Hair Styling Products 

In the first month of 2021, three hair products were subject to a Rapex notification. Two violations were found in these three products. Two products involved a prohibited ingredient. Another product received a notification due to the appearance characteristics of the product.  

Prohibited ingredient 

A prohibited ingredient was found in two products. This was cyclotetrasiloxane. This ingredient was found twice at 4%. These are two different products. Since this is a prohibited ingredient, the products have been removed from the market.  

Cyclotetrasiloxane (D4) is listed in the cosmetics Annex II/1388. At SkinConsult, this comes up in the preliminary report, where the product is checked for MoS values and the different annexes. Checking the INCI formula and raw materials is therefore hugely important.  

Appearance characteristics of the product 

A product has received a Rapex notification by its characteristic appearance, colour and size. The product looks such that a child or vulnerable person may see it as a food product. While this possibility is small, foaming agents in the product can make it dangerous. These foaming agents can cause chemical pneumonia, which can be fatal in children and the elderly. The product’s label should therefore be updated with warnings about the risks. 

The artwork of the product is part of the safety assessment and therefore product safety. SkinConsult reviews and checks all the artwork, boxes and leaflets of cosmetics, so that these kinds of problems do not occur with your products! 


White kits for teeth have become increasingly popular in recent years. We also see this product type passing by more and more often. This product was imported and rejected at the border after inspection. 

Ingredient concentration too high 

This product was rejected at the border because it measured an excessively high concentration of sodium fluoride. In this case, the measured value was up to 2% by weight. Sodium fluoride can cause staining in teeth and also weaken teeth. It can also lead to skin irritation. As a result, the authorities decided that the product does not comply with the cosmetics regulation.  

This excessive concentration can be prevented by calculating a proper Margin of Safety. This shows that the current concentration was not safe and in accordance with the cosmetics regulation. When this is found, the safety assessor can recommend that the ingredient be reduced or replaced.   

Nail products 

An excessive concentration of N-nitrosodiethanolamine (NDELA) was measured in a nail product. The total value was 110 µg/kg. NDELA is a nitrosamine that can cause cancer through dermal exposure. This finding forced the Responsible Person to remove the product from the market.  

This kind of situation can be prevented in two ways. On the one hand by having a good product COA in which these kinds of ingredients are measured. On the other hand, the raw material documentation should show this. This is why SkinConsult attaches great importance to correct and complete raw material documentation, including impurities.  

Hand gels 

In addition to the cosmetics reports, there have also been Rapex reports on various hand gels. In the Rapex these products fall under the category ‘Chemical products’. This concerns the biocide legislation. 

One of the products contains methanol. This ingredient is toxic to the nervous system and eyes. Hazard pictograms are missing on the product in question. As a result, the end-user does not have the correct information. This also shows how important artwork is, for both a biocide and cosmetics. Given the risk and potential consequences, this product has been removed from the market.  

Another product had to be recalled from end-users. This product did not contain enough active chlorine, so the product has no disinfecting effect. Because of this, you can argue that the claim made is not sufficiently substantiated, so the product is removed from the market. This since the claim is a hygiene claim. 

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