INCI name is available, it is to be used on the packaging and
labelling, but the absence of an INCI name on the Inventory does not automatically exclude
the use of the substance under consideration.
_____________________________________________________________________________________________
153
An entry in the Inventory provides identification of that particular substance through the
following parameters:
- Common name: INCI; but botanicals get their systemic (Linné) Latin names and
colourants a colour index (CI) number
- Chemical name
- Chemical Abstract Service (CAS) number
- European Pharmacopoeia (Ph. Eur.) name
- International Non-proprietary Name (INN) name, recommended by WHO
- International Union of Pure and Applied Chemistry (IUPAC) name
- EC number, meaning either:
European Inventory of Existing commercial Chemical Substances (EINECS) number
(format 2xx-xxx-x)
European List of Notified Chemical Substances (ELINCS) number (format 4xx-xxx-x)
No Longer Polymer (NLP) number (format 5xx-xxx-x)
EC Number appointed under REACH procedure (format 6xx-xxx-x or 7xx-xxx-x)
In 1998 the European Commission issued a Mandate (DG24/XXIV/1891/98), indicating that
the SCCNFP shall act as a resource of scientific expertise to the European Commission, in
terms of advising on the:
- medical and professional expectations and requirements of the Inventory,
- scientific accuracy and validity of proposed entries,
- outstanding needs of the existing text /proposed improvements in subsequent updates.
After collaboration with the JRC (Joint Research Centre) of the Commission, the experts from
European industry and Colipa (the European Cosmetic Toiletry and Perfumery Association;
now called Cosmetics Europe), the SCCNFP issued a Status Report on the Inventory
(SCCNFP/0098/99). In this report, 6 priorities were identified for a first update of the INCI
list:
1) To accomplish the principle: each INCI name should refer to only one specific
substance.
2) To correct the INCI names of Ethylhexyl derivatives and to adopt a final decision on
Ampho-derivatives.
3) To identify botanical entries with greater transparency.
4) To solve problems on chemical identification associated to polymers.
5) To solve the problem of hair dyes/cosmetic colourants with respect to Colour Index (CI)
identification and restrictions.
6) To improve the description of the functions of the substances.
Having taken into account this list of priorities, the SCCNFP published in June 2000 "The 1
st
Revision and Update of Section I of the Inventory of ingredients employed in cosmetics"
(SCCNFP/0299/00). This update contains many improvements to the original edition of
Section I, including 1466 new and 843 modified INCI names, as well as a number of necessary
recommendations for updating the inventory in the future.
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154
In October 2000, "The 1
st
Update of the Inventory of ingredients employed in cosmetic
products: Section II: Perfume and aromatic raw materials" was issued (SCCNFP/0389/00).
Again, many improvements were introduced (e.g. 650 new entries of botanicals) and
recommendations for future updates were added.
In 2006, Commission Decision 2006/257/EC established the most recent official list
containing the common nomenclature of ingredients employed in cosmetic products
(2006/257/EC).
From 11 July 2013 on, the INCI list will be replaced by the so-called "Common Ingredients
glossary" (2009/1223/EC). The new glossary will contain the harmonised names of
approximately 26.000 cosmetic substances.
4. COSING - EC INFORMATION ON COSMETIC SUBSTANCES
The CosIng database
1
is a publicly available information database in two parts, linked together
whenever possible. One part aims at containing all the regulations introduced by the Cosmetic
Directive/Regulation. This part contains the historical data since the beginning of the
Cosmetics Directive in 1976. The scientific opinions, which are the basis for many of the
authorised substances or the restrictions of the substances in the Annexes, are linked to the
regulated substances. Each substance is provided with the chemical name, INN name or
IUPAC-name, CAS- and EC number, Annex and entry number and the conditions and warnings
for its use.
The other part of the database contains the EU-inventory, which is a list of assigned INCI-
names to substances offered for sale to the cosmetic industry. In addition to the INCI-name,
if possible the CAS- and EC number, chemical name or its description is added, together with
the function in the cosmetic products and finally any restrictions imposed by the Cosmetics
Directive.
Every possible link between the 2 parts has been established.
5. PART 3 OF ANNEX VI TO REGULATION (EC) NO 1272/2008
Part 3 of Annex VI to Regulation (EC) No 1272/2008 provides the harmonised European
classification of a large number of dangerous substances according to the principles laid down
in Annex I to that same Regulation (2008/1272/EC). Annex VI Part 3 previously was Annex I
to Directive 67/548/EEC, which was repealed in December 2010. The European harmonised
classification Annex is updated on a regular basis and contains a large number of chemicals
that can be found in the composition of cosmetic products. It is useful to check the
harmonised classification of a compound of interest, but it is of particular importance with
regard to Art. 15 of the Cosmetic Products, which states (2009/1223/EC):
The use in cosmetic products of substances classified as carcinogenic, germ cell mutagenic
or toxic for reproduction, of category 1A, 1B and 2, under part 3 of Annex VI to Regulation
(EC) No 1272/2008 shall be prohibited ... A substance classified in category 2 may be used
in cosmetics if the substance has been evaluated by the Scientific Committee on Consumer
Safety (SCCS) and found acceptable for use in cosmetic products.
http://ec.europa.eu/consumers/cosmetics/cosing/ Consulted December 2020.
_____________________________________________________________________________________________
155
APPENDIX 3: STANDARD FORMAT OF THE OPINIONS
Scientific Committee on Consumer Safety
SCCS
OPINION ON
……………………………………………
The SCCS adopted this document
at its plenary meeting/by written procedure on xx
_____________________________________________________________________________________________
156
ACKNOWLEDGMENTS
Members of the Working Group are acknowledged for their valuable contribution to this
Opinion. The members of the Working Group are:
The SCCS members:
………………………………………
………………………………………
………………………………………
………………………………………
………………………………………
The SCHEER members (if applicable):
………………………………………
………………………………………
………………………………………
External experts (if applicable):
………………………………………
………………………………………
………………………………………
………………………………………
………………………………………
………………………………………
The additional contribution of the following experts is gratefully acknowledged (if applicable):
XXXXXX
All Declarations of Working Group members are available on the following webpage:
https://ec.europa.eu/transparency/regexpert/index.cfm
If relevant: This Opinion has been subject to a commenting period of XXX weeks (from ……
to ……) after its initial publication.
There were comments received and the final version of the Opinion includes information on
XXXX (section concerned)….compared to the preliminary one.
There were changes/no change in the conclusions.
OR - There were no comments received and the final version of the opinion remained
unchanged compared to the preliminary one.
_____________________________________________________________________________________________
157
1. ABSTRACT
Text from the rapporteur
Or
The SCCS concludes the following:
Q1
Response
Q2
Response
Q3
Response
etc
Keywords: SCCS, scientific opinion, INCI name, type of product, Regulation 1223/2009,
CAS ………, EC …………………
Opinion to be cited as: SCCS (Scientific Committee on Consumer Safety), Opinion on INCI
name - Submission …., preliminary version of (date), final version of (date),
SCCS/…../XX……………………………………………………………………………………………
_____________________________________________________________________________________________
158
About the Scientific Committees
Two independent non-food Scientific Committees provide the Commission with the scientific
advice it needs when preparing policy and proposals relating to consumer safety, public health
and the environment. The Committees also draw the Commission's attention to the new or
emerging problems which may pose an actual or potential threat.
These Committees are: the Scientific Committee on Consumer Safety (SCCS) and the
Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) and they are
made up of scientists appointed in their personal capacity.
In addition, the Commission relies upon the work of the European Food Safety Authority
(EFSA), the European Medicines Agency (EMA), the European Centre for Disease prevention
and Control (ECDC) and the European Chemicals Agency (ECHA).
SCCS
The Committee shall provide Opinions on questions concerning all types of health and safety
risks (notably chemical, biological, mechanical and other physical risks) of non-food consumer
products (for example: cosmetic products and their ingredients, toys, textiles, clothing,
personal care and household products such as detergents, etc.) and services (for example:
tattooing, artificial sun tanning, etc.).
