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A survey and health assessment of cosmetic products for children

4 Survey

• 4.1 Survey of cosmetic products for children
  • 4.1.1 Purchase of cosmetic products for children in retail shops
  • 4.1.2 Purchase of cosmetic products for children via the Internet
  • 4.1.3 Which types of products were bought?
• 4.2 Database of cosmetic products for children
  • 4.2.1 Chemical substances contained in the products
  • 4.2.2 Bar code
  • 4.2.3 Batch number
  • 4.2.4 Specifications of packaging
  • 4.2.5 Description of plastic type of the packaging
  • 4.2.6 CE labelling
  • 4.2.7 Marketing of the products – directly towards children?
  • 4.2.8 Possible comments
• 4.3 Results of the survey
  • 4.3.1 Product name
  • 4.3.2 Importers/producers
  • 4.3.3 How are the products procured?
  • 4.3.4 Product type
  • 4.3.5 Marketing of the products – directly towards children
  • 4.3.6 Chemical substances contained in the products
  • 4.3.7 Constituents with hazard classification
  • 4.3.8 Constituents in the guiding list for self-classification of the Danish Environmental Protection Agency
  • 4.3.9 Constituents with restrictions in relation to the statutory order
  • 4.3.10 Specification of number of constituents
  • 4.3.11 Content of perfume
  • 4.3.12 Content of preservatives
  • 4.3.13 No content of triclosan
  • 4.3.14 Content of colouring agents
  • 4.3.15 Design of packaging and CE labelling
  • 4.3.16 Plastic type of the packaging
  • 4.3.17 Bar code
  • 4.3.18 Batch number

One of the purposes of this project was to map the chemical substances which can be found in cosmetic products for children on the Danish market. First and foremost, such a survey takes place by surveying the cosmetic products that are sold in Denmark. The starting point of the project was to collect in total 200 cosmetic products for children as it was expected that such a number would cover a considerable part of the cosmetic products for children on the Danish market. (Quantity considerations are not included in the evaluation of the market coverage).

In the project a database of the mapped cosmetic products for children was developed for the Danish Environmental Protection Agency. Below is described how information about the products was procured and how the database of the products is built-up and which information is entered. Finally, the results of the survey and various extractions from the database are presented.

4.1 Survey of cosmetic products for children

The survey of cosmetic products for children in Denmark has taken place by use of the following sources:

• Association of Danish Cosmetics, Toiletries, Soap and Detergent Industries (SPT).
• Searches on the Internet
• Systematic purchase of cosmetic products for children in retail shops and via purchase on the Internet.

No complete survey of all cosmetic products for children being marketed in Denmark has taken place but a database with the 208 cosmetic products for children identified in the project has been developed.

Information about the content of chemical substances in the cosmetic products for children is procured in two different ways, either by purchasing the products or by asking for products or declarations of contents directly from the importers/producers. The survey of the products is carried out during a period of approximately 2 months (mainly from mid-April to mid-June 2006 and that is the reason why most of the products have been bought, as this was far the fastest way to get the products.

However, the declaration of contents for a few products has been available via the Internet and in these cases the information has thus been used.

According to SPT only a few of the Danish producers/importers market cosmetic products for children directly. One of these has sent the declarations of contents of their products electronically.

Products from both the retail shops and via the Internet have been bought so that the survey of the cosmetic products for children could cover as many products as possible. A few products can only be ordered by mail order or via the Internet and these products have also been bought. A few products are found at hairdressers. However, emphasis has been on products in the retail shops as it is estimated to be the most important way of shopping.

The survey is undertaken by buying products in the retail shops and at hairdressers at first. Then a search on the Internet after products not found in the retail shops has been completed. The few products bought via the Internet are thus primarily products which are not easily found in the retail shops. Conversely, many of the products in the retail shops can be bought via the Internet.

We evaluate that we have got hold of a significant part of the cosmetic products for children on the Danish market. However, the survey has shown that bath products designed as different figures – for instance Minnie Mouse, Barbie, Star Wars etc. – primarily are a product type being sold up to Christmas. When survey and thus the purchases in the project took place during the months April, May and June it has not been possible to procure all products of this type. It has primarily been the leftovers from the Christmas trade which we have bought. In the light of this we estimate that we have got hold of about 85-95 % of the products on the Danish market.

