Which nanoparticles in which cosmetic products?

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At the beginning of 2018, the French authorities(DGCCRF) had indicated that they had identified more than 11,000 product references and in 2021, the European Commission specified that on average, about 3620 new cosmetics containing nanomaterials were notified each year between 2016 and 2020. Every day, about ten new cosmetic products containing nanomaterials are placed on the market in the EU. Problem: the references in question, located via the “Cosmetic Products Notification Portal”(CPNP) of the European Commission, are not publicly available.

In fact, the precise identification of nanos in cosmetics is still very difficult for the consumer – thelabelling obligation, in force since 2013, is indeed little respected. Various initiatives have been put in place to identify cosmetics that contain nanos, but unfortunately they are too limited at this point.

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• toothpastes¹Sources:
  – Assessment of cosmetic products inspections at ANSM, ANSM, Perfumes & Cosmetics Congress, November 4, 2020: ANSM presented the results of tests it had conducted in 2019 on 12 toothpastes of different brands, complementing the analyses conducted by the DGCCRF on 5 other toothpastes
  – Are toothpastes hazardous to your health, The Daily, May 6, 2019
  – Investigation report on the presence of titanium dioxide in toothpastes, Act for the Environment, March 2019
  – Nanoparticles – Attention, elles se cachent partout, UFC-Que Choisir, Mensuel n° 566, February 2018: Aquafresh toothpaste (GlaxoSmithKline) contains titanium dioxide (TiO2), 40% of whose particles are smaller than 100 nmwhich often contain silica and/or nanoparticulate titanium dioxide
• sun creams with mineral filters²This is evidenced by:
  – analyses conducted by the DGCCRF (which unfortunately does not publish the references of the tested products)
  – tests conducted by Agir pour l’Environnement and WECF and available in the report Produits solaires pour enfants – Trop de substances préoccupantes, Wecf France and Agir pour l’Environnement, June 2020
  – the test of Lavera Sunscreen 100% mineral SPF 30 (organic) of Que Choisir which showed the presence of 100% nano titanium dioxide (but not labeled). Cf. Nanoparticles – Beware, they are hiding everywhere!UFC-Que Choisir, Monthly n° 566, February 2018nanoparticulate titanium dioxide or zinc oxide compounds
• make-up products³See in particular:
  – the analyses conducted by the DGCCRF (which unfortunately does not publish the references of the tested products)
  – the Bourjois 3D effect gloss test, Que Choisir, January 2018: the iron oxide (Fe₂O₃) it contained was 100% nano (but not labeled) These products are composed of dyes containing nanoparticles of titanium dioxide, iron oxides, carbon black, etc.

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Declarations in R-nano but no information on finished products (yet)

In 2017, some 20 “nanoparticulate substances” for cosmetic use had been the subject of 616 declarations in the r-nano register, where nano substances manufactured, imported or placed on the market in France must be declared each year⁴See list of ~20 grants on page 220 of the 2017 Balance Sheet. (These figures will be updated when the Official Report Card 2020 is published).

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However, as the registry currently stands, products containing these nano substances cannot be identified (hence the need for improvements to the declaration procedure).

A “catalog” of nanos in cosmetics in the European Union, to be improved

• A first version of the catalog of nanomaterials used in cosmetics marketed in the European Union was put online by the European Commission in mid-June 2017 (three and a half years after the date provided for by the Cosmetics Regulation⁵According to the Cosmetic Regulation, “by January 11, 2014, the Commission (should have made) available a catalog of all nanomaterials used in cosmetic products placed on the market, including those used as colorants, UV filters and preservatives, mentioned in a separate section, indicating the categories of cosmetic products and the reasonably foreseeable exposure conditions. This catalog shall be regularly updated thereafter and shall be made available to the public.”. In a letter dated September 3, 2015, Internal Market Commissioner Elzbieta Bienkowska had indicated that industry had provided inaccurate information and that the Commission had asked them to verify their notifications. It had also asked member states to monitor the market and contact operators by October 2015 to conduct verifications. “Once accurate and complete information is received, the Commission intends to publish the catalog.” In a February 18, 2016 article, Chemical Watch announced the publication of the catalog for mid-2016(Cosmetics nanomaterials inventory expected mid-2016, Chemical Watch, February 18, 2016). Questioned by the NGO Client Earth, the Commission had once again called for patience and promised that the catalog would be published “in the coming weeks” on the page https://ec.europa.eu/growth/sectors/cosmetics_en (see EU cosmetics nano inventory hits three-year delay, Chemical Watch, January 11, 2017 and Three-year wait for nanomaterial risk data promised ‘in the next few weeks’, Vito Buonsante, Client Earth, January 11, 2017), with many unauthorized nano substances (such as _TiO2 in toothpastes for example):

• The ^2nd version of the “catalog” was published by the European Commission in November 2019. It highlights once again the use of nanoparticles, some of which are not authorized.
  But curiously, the number of nanomaterials is clearly reduced compared to the first version of the catalog, especially concerning the dyes⁶For the rest, the number of nano UV filters has been reduced from 6 to 4, and the number of nano substances with other functions has been reduced from 25 to 22. : there were 12 listed in 2017, there were only 3 in 2019 : iron oxides for example have disappeared… while the DGCCRF has identified some in makeup products since 2019 !
  
  The “catalog” is not a catalogue in the sense that it does not actually give precise names of products or brands, it just provides a list of substances in the nano state and the (generic) categories of products in which they have been declared – without them necessarily being authorized… far from it! This is the case of _TiO2 nanoparticles used as a dye, for example.