Scientific Committee members
Ulrike Bernauer, Laurent Bodin, Qasim Chaudhry, Pieter Jan Coenraads, Maria Dusinska,
Janine Ezendam, Eric Gaffet, Corrado Lodovico Galli, Berit Granum, Eirini Panteri, Vera
Rogiers, Christophe Rousselle, Maciej Stepnik, Tamara Vanhaecke, Susan Wijhoven
Contact
European Commission
Health and Food Safety
Directorate C: Public Health
Unit C2: Health information and integration in all policies
L-2920 Luxembourg
SANTE-C2-SCCS@ec.europa.eu
©
European Union, 20XX
ISSN ISBN
Doi: ND-
The Opinions of the Scientific Committees present the views of the independent scientists
who are members of the committees. They do not necessarily reflect the views of the
European Commission. The Opinions are published by the European Commission in their
original language only.
http://ec.europa.eu/health/scientific_committees/consumer_safety/index_en.htm
_____________________________________________________________________________________________
159
2. MANDATE FROM THE EUROPEAN COMMISSION
Background
Terms of reference
Q1
Q2
Q3
Additional information
(If appropriate)
This chapter could provide additional background information relevant to the assessment
(e.g. previous Opinions or other assessments issued by other bodies/organisations).
_____________________________________________________________________________________________
160
3. OPINION
3.1 CHEMICAL AND PHYSICAL SPECIFICATIONS
3.1.1 Chemical identity
3.1.1.1 Primary name and/or INCI name
3.1.1.2 Chemical names
3.1.1.3 Trade names and abbreviations
3.1.1.4 CAS / EC number
3.1.1.5 Structural formula
3.1.1.6 Empirical formula
3.1.2 Physical form
3.1.3 Molecular weight
3.1.4 Purity, composition and substance codes
3.1.5 Impurities / accompanying contaminants
3.1.6 Solubility
3.1.7 Partition coefficient (Log P
ow
)
3.1.8 Additional physical and chemical specifications
Where relevant:
- organoleptic properties (colour, odour, taste if relevant)
- melting point
- boiling point
- flash point
_____________________________________________________________________________________________
161
- vapour pressure
- density
- viscosity
- pKa
- pH
- refractive index
- UV/visible light absorption spectrum
3.1.9 Homogeneity and Stability
3.2 EXPOSURE ASSESSMENT & TOXICOKINETICS
3.2.1 Function and uses
3.2.2 Dermal / percutaneous absorption
3.2.3 Other studies on toxicokinetics
3.2.4 Calculation of SED/LED
3.3 TOXICOLOGICAL EVALUATION
3.3.1. Irritation and corrosivity
3.3.1.1 Skin irritation
3.3.1.2 Mucous membrane irritation / eye irritation
3.3.2 Skin sensitisation
3.3.3 Acute toxicity
3.3.3.1 Acute oral toxicity
3.3.3.2 Acute dermal toxicity
3.3.3.3 Acute inhalation toxicity
3.3.4 Repeated dose toxicity
3.3.4.1 Repeated dose (28 days) oral / dermal / inhalation toxicity
3.3.4.2 Sub-chronic (90 days) oral / dermal / inhalation toxicity
3.3.4.3 Chronic (> 12 months) toxicity
_____________________________________________________________________________________________
162
3.3.5 Reproductive toxicity
3.3.5.1 Fertility and reproduction toxicity
3.3.5.2 Developmental Toxicity
3.3.6 Mutagenicity / genotoxicity
3.3.6.1 Mutagenicity / genotoxicity in vitro
3.3.6.2 Mutagenicity / genotoxicity in vivo
3.3.7 Carcinogenicity
3.3.8 Photo-induced toxicity
3.3.8.1 Phototoxicity / photo-irritation and photosensitisation
3.3.8.2 Photomutagenicity / photoclastogenicity
3.3.9 Human data
3.3.10 Special investigations
3.4 SAFETY EVALUATION (INCLUDING CALCULATION OF THE MoS)
3.5 DISCUSSION
Physicochemical properties
Exposure & Toxicokinetics
Toxicological Evaluation
Irritation and corrosivity
Skin sensitisation
Acute toxicity
Repeated dose toxicity
Reproductive toxicity
Mutagenicity / genotoxicity
Carcinogenicity
Photo-induced toxicity
Human data
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163
Special investigation
4. CONCLUSION
Q1
Response
Q2
Response
Q3
Response
etc
5. MINORITY OPINION
6. REFERENCES
7. GLOSSARY OF TERMS
See SCCS/1628/21, 11th Revision of the SCCS Notes of Guidance for the Testing of Cosmetic
Ingredients and their Safety Evaluation from page 181
8. LIST OF ABBREVIATIONS
See SCCS/1628/21, 11th Revision of the SCCS Notes of Guidance for the Testing of Cosmetic
Ingredients and their Safety Evaluation from page 181
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164
APPENDIX 4: ANIMAL TESTING: INTERFACE BETWEEN REACH AND
COSMETICS REGULATIONS
Reference: Interface between REACH and Cosmetics regulations (ECHA, 2014a)
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165
APPENDIX 5: CMR GUIDANCE ON SAFE USE OF CMR SUBSTANCES IN
COSMETIC PRODUCTS
GUIDANCE ON A HARMONISED APPROACH TO THE DEVELOPMENT AND USE OF
OVERALL EXPOSURE ESTIMATES IN ASSESSING THE SAFE USE OF CMR SUBSTANCES
IN COSMETIC PRODUCTS
I. Background
1. Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30
November 2009 on cosmetic products
37
(Cosmetics Regulation) contains in its Article 15
provisions on the use in cosmetic products of substances classified as carcinogenic, mutagenic
or toxic for reproduction (CMR substances) under Part 3 of Annex VI to Regulation (EC)
1272/2008
38
. These provisions apply from 1 December 2010.
2. As a general rule, the substances classified as CMR substances of category 1A, 1B and 2
under Part 3 of Annex VI to Regulation (EC) 1272/2008 are prohibited for use in cosmetic
products.
3. However, exceptions to this rule are foreseen by the Cosmetics Regulation. Indeed, a
substance classified as a CMR substance of category 2 may be used in cosmetic products
where the substance has been evaluated by the Scientific Committee on Consumer Safety
(SCCS) and found safe for use in cosmetic products on the basis of the data submitted.
4. Also, CMR substances of category 1A or 1B may be used in cosmetic products by way of
exception where, subsequent to their classification as CMR substances of category 1A or 1B
under Part 3 of Annex VI to Regulation (EC) No 1272/2008, all of the following conditions are
fulfilled:
(a) they comply with the food safety requirements as defined in Regulation (EC) No 178/2002
of the European Parliament and the Council of 28 January 2002 laying down the general
principles and requirements of food law, establishing the European Food Safety Authority
and laying down procedures in matters of food safety
39
;
(b) there are no suitable alternative substances available, as documented in an analysis of
alternatives;
(c) the application is made for a particular use of the product category with a known
exposure; and
(d) they have been evaluated and found safe by the SCCS for use in cosmetic products, in
particular in view of exposure to these products and taking into consideration the overall
exposure from other sources, taking particular account of vulnerable population
subgroups.
II. Scope and objectives
5. Article 15, paragraph 3 of the Cosmetics Regulation foresees that the Commission shall
ensure that appropriate guidance is developed with the aim of enabling a harmonised
approach to the development and use of overall exposure estimates in assessing the safe use
of CMR substances.
37
OJ L 342, 22.12.2009, p. 59.
38
OJ L 353, 31.12.2008, p. 1.
39
OJ L 31, 1.2.2002, p. 1.
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166
6. To authorise the use of CMR substances of category 1A or 1B in cosmetic products, one of
the conditions to be fulfilled is that they have been evaluated and found safe by the SCCS for
use in cosmetic products, in particular in view of exposure to cosmetics products and taking
into consideration the overall exposure from other sources and vulnerable population
subgroups.
7. On a case-by-case basis and at the request of the SCCS, it may also be necessary to
perform an overall exposure from other sources for CMR 2 substances. Therefore, the
procedure developed below for the overall exposure assessment of CMR 1A and 1 B
substances should, where necessary, also apply to CMR 2 substances (condition (d) only)
8. Appropriate consultations with the SCCS and other relevant stakeholders have been carried
out in order to develop this guidance. In addition, administrative agreements have been
established with relevant EU Agencies - European Chemicals Agency (ECHA), European Food
Safety Authority (EFSA), European Medicines Agency (EMA) - to ensure the appropriate
exchange of data between them and the SCCS Secretariat.