One of the big importers of bath products for children which are designed as different figures has informed that they re-sell these products to shops in connection with the Christmas trade. One of the big foreign producers of this product type has been contacted as we hoped to receive declarations of contents of their products electronically – but with no result.

Furthermore, the project has shown that the products on the market are frequently replaced; this means that new products are frequently launched on the market with new appearance and form. It was especially seen when a few products being chosen for analysis were impossible to find again. On the other hand a few quite new products had entered the market. However, this case occurs especially for bath products designed as different animals or things.

4.1.1 Purchase of cosmetic products for children in retail shops

As described, purchase of products in the retail shops has been the primary way of finding the products. Search for cosmetic products for children has taken place in different types of shops (convenience stores, toy stores, children’s clothes stores, bookstores, various “10 kroner” stores and hairdressers) – mainly in the area of Copenhagen and Northern part of Zealand. Table 4.1 is an overview of the shops where cosmetic products for children are found as well as where we have looked for cosmetic products for children without any result. No found cosmetic products for children in for instance Kvickly, Super Brugsen or Fakta mean that they only had products on the shelves which already were found elsewhere.

Table 4.1: Shops where we have bought and looked for cosmetic products for children

4.1.2 Purchase of cosmetic products for children via the Internet

After purchase of products in the retail shops a search for cosmetic products for children via the Internet has been conducted. Products not already bought were ordered via the Internet. Products were bought on the following home pages:

• www.babynature.dk
• www.duft-natur.dk
• www.jydsklasercenter.dk
• www.konceptkids.dk
• www.kropsprodukter.dk
• www.lavera.dk
• www.nuno.dk
• www.onlinekids.dk
• www.oriflame.dk
• www.satika.dk

4.1.3 Which types of products were bought?

As described in chapter 2 ”Definition of cosmetic products for children”, cosmetic products for children in this project are defined as products aiming at children in the age 3-14 years and they are products directly addressed to children (i.e. they are labelled with “Kids”, “Children’s” or “Junior”) or they are products which in their appearance are directed at children (i.e. they have either a special appearance or a special look appealing to children).

Most of the products are directly marketed to children either via the name or the appearance. But with regard to a number of products it can be discussed whether they are products directly intended for children. However, these products are included in the survey because they appeal to children due to their appearance and because in some cases they have even been found on the same shelf as other cosmetic products for children.

Among others, a number of products in the product category “Bath confetti/bath caviar/fizzle salt” are bought. This category covers product types like bath confetti, bath caviar and bath salt. These three product types are products to be used in the bath tub. The products are put into the bath water and will slowly be dissolved. Typically, they have both a soap function and a scent function and generally this product type is designed as colourful flowers, petals, hearts or similar. These products might primarily appeal to the female gender and they appeal to both women and girls. The products have been included in the survey as we ourselves have seen that they also appeal to girls below 15 years in a buying situation and as a few of this type of products are also found on the same shelf as other products for children.

Furthermore, a number of hair dyes (rinsing colours) has been bought. According to the shop assistant the hair dye series is addressed towards young girls as the products are rinsing colours which are washed out after a couple of hair washes so the girls can make experiments with the hair dyeing. On the packaging drawings of young girls with bare stomachs can be seen. Even if the hair dyes might also appeal to an older audience it is estimated that also girls below 15 years will buy these.

One cosmetics series is bought as there are drawings of Snoopy and strong colours – green or pink – on the packaging. It can be discussed whether a picture of Snoopy only appeals to adults and young persons or whether it also appeals to children (teenagers). Fact is that the cosmetics series was exhibited in the shop together with decorative cosmetics and hair slides etc. which also appeal to older children and the youngest teenagers.

Similarly, a skin care series is bought as these products are for teenagers according to the shop assistant. Thus the products also appeal to somewhat older persons than the target group of this project but also to the older part of the target group of this project.

Finally, a cosmetic series is bought despite that neither name nor design necessarily is directed towards children but because it is sold in a shop exclusively selling toys, children’s clothes and baby articles.

4.2 Database of cosmetic products for children

For the Danish Environmental Protection Agency a database in Microsoft Access 2000 is developed with in total 208 mapped cosmetic products for children. The purpose of the database of the cosmetic products for children is to create an overview of the products and their content of chemical substances in a relatively simple way. Furthermore it is possible in the database to sort the information and to extract information of the entered data criss-cross.

The database is built around a product overview where the following is recorded for each product:

-          Content of chemical substances

-          Various information about the product (type, place of purchase etc.)