• These catalogs are produced from the European Commission’s Cosmetic Products Notification Portal(CPNP).

An inventory of nano pigments

September 2018, more than 80 nano-sized pigments were identified on the European market by the European Chemicals Agency (ECHA). Many are likely to be present in cosmetic products, especially make-up products (lipsticks, mascaras, eyeliners, blushes, powders, etc.) or toothpastes.

Censuses conducted by associations (not updated)

• In 2019, the association Agir pour l’Environnement (APE) launched the website https://dentifrice-infoconso.agirpourlenvironnement.org, a database listing, initially, 271 toothpastes suspected of containing titanium dioxide nanoparticles. By the end of 2021, the number had dropped to 224, or nearly 50 fewer toothpastes. The database has not been updated since.

• Several other “guides” or “applications⁷“The Safe Sunscreen Guide summer 2010-2011 of Friends of the Earth Australia, December 2010 and the “Skin Deep Cosmetic Safety database⁸” created by the American NGO Environmental Working Group (EWG) for example propose to identify nanos in cosmetics or, conversely, “nano-free” cosmetics, but their reliability is limited, either because they are too dated or because they rely on the (sometimes misleading) declarations of manufacturers.

• The“Yuka” or“Which product?” (from Que Choisir) apps do not allow you to search for the presence or absence of nanos in products.

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Theobligation to label nanomaterials in cosmetics is applied by some brands… but not by all, far from it.

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The nanomaterials present in cosmetic products are mainly colorants, texture agents, antibacterial agents or UV filters.

According to a report published in 2021 by the Commission, the most notified nano substances in the European CPNP portal – and which account for more than 70% of all nanomaterial notifications – are:

• titanium dioxide
• silicas
• carbon black.

As an indication, here are the main nanomaterials identified as being used or likely to be present in cosmetics(although they are not necessarily authorized), with their supposed functions (non-exhaustive list):

For a given substance (e.g. “titanium dioxide”, “zinc oxide”, “iron oxide”, …), the proportion of nanometric particles, having a size at least under the 100 nm mark, can be very variable. The greater the proportion of “nano” particles, the greater the associated risks are likely to be (due to the greater mobility and reactivity of small particles)¹³On the risks associated with nanos in cosmetics, see in particular:
In French :
– Evaluating and anticipating the risks associated with nanoparticulate UV filters used in sunscreens: a life cycle oriented study, thesis by Riccardo Catalano, June 2020 (abstract in French, thesis in English)
– Titanium dioxide nanoparticles, their place in the cosmetic industry and its dangers, Laura Daragnes, Thesis for the obtention of the State Diploma of Doctor of Pharmacy, under the direction of Isabelle Bestel, University of Bordeaux, September 2018
– Les nanos dans les cosmétiques: bénéfice ou risque?”, in Faut-il avoir peur des nanos? Francelyne Marano, Buchet Chastel, April 2016
In English:
– Influence of _TiO2 nanocomposite UV filter surface chemistry and their interactions with organic UV filters on uptake and toxicity toward cultured fish gill cells, Martin N et al, Ecotoxicology and Environmental Safety, 243, 113984, September 2022
– Safety Assessment of Nanomaterials in Cosmetics: Focus on Dermal and Hair Dyes Products, Cosmetics, Coimbra SC et al, 9, 83, 2022
– Scientific advice on the safety of nanomaterials in cosmetics, Scientific Committee on Consumer Safety (SCCS), January 2021 (Corrigendum of 8 March 2021)
– Titanium Dioxide Nanoparticles in Food and Personal Care Products-What Do We Know about Their Safety, Joanna Musial et al, Nanomaterials, June 2020
– NanoTiO2 Sunscreen Does Not Prevent Systemic Oxidative Stress Caused by UV Radiation and a Minor Amount of NanoTiO2 is Absorbed in Humans, Pelclova D et al, Nanomaterials, 9(6), 888, 2019
And more info here.

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More and more brands are banking on “nano-free” to attract customers who do not want to buy cosmetics with nanoparticles. However, as of July 1, 2019, restrictions for “without…” claims in cosmetics came into effectCf.¹⁴“Without” claims in cosmetic products: clarifications from the control authorities, ANSM & DGCCRF, April 16, 2020. The terms “nanoparticle-free”, “nanomaterial-free”, “titanium dioxide-free” (among others) should no longer appear on cosmetics.

Apart from the regulatory requirement, experience shows that the total absence of nanoparticles is difficult to guarantee anyway. Some raw material suppliers do not indicate the nanometric dimension of the ingredients they sell to cosmetics manufacturers and others have even gone so far as to sell them as “non-nano” ingredients that are actually nano – ECOCERT learned this the hard way in 2012¹⁵ In August 2012, ECOCERT had to suspend its organic certification of the ingredient ZinClear of the brand Antaria Ltd: composed of zinc oxide, it was presented by the brand as “nano-free” while Friends of the Earth Australia had revealed that other documents of the company proved that it knew its nanometric composition (Cf. Antaria finally admits its sunscreen ingredient is a nanomaterial, Friends of the Earth Australia, 4 March 2013) before the brands tested in France since 2017 by the associations and the DGCCRF (see above).

Cosmetic brands should conduct frequent tests to monitor particle size in their raw materials and finished products – a challenge for smaller companies with fewer resources. One possible solution lies in the hands of the professional federations: the pooling of resources to carry out regular analyses of suppliers’ raw materials and to create “pools” of very well-characterized raw materials that are not harmful to health or the environment. A major challenge – literally and figuratively!