III. Procedure
9. The aim of this guidance is to outline the mechanisms necessary for ensuring the
generation and the exchange of the appropriate data for the assessment by the SCCS of the
overall exposure to a CMR 1A or 1B substance stemming from other sources than cosmetics
(such as food, biocides, etc.).
10. When a substance of interest for the industry is indicated in the Registry of Intentions for
the purpose of its harmonised classification as CMR substance under Part 3 of Annex VI to
Regulation (EC) No 1272/2008, it is for the industry to inform the Commission in due time of
its intention to defend a substance under discussion to allow that any possible derogation
measure is adopted by the Commission within the timeframe defined by Article 15 of the
Cosmetics Regulation 1223/2009.
11. The Commission responsible Services should inform the SCCS that the industry intends to
defend the substance. They should also inform the Member States of this intention, so that
any relevant data available in public or state laboratories, or elsewhere, may be considered
for the scientific assessment. In parallel, they may also organise a call for scientific data from
anyone holding or being aware of further relevant information, in order to gather additional
scientific data.
12. It is the industry's responsibility to demonstrate that the first three conditions (a), (b)
and (c) for derogation laid down in Article 15 paragraph 2 of Cosmetics Regulation are
fulfilled. For justifying compliance with each of the above conditions, the industry should
submit appropriate dossiers for examination by the Commission responsible Services.
13. The Commission responsible Services should verify the compliance with the food safety
requirements, where necessary by consulting the EFSA, and verify the absence of suitable
alternative substances and the fact that the application is limited for a particular use of the
product category with a known exposure, where necessary by consulting the Standing
Committee on Cosmetic Products.
14. Subsequently, the procedure for the exchanges of data between the relevant entities can
be started as regards to the overall exposure assessment by the SCCS (condition d). Requests
for data sharing with the relevant EU Agencies (ECHA, EFSA and EMA
40
) should be initiated
and managed by the SCCS Secretariat. On a case by case basis, the Commission responsible
Services can, where relevant, ask for data to Member States or third countries.
40
The need to consult EMA will be checked by the Commission on a case by case basis.
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167
15. The "Declaration of Commitment by the Commission with respect to security aspects for
ECHA's information systems" has been signed by the responsible Commission Services
41
and
sets up the conditions under which exchange of confidential data from REACH dossiers can
be ensured with ECHA.
16. Upon request by the SCCS Secretariat, the Commission responsible Services should grant
access to relevant data in REACH registration dossiers to a designated SCCS expert who
adheres to the security rules for users of ECHA's Information System.
17. The extraction of relevant data from REACH dossiers and their processing to establish
aggregated exposure levels should be completed by the designated SCCS expert within the
secure room of the Commission responsible Services and in accordance with all applicable
security rules. In case an evaluation of the CMR substance has already been completed under
REACH, exposure levels that have been established can also be used straightaway where
appropriate.
18. The EFSA should be consulted by the SCCS Secretariat to provide, if available, data or
estimates on exposure from food and other relevant sources.
19. Additionally, the EMA could be consulted by the SCCS Secretariat on a case-by-case basis
on exposure from substances used as pharmaceuticals.
20. The applicant should include in their submission all of the exposure information that they
have. In addition to the exposure information gathered as mentioned above, e.g., exchange
of data with the Agencies, public call for information, consultation with Member States, the
SCCS will consider the exposure information provided by the applicant.
21. It is necessary that the exchange of data takes place in a smooth and timely manner as,
for CMR 1A and 1B substances, the measure necessary for the derogation must be adopted
by the Commission within 15 months following the adoption of the classification as CMR
substance.
22. The SCCS, once it has received the scientific data from ECHA, EFSA, EMA and has taken
into consideration the data submitted by the industry and other available sources (such as
information gathered from Member States or following public consultation), shall assess the
specific CMR substance(s) for safety of use in cosmetic products taking into account the
overall exposure from other sources and vulnerable population groups within a timescale of
at least six months for finalising their Opinion after an adequate submission and a complete
set of exposure data is received.
23. It should be noted that, where the work of other scientific/regulatory bodies contains
information on exposure to humans via the environment, this may have been incorporated in
their overall estimates of exposure. However, Cosmetic Regulation (EC) No 1223/2009 only
covers the aspects of safety to human health. As indicated in recital 5 of that Regulation, the
environmental concerns that substances used in cosmetic products may raise are considered
through the application of Regulation (EC) No 1907/2006 (REACH)
42
.
24. As regards the scientific risk assessment of CMR substances of categories 1A and 1B used
in cosmetics, the SCCS will determine the most appropriate methodology for their safety
evaluation based on the best scientific knowledge and taking into account the exposure from
the specific uses in cosmetic products and the overall exposure from other sources.
41
DG ENTR and DG ENV co-managed the REACH legislation.
42
OJ L 396, 30.12.2006, p. 1.
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168
25. In order to provide transparency on the applied methodology and guidance to the industry,
the SCCS should develop and incorporate this methodology within the next revision of its
"Notes of Guidance for the testing of cosmetic substances and their safety evaluation"
43
.
IV. Final observations
26. This document is only meant to provide guidance for a harmonised approach to the
development and use of overall exposure estimates in assessing the safe use of CMR
substances in cosmetic products and it is by no means binding.
27. The SCCS evaluation will not automatically trigger action under any legislation other than
the Cosmetics legislation. The SCCS conclusions will be publicly available.
28. This document may be revised in the future in light of further scientific developments.
43
SCCS/1564/15 of 29 September 2015, revised on 16 March 2016.
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169
APPENDIX 6: REQUIREMENTS FOR THE CERTIFICATE OF ANALYSIS
FOR A COSMETIC INGREDIENT
The Certificate of Analysis for a cosmetic ingredient should include:
1. The name and address of the laboratory performing the tests.
2. The registration number of the certificate of analysis.
3. The name, description and number of the batch for which the certificate is issued, the
date of manufacture, and the expiry date.
4. The date on which the batch for which the certificate is issued was received.
5. A reference to the test procedure used, including the acceptance criteria (limits).
6. The results of all tests performed on the batch for which the certificate is issued (in
numerical form, where applicable) and a comparison with the established acceptance
criteria (limits), including information on Appearance, Identity (IR, NMR, MS), Purity,
Solubility, Impurities (% content), Heavy metals.
7. Any additional test results obtained on samples from the batch as part of a periodic
statistically based testing program
8. A statement indicating whether the results were found to comply with the
requirements.
9. The date(s) on which the test(s) was (were) performed.
10. The signature of the head of the laboratory or an authorised person.
11. The name, address, and telephone and fax numbers of the original manufacturer. If
supplied by repackers or traders, the certificate should show the name, address, and
telephone and fax numbers of the repacker/trader and a reference to the original
manufacturer.
12. A statement of the expected conditions of shipping, packaging, storage and
distribution, deviation from which would invalidate the certificate.
13. A copy of the certificate generated by the original manufacturer, if the sample is
supplied by a repacker or trader.
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170
APPENDIX 7: DETAILED EXPOSURE DATA FOR COSMETIC PRODUCTS
During the last years, exposure data for several cosmetic product categories became available
in the open literature. This can be useful for safety assessors and safety agencies when in
some particular cases refinement of risk assessment is necessary to show product or
ingredients safety. In Table A.7 a literature overview is provided of recent cosmetic product
consumer exposure data (e.g. different categories of cosmetics with frequency of use, amount
per application, amount per day) which are focused on consumers from one or more particular
countries. In a number of cases, data are shown stratified by age and/or gender, and for
different cosmetic formulations.