Appendix A (chapter 1) is an overview of the content in the database.

In Table 4.2 is stated the information which is recorded in the database for all of the mapped cosmetic products for children.

Table 4.2: information about the cosmetic products recorded in the database

In the following a more detailed description with information about the registrations in the database of each of the above points is presented.

4.2.1 Chemical substances contained in the products

According to the Cosmetics Statutory Order (Stat. Ord. 422, 2006) the chemical substances that form a part of the cosmetic products for children have to be stated on the container with their INCI name that is a common nomenclature for use in declarations of contents of cosmetic products in the EU. An INCI name can cover several different chemical units (INCI, 2006).

Furthermore, the constituents shall be stated in order after descending weight. However, constituents in a concentration of less than 1% may be mentioned in a random order after the constituents whose concentration is higher than 1%. Hair dyes can be mentioned in a random order after the other constituents and scented and aromatic compounds can simply be named “perfume” and “aroma” respectively. Since March 2005 26 fragrances have to be stated in the declaration of contents when the concentration is higher than 0.001% in products which are not to be cleansed and 0.01 in products which are to be cleansed.

For products which with exception of the colours being alike the different colouring agents being used for the series might be stated with “+/-“ or “may contain”. This is seen for some of the mapped products. In these cases all colouring agents for the products are noted in the database even if the product with a particular colour might only contain one of the stated colouring agents. This means of course that the number of constituents as stated in the database for some products is larger than the real number.

Despite these exceptions the order in which the constituents are mentioned on the container is an indication of the quantity of the different constituents in the product.

Therefore, for each product information is entered into the database about the constituents which form a part of the products but also in which order (ranking) the constituents are listed on the product. Thus the ranking is an indication of the relative concentration of the constituents in the products. A low number (high ranking) expresses that the substance is a main constituent in the products whereas a high number (low ranking) indicates that the substance is an additive, for instance a preservative.

It shall be noted that in general it is not examined whether the products in fact contain the chemical substances that are stated on the products. It is possible that there are mistakes on the labels compared with the actual content which we cannot and have not taken into account in this project. The declaration of contents and the actual content were expected to be identical as a general rule.

The latest English edition of the EU INCI list (24.2.2006) containing about 7,600 constituents applied in cosmetic products is entered as a table in the database. In the first place, it makes the keying in of the constituents in the database much easier as in this way it is possible to select the constituents from a list defined in advance. In the second place, it means that the risk of mistakes when keying in is reduced as it is only possible to key in constituents which already are in this INCI list. Finally, it also means that it is possible to control whether all constituents can be found in the INCI list.

During the keying in it turned out that several products contained constituents that are not in the latest INCI list (dated 24.2.2006). In these cases the constituents in question are added to the EU INCI list of the database with the remark that they are added. In total 38 substances are added to the INCI list of the database. There might be some reasons for the fact that a substance is not in the INCI list dated 24.2.2006:

• The substance is not in the latest updating of the INCI list, i.e. application for use of this INCI name is in preparation or under consideration or the EU INCI list has not been updated..
• It is not the INCI name that is stated on the products as required and it has not been possible to find or guess the “correct” INCI name.
• There are spelling mistakes in the declaration of the product where it has not been possible to conclude the “correct” INCI name that should be stated on the packing. (All assumptions about spelling mistakes are noted).

4.2.2 Bar code

For all products with a printed bar code, this bar code has been registered. To print a bar code (EAN No.) on a product is voluntary. The bar code is a tool for registration of goods in connection with stock control and sales. The bar code is stated both by a number (the EAN number) and the very bar code. The two first digits state in which country the product is registered but not necessarily where it is produced. 57 is the code for Denmark. The next five digits are a marketing number for producer, importer or retail trade. Hereafter five digits follow. These are the internal item number of the marketing person and the last one is a control digit. The price of the products is not stated in the EAN number and bar code (the Labelling Guide, 1997)

4.2.3 Batch number

According to the Cosmetics Statutory Order cosmetic products must be labelled with the number of the production series or a reference specification, i.e. a batch number so that date and place of production can be identified (Stat. Ord. 422, 2006). The batch number for all the mapped products is registered in the database.

4.2.4 Specifications of packaging

In the project the packagings of the cosmetic products are divided into the following four categories:

1.       Neutral

2.       Colourful, no special design

3.       Colourful, with pictures of figures, but no special design

4.       Colourful, designed as a special figure

The Danish Safety Technology Authority has given an indicative statement of which products from category 4 being under the legislation for toys in order to be able to compare with the products which ought to have a CE labelling.

4.2.5 Description of plastic type of the packaging

For most of the products of plastic it is stated on the packaging which type of plastic the packaging is made of. This plastic type is stated in the database. The following parameters are used:

• 01 - PET
• 02 - HDPE
• 03 - PVC
• 04 - LDPE
• 05 - PP
• 06 - PS
• 07 - Others
• Not stated
• Not relevant

The parameter ”Not relevant” is used for products which for example is made of glass or metal. The parameter “Not stated” means that the packaging is made of plastic but the type is not stated or it has not been possible to read the stated type of plastic.

4.2.6 CE labelling

Some of the cosmetic products for children are designed as various figures, for example Winnie the Pooh, Barbie, Minnie Mouse, a mobile phone or simply a kind of bobble bath designed for instance as a frog. According to the Toys Statutory Order (see section 3.2.1 ”Safety requirements to toys”) products clearly designed or intended for playing purposes for children below 14 years must be CE labelled (Stat. Ord. 1116, 2003).

It is the Danish Safety Technology Authority who is responsible for and assesses whether a product comes under the definition of toys and thus must be CE labelled. In the database it is stated whether the mapped products are CE labelled or not.

4.2.7 Marketing of the products – directly towards children?

This point is added to the database to give a varied description of how the cosmetic products are marketed towards children. The reason is that during the survey it turned out that there is a number of grey area products where it might be discussed whether they are products being directly marketed towards children or they just are products appealing to children due to for instance the design or appearance of the products.

As described in chapter 2 ”Definition of cosmetic products for children”, cosmetic products for children in this project are defined both as products which are directly marketed to children, i.e. as an example they are called “Children’s”, and products which via their design or appearance appeal to children. However, in some cases, the latter is a matter of opinion and therefore this assessment has been made for each product and this is noted in the database.

4.2.8 Possible comments

In the database there is space to note possible comments about the product in question. The noted comments are for instance the following:

• Information about possible spelling mistakes in the INCI names of the declaration of contents as well as a note with an assumption of the INCI names which should have been stated.
• Information about the constituents that could not be found in the present INCI list and therefore is added to the INCI list of the database.

4.3 Results of the survey

In the following the data material which can be extracted from the database of the 208 purchased cosmetic products for children is presented.

4.3.1 Product name

As mentioned, in total 208 cosmetic products for children were bought. These cover all the products of cosmetic products for children which we could find in the survey period from mid-April 2006 to mid-June 2006. Intentionally, all product names are kept out of the report but the information is available at the Danish Environmental Protection Agency.

4.3.2 Importers/producers

The names of the importers and producers are intentionally taken away from the report but the information is available at the Danish Environmental Protection Agency.

4.3.3 How are the products procured?

Table 4.3 shows that the products are first and foremost procured via purchase. The major part of the products are bought (93%) – either via retail shops (81 %), hairdressers (1%) or the Internet (11%).

Table 4.3: Overview of the number of products in the survey

4.3.4 Product type

In Table 4.4 is stated the number of products of the different types which are bought and where they are bought (in shop, at hairdresser or via the Internet).

Table 4.4: Overview of the type of the cosmetic products for children

As it can be seen in Table 4.4 the database contains most products of the type body shampoo/bath gel, bath confetti/bath caviar/fizzle salt, shampoo and tooth paste but this illustrates quite well the reality as they are the most common products in the retail trade. The purchases have been incidental and therefore the database, also at this point, represents the Danish market of cosmetic products for children quite well.

The category ”Others” covers some undefinable product types such as Body Splash (body spray), preventive head lice shampoo or various cleansing products for the skin (primarily for the older children – teenagers). If we have not been able clearly to categorize the product under the other product types, “Others” is used.

4.3.5 Marketing of the products – directly towards children

As earlier described the majority of the mapped products is marketed directly towards children, i.e. they are for instance called something with “Kids” or “Children”, are designed as particular (cartoon) figures, have drawings of particular (cartoon) figures on the packaging, are on an Internet page under “Children’s products” or are sold in shops/Internet shops which exclusively sell things for children. This is the case for 146 of the 208 products in total.