Table A.7: literature overview (2015-2020) of specific cosmetic consumer exposure data and
assessments
References
Country(ies)
Product categories
Additional information
Husoy et al., 2020
Norway
cosmetic products and
toothpaste
Adults, both genders
Gomez-Berrada et
al., 2018a
France
toothpaste
adults and children;
both genders
Gomez-Berrada et
al., 2018b
France
sunscreens
adults and children; both
genders under real-life
conditions
Bernard et al., 2018
France
face and oral care
cosmetic products
probabilistic exposure
assessment; both genders;
different age groups
Gomez-Berrada et
al., 2017
France/ (1 city: Rennes)
cosmetic products
children under 2 years
consumption; exposure
assessment
Ficheux and Roudot
2017
France
cosmetic products
general population; both
genders; different age groups
Dornic et al., 2017a
France
perfumes in cosmetic
products
adults and children
Dornic et al., 2017b
France
default values for skin surface
area
Dornic et al., 2017c
France
cosmetic products
exposure data;
both genders, different age
groups
Lee et al., 2017
Korea
baby care products
children 0-3 years
Garcia-Hidalgo et al.,
2017
Swiss
personal care products
use patterns both genders;
different age groups
Rieder et al., 2017
cosmetic ingredient
case of tea tree oil
Strittholt et al., 2016
toothpaste
in children (2-7yrs)
Bernard et al., 2016a
France
hair dye products
both genders
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171
use patterns; exposure
assessment
Ficheux et al., 2016a
France
different cosmetic products
children (0-3yrs)
Ficheux et al., 2016b
France
different hair cosmetic
products
both genders
Ficheux et al., 2016c
Ficheux et al.,2019
France
France
different cosmetic products
different cosmetic products
consumption amounts;
different age groups; both
genders
probabilistic aggregate exposure
for babies, children; both
genders
Dey et al., 2016a
USA, Germany, UK
baby wipes
lotion transfer via baby wipes
Dey et al., 2016b
world
exposure factor of disposable
diapers
Comiskey et al.,
2015
EU, USA
fragrance ingredients
probabilistic aggregate exposure
Manová et al., 2015
Swiss, Germany
UV filter
ethylhexylmethoxy-
cinnamate
probabilistic aggregate exposure
Tozer et al., 2015
USA
Zn pyrithione in rinse-off
personal cleansing
products
probabilistic aggregate exposure
Dudzina et al., 2015
siloxane D5
probabilistic aggregate exposure
(PACEM)
Nijkamp et al., 2015
fragrance geraniol in
personal care products
probabilistic aggregate exposure
Safford et al., 2015
fragrance ingredients in
cosmetic and personal care
products
probabilistic aggregate exposure
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172
APPENDIX 8: KEY CHARACTERISTICS OF CARCINOGENS
In the overall WoE assessment of a cosmetic ingredient, 10 key characteristics commonly
exhibited by established human carcinogens can be taken into account (Smith et al., 2019,
Al-Zougholl, 2019). High-throughput assay systems, such as the US EPA’s ToxCast program
(Chiu et al., 2018), which provide in vitro mechanistic data on several of the key
characteristics, may be helpful.
Table A.8: Key characteristics of carcinogens (based on: Smith et al., 2019 and Al-Zougholl
et al., 2019); AhR, aryl hydrocarbon receptor; ER, estrogen receptor; PPAR, peroxisome proliferator
activated receptor.
Characteristic
Description
1. Is electrophilic or can be
metabolically activated to
electrophiles
Formation of protein adducts indicates the presence of reactive
chemicals, which are sometimes also considered as indirect
indicators/predictors of DNA damage (see characteristic 2, below)
Requires biotransformation (metabolic activation) to produce reactive
metabolites, e.g. alkylating agents, epoxide metabolites, aryl-nitrenium
ion
Evidence for ADME of the agent affecting its carcinogenicity
2. Is genotoxic
Direct evidence of DNA damage this category includes nuclear and
mitochondrial DNA damage (in vitro or in vivo): DNA adducts, DNA
strand breaks (single- and/or double-strand breaks), DNAprotein cross-
links, DNADNA cross-links.
Indirect indicators or biomarkers of DNA damage (in vitro or in vivo).
Disruption or breakages of chromosomes leading to sections of the
chromosome being deleted, added, or rearranged.
Reversions and forward mutations in microorganisms or mammalian
cells. Mutations affecting oncogenes, tumour-suppressor genes, and
other genes involved in cell cycle control.
3. Alters DNA repair or
causes genomic instability
Effects on key DNA-repair mechanisms such as base-excision repair
(BER) and nucleotide-excision repair (NER). Inherited abnormalities in
DNA-repair function lead to enhanced cancer susceptibility.
4. Induces epigenetic
alterations
Stable, long-term alterations in the transcriptional potential of a cell.
These effects can be caused by factors such as altered methylation of
DNA, micro-RNA expression, and changes in chromatin and histone
structure.
5. Induces oxidative stress
Disturbance in the balance between the production of reactive oxygen
species (free radicals) and antioxidant defenses within a cell.
6. Induces chronic
inflammation
Chronic inflammation and/or irritation leading to oxidative DNA damage.
7. Is immunosuppressive
Measures of altered function of the immune system that may lead to
increased cancer risk (e.g. HIV-related effects).
8. Modulates receptor-
mediated effects
Interference with cell-signaling pathways leading to expression of
carcinogenic trait/phenotype in the cell, e.g. facilitating cell invasion or
induction of genes for inflammatory mediators, oncogenes
Interference with the synthesis, secretion, transport, binding, action, or
elimination of natural hormones in the body. External agents can
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173
interfere with the synthesis, secretion, transport, binding, action, or
elimination of natural hormones in the body.
9. Causes immortalization
A. Oncogenic transformation, i.e. anchorage-independent growth, loss of
contact inhibition.
B. Increased motility and invasiveness of cancer cell lines
C. Cell transformation
Activation of a telomerase that prevents loss of telomere length, leading
to immortalization of cells.
10. Alters cell proliferation,
cell death or nutrient supply
Interference with cell-signaling pathways leading to expression of
carcinogenic trait/phenotype in the cell e.g. facilitating cell invasion or
induction of gene promotion for inflammatory mediators, oncogenes.
Induced defects in programmed cell death (apoptosis). Evasion of
apoptosis is a requirement for both neoplastic transformation and
sustained growth of cancer cells.
Detection of alterations in cell proliferation and cell-cycle effects (e.g.
DNAreplication changes, cell-cycle control, ploidy), mitogenesis. Altered
nutrient supply affects cell viability.
Change in pro-angiogenesis factors
Disruption of gap-junction intercellular communication pathways that
can cause a loss of ‘contact inhibition’ and abnormal cell growth.
The bystander effect was first identified in radiobiology and refers to the
situation where non-irradiated cells exhibit effects caused by radiation
as a result of chemical signals (messengers) received from nearby
irradiated cells. These effects are often mediated through gap-junction
transfer of chemical agents.
Any of the 10
characteristics in this table
could interact with any
other (e.g., oxidative
stress, DNA damage, and
chronic inflammation),
which when combined
provides stronger evidence
for a cancer mechanism
than would oxidative stress
alone.
Any of the 10 characteristics in this table could interact with any other (e.g., oxidative stress, DNA
damage, and chronic inflammation), which when combined provides stronger evidence for a cancer
mechanism than would oxidative stress alone.
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174
APPENDIX 9: GUIDELINES ON MICROBIOLOGICAL QUALITY OF THE
FINISHED COSMETIC PRODUCT
This part has been taken over from the 9th Revision of the NoG (SCCS/1564/15):
https://ec.europa.eu/health/sites/health/files/scientific_committees/consumer_safety/docs
/sccs_o_190.pdf
Although the NoG are concerned with the safety evaluation of ingredients, this appendix is
concerned with the finished cosmetic product. The reason for this is the fact that in other
pieces of legislation, reference has been made to it as being part of the NoG.
Preamble:
Skin and mucous membranes are protected from microbial attack by a natural mechanical
barrier and various defence mechanisms. However, these may be damaged and slight
trauma may be caused by the action of some cosmetics that may enhance microbial
infection. This may become of particular concern when cosmetics are used around the eyes,
on mucous membranes in general, on damaged skin, on children under 3 years, on elderly
people and persons with compromised immune system. Consequently, two separate
categories of cosmetic products are defined in the microbiological quality control limits:
Category 1: Products specifically intended for children under 3 years, to be used in the eye
area and on mucous membranes.
Category 2: Other products.
Microbial contaminants usually come from two different origins: during production and filling,
and during the use of the cosmetic by the consumer. From the moment the cosmetic unit is
opened until the last use of the product by the consumer(s), a permanent, variable and
additive microbial contamination of the cosmetic is introduced, caused by the domestic
environment and contact with the skin of the consumer(s) (hands and body).
Reasons for microbial preservation of cosmetics are:
- to ensure the microbial safety of cosmetics for the consumer,
- to maintain the quality and specifications intended of the product,
- to confirm hygienic and high-quality handling.
Although only a small number of cases of microbiological contamination of cosmetics leading
to microbial infections of the consumer has been reported, microbial contamination of
cosmetic products may spoil them or seriously reduce the intended quality. In order to
ensure the quality of the product and the safety for the consumer, it is necessary to carry
out routine microbiological analysis of each batch of the finished product coming on the
market. In some justified cases (e.g. alcohol content > 20%), end product testing is not
necessary (ISO 29621, 2010). The parameters examined, the criteria and methods used,
and the results obtained per batch should be specified in properly filed reports and be taken
up in the TIF.
Quantitative and qualitative limits
Quantitative and qualitative limits are based on the European Standard EN ISO 17516:2014
Cosmetics Microbiology Microbiological limits. The European Standard EN ISO
17516:2014 was approved by CEN on 9 August 2014 and at present is widely used by the
cosmetics industry as international standard (Table A9). It is reviewed and confirmed in
2020
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175
Table A9: Microbiological limits for cosmetics. European Standard EN ISO 17516:2014
Cosmetics Microbiology Microbiological limits
Types of microorganism
Products specifically
intended for children
under three years of age,
the eye area or the
mucous membranes
Other products
Total Aerobic Mesophilic
Microorganisms (Bacteria
plus yeast and mould)
≤ 1 x 10
2
CFU per g or
ml
a
≤ 1 x 10
3
CFU per g or
ml
b
Escherichia coli
Absence in 1 g or 1 ml
Absence in 1 g or 1 ml
Pseudomonas aeruginosa
Absence in 1 g or 1 ml
Absence in 1 g or 1 ml
Staphyloccocus aureus
Absence in 1 g or 1 ml
Absence in 1 g or 1 ml
Candida albicans
Absence in 1 g or 1 ml
Absence in 1 g or 1 ml
Due to inherent variability of the plate count method, according to USP Chapter 61 or EP
Chapter 2.6.12, Interpretation of results, results considered out of limit if
a > 200 CFU/g or ml,
b > 2 000 CFU/g or ml.
NOTE When colonies of bacteria are detected on Sabouraud Dextrose agar, Sabouraud
Dextrose agar containing antibiotics may be used.
Challenge testing (based on US Pharmacopoeia 2014, European Pharmacopoeia 2014)
Note that this chapter addresses microbiological contamination, i.e. unwanted presence of
microorganisms. Total germ counts and challenge test are not directly applicable for the case
of probiotic cosmetic formulations to which live or viable microorganisms have been
deliberately added.
The efficacy of the preservation of a cosmetic product under development has to be assessed
experimentally in order to ensure microbial stability and preservation during storage and
use. This is done by challenge testing. The latter is mandatory for all cosmetic products that,
under normal conditions of storage and use, may deteriorate or form a risk to infect the
consumer.
A challenge test consists of an artificial contamination of the finished product, followed by a
subsequent evaluation of the decrease in contamination to levels ensuring the microbial
limits established for Categories 1 and 2. The microorganisms used in the challenge test may
be issued from official collection strains from any state in the EU to ensure reproducibility of
the test and are: Pseudomonas aeruginosa, Staphylococcus aureus, Candida albicans and
Aspergillus brasiliensis.
It is well known today that the consistency of challenge tests relies more on the capability
of the used microorganisms to contaminate a specific cosmetic product than on the
taxonomic status of the microorganisms, their initial concentrations, or the conditions of
incubation and media of recovery used. Microorganisms with the capability to contaminate
specific cosmetics are the best candidates for use in a challenge test. The microbicidal
activity of preservatives or any other compound in the finished cosmetic must be ruled out
in the challenge test by dilution, filtration, addition of neutralisers or any other means.
The experimental performance of the microbial controls and the challenge tests must be
carried out/supervised and validated by a microbiologist. As mentioned before, the
responsible person must guarantee the efficacy of the preservation of his products
experimentally by challenge testing. However, as no legal or universal challenge test method
is currently available, it is up to the responsible person to decide on the details of the test
to be used.
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176
Good Manufacturing Practice (GMP)
In order to comply (mandatory but no certification required) with Good Manufacturing
Practice and Microbial Quality Management, manufacturers of cosmetics have to define and
follow specific cleaning, sanitation and control procedures to keep all apparatus and materials
appropriately clean and free of pathologic microorganisms. Procedures also include
microbiological control of raw materials, bulk and finished products, packaging material,
personnel, equipment and preparation and storage rooms. Compliance should be checked
with the currently available European Committee for standardization (CEN) standards
(available through http://www.cenorm.be/cenorm/index.htm) and/or ISO standards
(available through http://www.iso.org/iso/en/ISOOnline.frontpage). According to Article 8 of
Regulation (EC) No 1223/2009, good manufacturing shall be presumed where the
manufacture is in accordance with the relevant harmonised standards, the references of
which have been published in the Official Journal of the European Union.
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177
APPENDIX 10: FREE ACCESS TO IN SILICO MUTAGENICITY /
GENOTOXICITY AND CARCINOGENICITY DATABASES
The Danish QSAR database (http://qsar.food.dtu.dk/) which includes QSAR models
based on structural alerts for DNA reactivity; in vitro Ames test in S. typhimurium,
chromosome aberration in Chinese Hamster Lung (CHL) and ovary (CHO) cells;
Comet assay in mouse; micronucleus test in mouse erythrocytes; sister chromatid
exchange in mouse bone marrow cells; mutations in HGPRT locus in Chinese hamster
ovary (CHO) cells; mutations in thymidine kinase locus in mouse lymphoma cells;
and sex-linked recessive lethal test in Drosophila melanogaster.
The OECD QSAR Toolbox (https://qsartoolbox.org/), which also incorporates the
models and tools from the Danish QSAR database, provides a versatile suite of
programs for chemical profiling, categorisation, and data gap filling by (Q)SAR models
and read-across for various toxicological endpoints, including mutagenicity. The
system also includes metabolic simulators that further enable the prediction and
genotoxicity assessment of metabolites. The Toolbox also provides profilers for
mutagenicity that are based on structural alerts for in vitro mutagenicity (Ames test),
in vivo mutagenicity (micronucleus) chromosomal aberration and micronucleus test,
and DNA and protein binding. The predictions from the profilers can provide
supporting information when used in conjunction with QSAR predictions. The Toolbox
also provides a few profilers that combine several structural alerts for the purpose of
category formation on the basis of carcinogenicity potential of chemical substances.
A notable one is the ISS profiler that combines 58 structural alerts for carcinogenicity
(both genotox and non-genotox) from the Toxtree software
(http://toxtree.sourceforge.net/ ). Around 20 of the alerts are for non-genotoxic
carcinogenicity, and the remaining ones for genotoxic carcinogenicity (mutagenicity).
A recent study (Aljallal, 2020) has indicated that some of the structural alerts and
the profilers provided in the OECD QSAR Toolbox need further refinement, and their
use in conjunction with QSAR models and read-across would be required to improve
the accuracy of predictions.
VEGA QSAR platform (www.vegahub.eu/) provides QSAR models for mutagenicity
developed in line with the OECD principles using high quality datasets with the aim
to use for regulatory purposes;
The US-EPA’s Toxicity Estimation Software Tool (T.E.S.T.)
(www.epa.gov/nrmrl/std/qsar/qsar.html) is an Expert system that uses an ensemble
of QSARs to estimate toxicity - including mutagenicity (Ames test in S. typhimurium);
Toxtree (http://toxtree.sourceforge.net/) enables estimation of toxicity hazard by
applying a decision tree approach;
Lazar (https://lazar.in-silico.ch/predict) is an automated system of read across to
calculate toxicity predictions.
OpenTox for carcinogenicity through OpenTox platform (ToxPredict)
(www.opentox.net/library/toxicity-prediction
OncoLogic (US EPA) (www.epa.gov/tsca-screening-tools/oncologictm-expert-
system-evaluate-carcinogenic-potential-chemicals
_____________________________________________________________________________________________
178
APPENDIX 11: INHALATION PARAMETERISATION
Table A. 11: Example for the parameterisation of a 2- Box model for sunscreens based on
Rothe et al., 2011 and SCCS recommendations. Product-dependent parameter values in this
example are specific for sunscreens and denoted with an asterix * (see also 3-3.5.4.1
calculation of the inhalation SED)
Parameter
Parameter description
Propellant
spray
Pump
spray
Unit
Reference
a
product
*
amount per application*
9
9
g/application
SCCS, NoG
f
air
air-borne fraction of spray
mist
1
0.2
fraction
Bremmer et al, 2006
V
1
*
Box 1 (Near-field around
the head)*
1000
1000
L
SCCS, Octocrylene
t
1
*
duration of exposure in
Box 1
(near field)*
2
2
min
SCCS, Octocrylene
r
inh
inhalation rate
13**
13**
L/min
US-EPA 2011
V
2
*
Box 2 (Far-field, e.g.
bathroom)*
10000
10000
L
SCCS, Octocrylene
t
2
*
duration of exposure in
Box 2 (far field)*
10
10
min
SCCS, Octocrylene
f
resp
respirable fraction
experimental
data
experimental
data
fraction
f
ret
substance retention
fraction in the lungs (25%
exhaled)
0.75
0.75
fraction
Rothe et al., 2011
f
appl
*
frequency of application*
2
2
per day
SCCS, NoG
bw
bodyweight
60
60
kg
SCCS, NoG
* Product-dependent parameter value;
**highest median among several adult age categories;
SCC/1627/21 opinion on octocrylene; SCCS NoG = SCCS Notes of Guidance.
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179
APPENDIX 12: LIFETIME CANCER RISK (LCR) APPROACH
The "T25 method" (Sanner et al., 2001) is used as a simple method for quantitative risk
assessment of carcinogens in the REACH Regulation (ECHA, 2017). It should be noted that,
in six cases where high quality epidemiology and animal carcinogenicity studies were
available, quantitative risk characterisation based on epidemiological data and data based on
animal studies using the T25 method differed by factors of less than three (Sanner and
Dybing, 2005).
Determination of the LCR is carried out in different steps. After having decided what animal
data set to use and type of tumour to consider, the dose descriptor T25 is determined, which
is described in detail (ECHA, 2012a; Dybing et al., 1997).
The animal dose descriptor (T25) is converted to the human dose descriptor (HT25) based
on comparative metabolic rates (Sanner et al., 2001):
HT25=
T25
(body weight
human
/body weight
animal
)
0.25
Based on the daily lifetime SED, the LCR is calculated by linear extrapolation by use of the
following formula:
LCR =
SED
HT25/0.25
Subsequently, a statement is generated describing whether the actual risk may be higher or
lower than the risk calculated for a specific scenario. The procedure and the following
elements are reported and discussed in detail (Sanner et al., 2001; ECHA, 2012a).
_____________________________________________________________________________________________
180
APPENDIX 13: POD USED FOR TTC DERIVATION
Table A.13: Chemical classes and 5
th
percentile Cramer Class PoDs of selected published TTC
datasets. n = number of substances / PoDs in the dataset. 5
th
percentiles were derived from log-normal
parametric distributions, except by Pinalli et al., (2011); van Ravenzwaay (2017) and Kalkhof et al.
(2012) who did not report the calculation method. NO(A)EL = No Observed Adverse Effect Level; PoD
= Point of Departure; CC = Cramer Class; DB = data base; dev. = developmental
References
Dominant chemical classes
n
5th percentile NO(A)ELs
adjusted to chronic (PoD,
mg/kg bw/day)
Cramer
Class I
Cramer
Class II
Cramer
Class III
Yang et al., 2017,
‘federated’
Cosmetic-related,
packaging and pesticides
977
4.57
0.62
0.23
Munro et al., 1996
Food contact, pesticides
612
3.0
0.91
0.15
Yang et al., 2017, Munro
et al., 1996 ‘Munro-2016’
Some Cramer Classes and
other errors corrected,
harmonised assessment
factors
612
4.90
1.07
0.15
Yang et al., 2017,
COSMOS 2017
Cosmetic-related & packaging
552
4.20
0.58
0.79
Tluczkiewicz et al., 2011
Industrial chemicals and
pesticides
521
0.62
0.038
Kalkhof et al., 2012
German pre-REACH DB,
industrial chemicals
813
2.5 (n=69)
2.5 (n=20)
1.3
(n=724)
Pinalli et al., 2011
Food contact materials
232
CCI/II not reported
£
CCIII reported in
Feigenbaum et al.,
2015
0.4
£
(n=113)
Feigenbaum et al., 2015
Pesticides without carbamates
and organophosphates
279
-
-
0.2
Munro+ Pinalli+ pesticides
with carbamates and
organophosphates
840
0.15
Laufersweiler et al., 2012
Only reproductive and
developmental endpoints.
From Kroes et al. (2000),
Bernauer et al. (2008), plus
literature.
283
13.1
(n=69)
1.87
(n=11)
0.31
(n=203)
Van Ravenzwaay et al.,
2017
Chemicals & pesticides,
developmental studies only
150§/
537*
§rabbits: 5/9.5 maternal/dev
*rats: 7.6/10 maternal/dev
Patel et al., 2020
‘RIFM’
Fragrance chemicals
476
5.39
(n=238)
1.97
(n=76)
1.17
(n=162)
Patel et al., 2020
‘RIFM/COSMOS/Federated’
Fragrance chemicals,
Cosmetic-related, packaging
and pesticides
1327
4.91
(n=421)
1.27
(n=111)
0.29
(n=795)
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181
ABBREVIATIONS AND GLOSSARY OF TERMS
2D Two Dimensional
3D
Three Dimensional
3R
Refinement, Reduction, Replacement
3T3 NRU PT
3T3 Neutral Red Uptake Phototoxicity Test
A
Androgen
Å
Angström
ADME
Absorption, Distribution, Metabolism, Excretion
ADRA
Amino acid Derivative Reactivity Assay
Adverse
An adverse response is defined as any treatment-related
response that results in change in the morphology,
physiology, growth, development or life-span of an organism,
which results in an impairment of functional capacity, an
impairment of the capacity to compensate for additional
stress, or an increase in susceptibility to other environmental
influences (WHO 2004)
AEL
Acceptable Exposure Level
AhR
Aryl hydrocarbon Receptor
AIC
Akaike Information Criterion
A.I.S.E.
International Association for Soaps, Detergents and
Maintenance Products
Alternative methods
All those procedure which can completely replace the need
for animal experiments, which can reduce the number of
animals required, or which can reduce the amount of pain
and stress to which the animal is subjected in order to meet
the essential needs of humans and other animals
(Rogiers et al., 2000; Russell et al., 1959)
AMA
Amphibian Metamorphosis Assay
AOP
Adverse Outcome Pathway
AR
Androgen Receptor
Art.
Article
AhR
Aryl hydrocarbon Receptor
ATM
Alternative Test Method
ATP
Adaptation to Technical and scientific Progress
AUC
Area Under the Curve
BCOP
Bovine Corneal Opacity and Permeability
BCRP
Breast Cancer Resistance Protein
BHT
Butylated HydroxyToluene
BMD
The BenchMark Dose is proposed as an alternative for the
classical NOAEL and LOAEL values. The BMD is based on a
mathematical model being fitted to the experimental data
within the observable range and estimates the dose that
causes a low but measurable response (the benchmark
response BMR) typically chosen at a 5 or 10% incidence
above the control.
BMDS
BMD Software
BMDL
BMD Lower limit refers to the corresponding lower limit of a
one-sided 95% confidence interval on the BMD.
BMDU
BMD Upper limit refers to the corresponding upper limit of a
one-sided 95% confidence interval on the BMD.
BMR
BenchMark Response
BoA
Board of Appeal
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182
BrdU
5-Bromo-2-deoxy-Uridine
BSE
Bovine Spongiform Encephalopathy
BW
Body Weight
C
Concentration
CAS n°
Chemical Abstracts Service registry number
Cat.
Category
CC
Cramer Class
CEBS
Chemical Effects in Biological Systems
CEL
Consumer Exposure Level
CEN
European Committee for Standardization
CERAPP
Collaborative Estrogen Receptor Activity Prediction Project
CFU
Colony Forming Unit
CHMP
Committee for Medicinal Products for Human use
CI
Colour Index
Colour Index
CIN
Common Ingredient Name
CLP
Classification, Labelling and Packaging of Substances and
Mixtures
CMR
Carcinogenic, Mutagenic, toxic to Reproduction
CM
Cytosensor Microphysiometer
COC
Committee on Carcinogenicity of Chemicals in Food,
Consumer Products and the Environment.
Colipa
The European Cosmetic and Perfumery Association
COM
COmmittee on Mutagenicity of Chemicals in Food, Consumer
Products, and the Environment
COM
Communication from the Commission
COMET
COnsortium for MEtabonomic Toxicology
CPDB
Carcinogenic Potency DataBase
CPSR
Cosmetic Product Safety Report
CVM
Collagen Vitrigel Membrane
CYP
Cytochrome P450
DA
Defined Approach
DART
Developmental and Reproductive Toxicity Database
DB
Data Base
Dev.
Developmental
DG
Directorate General
DIMDI
German Institute for Medical Documentation and Information
DPRA
Direct Peptide Reactivity Assay
E
Estrogen
EADB
Endocrine Activity Database
EASIS
Endocrine Active Substances Information System
EATS
Estrogenic, Androgenic, Thyroid, Steroidogenic
EC
European Commission
ECB
European Chemicals Bureau
ECETOC
European Centre for Ecotoxicology and Toxicology
of Chemicals is an industry-funded expert not-for-profit
think tank whose sole purpose is to enhance the quality
of chemicals risk assessment so that chemicals
management decisions are informed, reliable and safe.
ECHA
European CHemicals Agency
ECVAM
European Centre for the Validation of Alternative Methods
ED
Endocrine Disruptor
Ed.
Edition
E dermal
Exposure dermally
EDKB
Endocrine Disruption Knowledge Base
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183
EDSP
Endocrine Disruption Screening Program
EEC
European Economic Community
EFSA
European Food Safety Authority
EINECS
European INventory of Existing commercial Chemical
Substances
EIT
Eye Irritation Test
ELINCS
European LIst of Notified Chemical Substances
ELISA
Enzyme-Linked ImmunoSorbent Assay
EMA/EMEA
European Medicines Agency
EOGRTS
Extended One-Generation Reproductive Toxicity Study
(US) EPA
(United States) Environmental Protection Agency
ER
Estrogen Receptor
ERBA
Endocrine Receptor Binding Assay
ESAC
ECVAM Scientific Advisory Committee
EDSP
Endocrine Disruptor Screening Program
EST
Embryonic Stem cell Test
EU
European Union
EURL-ECVAM
European Union Reference Laboratory - European Centre for
the Validation of Alternative Methods
F
Frequency of application
FDA
Food and Drug Administration (federal agency of the United
States Department of Health and Human Services)
Finished cosmetic product
The cosmetic product in its final formulation, as placed on
the market and made available to the end user, or its
prototype (2009/1223/EC)
FL
Fluorescein Leakage test
f
ret
Retention factor
GC-MS
Gas ChromatographyMass Spectrometry
GLP
Good Laboratory Practice
GMP
Good Manufacturing Practice
GPMT
Guinea Pig Maximisation Test
GR
Glucocorticoid Receptor
GST
Glutathione S-Transferase
GUM
Gesellschaft für Umweltmutationsforschung
Hair product
A cosmetic product which is intended to be applied on the
hair of head or face, except eyelashes (2009/1223/EC)
HBM
Human BioMonitoring
HCA
High Content Analysis
HCE
Human Corneal Epithelium
hCLAT
human Cell Line Activation Test
HESS
Hazard Evaluation Support System
HET-CAM
Hen's Egg Test-Chorio Allantoic Membrane
HET-MN
Hen’s Egg Test for MicroNucleus
HPG
Hypothalamus-Pituitary-Gonad
HPLC
High-Performance Liquid Chromatography
HPLC-PDA
High-Performance Liquid Chromatography/Photo-Diode
Array detection
HPRT
Hypoxanthine-guanine PhosphoRibosyl Transferase
HPT
Hypothalamus-Pituitary-Thyroid
HSDB
Hazardous Substances Data Bank
HT25
Human dose descriptor, derived from T25 and based on
comparative metabolic rates (Sanner et al., 2001)
IARC
International Agency for Research on Cancer
_____________________________________________________________________________________________
184
IATA
Integrated Approaches to Testing and Assessment
ICCR
International Cooperation on Cosmetics Regulation
ICE
Isolated Chicken Eye
ICH
International Conference on Harmonisation
ICRP
International Commission on Radiologic Protection
In silico methods
Computational approaches that use (quantitative) structure-
activity relationship modelling, and read-across between
substances on the basis of structural or functional similarities
(ICCR, 2014).
In vitro test method
Biological method: using organs, tissue sections and
tissue cultures, isolated cells and their cultures, cell lines
and subcellular fractions
Non-biological method: such as computer modelling,
chemical interaction studies, receptor binding studies etc.
(based on Rogiers et al., 2000)
In vivo test method
Test method using living (experimental) animals
[Rogiers et al., 2000]
IL-1α
InterLeukin-1α
INCI
International Nomenclature of
Cosmetic Ingredients
INN
International Non-proprietary Name
IPCS
International Programme on Chemical Safety
IR
Infra Red
IRE
Isolated Rabbit Eye
ISSMIC
In vivo MICronucleus database
ISSSTY
In vitro mutagenesis in
Salmonella TYphimurium
ISO
International Organization for Standardisation
iTTC
internal Treshold of Toxicological Concern
IUPAC
International Union of Pure and Applied Chemistry
IWGT
International Workshop on Genotoxicity Testing
JRC
Joint Research Centre
kDPRA
kinetic Direct Peptide Reactivity Assay
KE
Key Event
kNN
k-Nearest Neighbour (algorithm)
LAGDA
Larval Amphibian Growth and Development Assay
LC
50
Median Lethal Concentration 50%: a time dependent,
statistically derived estimate of a test article concentration
that can be expected to cause death during exposure or
within a fixed time after exposure in 50% of animals
exposed for a specified time {expressed as mass of test
article per unit volume of air (mg/L, mg/m
3
) or as a unit
volume of test article per unit volume of air (ppm, ppb)}
(OECD 2009b).
LC-MS
Liquid ChromatographyMass Spectrometry
LCR
Lifetime Cancer Risk
LD50
Median Lethal Dose 50%: a statistically derived single
dose of a substance that can be expected to cause death
in 50% of the dosed animals (expressed in mg/kg body
weight) (EC B.1 bis)
LED
Lowest Effective Dose, e.g. LED10
LLBO
Laser Light-Based Opacitometer
LLNA
Local Lymph Node Assay
LO(A)EL
The Lowest Observed (Adverse) Effect Level is the
outcome of repeat-dose long-term toxicity studies, such
as 28-day or 90-day tests with rats, mice, rabbits or dogs,
_____________________________________________________________________________________________
185
chronic toxicity tests, carcinogenicity tests, teratogenicity
tests, reproduction toxicity tests, etc. It is the lowest dose
where (adverse) effects can be observed. In the
calculation of the MoS, the lowest obtained LOAEL value
may be used when a NOAEL is not available. The LOAEL
should be expressed as mg/kg bw/d. (ECB, 2003)
LoD
Level of Detection
LoQ
Level of Quantification
MDCK
Madin-Darby Canine Kidney cells
MDR
Multi Resistance Protein
MEC
Molecular Extinction Coefficient
MEGA
Multi-Endpoint Genotoxicity Assay
MIE
Molecular Initiating Event
MLA
Mouse Lymphoma Assay
MM
MicroMass
MMAD
Mass Median Aerodynamic Diameter
MN
MicroNucleus
MoA
Mode of Action
MoE
Margin of Exposure
MoS
Margin of Safety
MR
Mitotic Recombination
mROS
micellar Reactive Oxygen Species
MRP
Multidrug Resistance-associated Protein
MS
Mass Spectrometry
MTT
3-(4,5)-diMethyl-2-Thiazolyl-2,5-dimethyl-2H-
Tetrazolium bromide
MW
Molecular Weight
N
Data points
NAM
New Approach Methodology
Nanomaterial
An insoluble or bio-persistent an intentionally
manufactured material with one or more external
dimensions, or an internal structure, on the scale from 1
to 100 nm. (2009/1223/EC). Deviating definitions in other
regulatory fields may also exist.
NAT1
N-AcetylTransferase 1
NESIL
No Expected Sensitising Induction Level
NGC
Non-Genotoxic Carcinogen
NGRA
Next Generation Risk Assessment
NIH
US National Institute of Health
NIOSH
National Institute for Occupational Safety and Health
NLM
US National Library of Medicine
NLP
No Longer Polymer
No Longer Polymer
NMR
Nuclear Magnetic Resonance
NOAEC
No Observable Adverse Effect Concentration
NO(A)EL,
NO(A)EL
sys
The No Observed (Adverse) Effect Level is the outcome of
repeated dose toxicity studies, such as 28-day or 90-day
tests with rats, mice, rabbits or dogs, chronic toxicity
tests, carcinogenicity tests, teratogenicity tests,
reproduction toxicity tests, etc. It is the highest dose for
which no (adverse) effects can be observed (based on EC
B.26). The NOAEL should be expressed as mg/kg bw/d.
In the calculation of the MoS, the lowest obtained NOAEL
value is used, in order to take into account the most
sensitive species, as well as the relevant effect occurring
at the lowest dose possible. Whereas the NOAEL is a dose
_____________________________________________________________________________________________
186
descriptor for an external dose, the NOAEL
sys
is a dose
descriptor of the systemic exposure to a substance and is
calculated from the NOAEL by use of the proportion of the
substance systemically absorbed
NoG
Notes of Guidance
NR
Neutral Red
NRU
Neutral Red Uptake
NTP
National Toxicology Program
NURSA
NUclear Receptor Signaling Atlas
OCHEM
Online CHemical Modeling Environment
OD
Optical Density
OI
Ocular Irritection
OECD
Organisation for Economic Co-operation and
Development
OPPTS
Office of Prevention, Pesticides and Toxic Substances
P
50
, P
90
50
th
, 90
th
Percentile
PACEM
Probabilistic Aggregate Exposure
PBMDC
Peripheral Blood Monocyte Derived Dendritic Cells
PBPK
Physiologically Based PharmacoKinetics
PBPK modelling
Physiologically Based PharmacoKinetic modelling
PBTK
Physiologically Based ToxicoKinetics
PBTK modelling
Physiologically Based ToxicoKinetic modelling
PDA
Photometric Diode Assay
Personal care products
Consumer products used: for beautification (make up
products) and in personal hygiene (shower gel, skin
cream, shampoo, feminine hygiene products, diapers,
toilet paper etc.)
PhEUR
European Pharmacopoeia
PHMB
PolyHexaMethylene Biguanide
PIF
Product Information File
PMS
Post-Marketing Surveillance
PoD
Point of Departure
Pow
n-octanol/water Partition coefficient
PPD
P-PhenyleneDiamine
PPAR
Peroxisome Proliferator-Activated Receptor
ppm
parts per million (e.g. mg/kg)
PPRA
Peroxidase Peptide Reactivity Assay
Prototype
A first model or design that has not been produced in
batches, and from which the finished cosmetic product is
copied or finally developed.
(2009/1223/EC)
PXR
Pregnane X Receptor
QMRF
QSAR Model Reporting Format
QRA
Quantitative Risk Assessment
QSAR
Quantitative Structure Activity Relationship
RA
Risk Assessment
REACH
Registration, Evaluation, Authorisation and restriction of
CHemicals
Reference material
Material sufficiently homogeneous and stable with respect
to one or more specified properties, which has been
established to be fit for its intended use in a measurement
process (ISO, 2008).
RhCE
Reconstructed human Cornea-like Epithelium test
RhE
Reconstructed human Epidermis
RhT
Reconstructed human Tissue
_____________________________________________________________________________________________
187
RIVM
RijksInstituut voor Volksgezondheid en Milieu
rLLNA
reduced Local Lymph Node Assay
ROS
Reactive Oxygen Species
RP
Responsible Person
RSMN
Reconstructed Skin MicroNucleus assay
RTEC
Registry of Toxic Effects of Chemical substances
SAF
Sensitisation Assessment Factors
SAR
Structure Activity Relationship
SAS
Synthetic Amorphous Silica
SC
Stratum Corneum
SCC
Scientific Committee on Cosmetology
SCCNFP
Scientific Committee on Cosmetic products and Non-Food
Products intended for consumers
SCCP
Scientific Committee on Consumer Products
SCCS
Scientific Committee on Consumer Safety
SCENIHR
Scientific Committee on Emerging and Newly Identified
Health Risks
SCHEER
Scientific Committee on Health, Environmental and
Emerging Risks
SCs
Scientific Committees
SD
Standard Deviation of the mean
SED
Systemic Exposure Dose
SHE
Syrian Hamster Embryo
SI
Stimulation Index
SIT
Skin Irritation Test
Spray, sprayable
cosmetic product
A formulation is either dispensed by the use of propellant
gas as defined in Directive 75/324 (propellant spray), or
by a spray bottle with a pump dispenser that forces a
liquid through a nozzle generating a spray stream or a
mist of a liquid (pump spray) (SCCS/1539/14).
SSA
Skin Surface Area
STE
Short Time Exposure
S
Steroidogenic
S
9
Fraction (supernatant) containing cytosol and microsomes
of cells after centrifugation at 9000g
Substance
A chemical element and its compounds in the natural state
or obtained by any manufacturing process, including any
additive necessary to preserve its stability and any
impurity deriving from the process used but excluding any
solvent which may be separated without affecting the
stability of the substance or changing its composition
(2009/1223/EC)
SVHC
Substance of Very High Concern
SUE
A Serious Undesirable Effect is an undesirable effect which
results in temporary or permanent functional incapacity,
disability, hospitalization, congenital anomalies or an
immediate vital risk or death (2009/1223/EC)
SPF
Sun Protection Factor
T25
Animal dose descriptor; chronic dose rate that will give
25% of the animal's tumours at a specific tissue site after
correction for spontaneous incidence (Dybing et al., 1997)
T
Thyroid
TER
Transcutaneous Electrical Resistance
TEER
TransEpithelial Electrical Resistance
TEST
Toxicity Estimation Software Tool
_____________________________________________________________________________________________
188
TG
Test Guideline
TGR
TransGenic Rodent
TIF
Technical Information File
TopKat
Toxicity prediction by Komputer Assisted technology
Toxicodynamics
Cover the process of interaction of chemical substances
with target sites and the subsequent reactions leading to
adverse effects (ECB, 2003)
Toxicokinetics
Describe the time-dependent fate of a substance within the
body and include absorption, distribution, biotransformation
and/or excretion (ADME) (ECB, 2003)
TOXNET
TOXicology data NETwork
TPO
TrimethylbenzoyldiPhenylphosphine Oxide (SCCS/1528/14)
TSE
Transmissible Spongiform
Encephalopathy
TTC
Threshold of Toxicological Concern
UDS
Unscheduled DNA Synthesis
UF
Uncertainty Factor
UGT
Uridine diphosphate GlucuronosylTransferase
Undesirable effect
An adverse reaction for human health attributable to the
normal or reasonably foreseeable use of a cosmetic
Product (2009/1223/EC)
UN GHS
United Nations Globally Harmonised System of
Classification and Labelling of Chemicals
U SENS
Myeloid U937 Skin Sensitisation Test
USA
United States of America
USP
USA Pharmacopoeia
UV
UltraViolet (wavelengths UV-A:315-400 nm, UV-B: 280-
315 nm, UV-C: 100-280 nm) (EC B.41)
Valid method
A technique that has not necessarily gone through the
complete validation process, but for which sufficient
scientific data exist demonstrating its relevance and
reliability (Rogiers, 2003)
Validated method
A method for which the relevance and reliability are
established for a particular purpose (in most cases
according to the criteria established by EURL-ECVAM,
taking into account that a prediction model needs to be
present from the start of the validation procedure). (based
on Balls et al., 1997 and Worth et al., 2001) These
methods are taken up in Regulation (EC) No 440/2008
and/or published as OECD Technical Guidelines
*
VIS
VISible light (wavelength 400-800 nm)
WEC
Whole Embryo Culture
WHO
World Health Organisation
WoE
Weight of Evidence
XETA
Xenopus Eleutheroembryo Thyroid Assay
XME
Xenobiotic substances Metabolising Enzyme
Xprt
Xantine-guanine phosphoribosyl transferase gene
yH
2
AX
Phosporylated for of H
2
AX histone