The other 61 products consist of the products in the category “Bath confetti/caviar/fizzle salt” and other products which quite as much appeal to the somewhat older public (older children or adult women). The products are included in the survey because the products also appeal to especially the somewhat older girls because the shop assistant described for a part of the products that the products also were sold to the target group of this project and because some of the products also are found on the shelf together with other cosmetic products for children.

4.3.6 Chemical substances contained in the products

Appendix A contains a number of extractions from the database regarding the chemical substances being identified in the 208 mapped cosmetic products for children:

• Appendix A – chapter 2 is a list of all chemical substances being found in the mapped products. At first the list is stated after descending frequency and thereafter the same list is stated in alphabetical order.
• Appendix A – chapter 3 is a list of all chemical substances being identified for the individual types of products. The lists are only stated after descending frequency and there is only stated a list of the constituents for the most frequent types of producs, i.e.:

-          Bath confetti/caviar/fizzle salt

-          Balsam

-          Bodylotion/cream

-          Body shampoo/bath gel

-          Shampoo

-          Bobble bath

-          Tooth paste

In total 461 different substances are found in the 208 cosmetic products for children which are recorded in the database. Furthermore, Appendix A (chapter 2) shows how often the different chemical substances are found and which average ranking they have. The ranking is an indication of the relative concentration of the constituents in the products. A low number (high ranking) expresses that the substance is the main constituent in the product whereas a high number (low ranking) indicates that the substance is an additive, for instance preservatives.

Appendix A (chapter 3) shows the chemical substances in the cosmetic products for children divided on the type of product. I.e. which substances are found in shampoo, tooth paste, hair styling products, perfume etc. At the same time Appendix A (chapter 3) shows which average ranking the substances form a part of for the mentioned product type, i.e. which average relative concentration the substances form a part of.

Table 4.5 below shows the 50 most abundant chemical substances in the mapped products. At the same time the table shows how many of the 208 products the substances form a part of as well as with which average ranking.

Table 4.5: the 50 most abundant constituents in the cosmetic products for children.

Click here to see the Table

As it is seen from the table water and perfume are the two constituents which are most frequently used in the cosmetic products for children. Of the 26 fragrances mandatory to declare (see a detailed description in section 4.3.11 ”Content of perfume”) 13 of these are on the list of the 50 most frequently used substances in cosmetic products for children.

Of other frequently used constituents in the cosmetic products for children parabens (preservatives) can be mentioned. Listed below after declining frequency:

• Methylparaben (in 79 products)
• Propylparaben (in 70 products)
• Butylparaben (in 48 products)
• Ethylparaben (in 46 products)
• Isobutylparaben (in 39 products)

4.3.7 Constituents with hazard classification

Out of the 461 different chemical substances which form a part of the 208 cosmetic products for children 19 of these are classified as hazardous in pure form according to the List of dangerous substances (Stat. Ord. 923, 2005). In practice, this is checked via a data run where CAS numbers as stated on the INCI list are compared with CAS numbers from the List of dangerous substances. The result is seen below.

Table 4.6: Constituents in the cosmetic products for children which in pure form are classified as hazardous.

1              The function of Limonene is a solvent and aroma/fragrance

2             The function of Citral is also aroma/fragrance

3             Sodium fluoride strengthens against caries
4             Propelling gases as butane and isobutene are prohibited to use as propelling gas with Carc1 classification

4.3.8 Constituents in the guiding list for self-classification of the Danish Environmental Protection Agency

Of the in total 461 different chemical substances which form a part of the 208 cosmetic products for children, 38 of them are in the guiding list for self-classification of dangerous substances of the Danish Environmental Protection Agency (Environmental Project 635, 2001). The list is prepared as an offer to importers/producers on classification of chemical substances where no other reliable data are available. The list is prepared on basis of QSAR models. The result is seen below.

In practice, a database run is made where CAS numbers as stated in the INCI list are compared to CAS numbers from the guiding list for self-classification of dangerous substances of the Danish Environmental Protection Agency. The result is seen below.

Table 4.7: Constituents in cosmetic products for children which in pure form are in the guiding list for self-classification of dangerous substances of the Danish Environmental Protection Agency

Click here to see the Table

4.3.9 Constituents with restrictions in relation to the statutory order

A search after which constituents being required restrictions in relation to the Cosmetics Statutory Order is made. The search has been conducted via the used EU INCI list of the identified constituents in the mapped products. 66 of the 461 constituents being found in the 208 mapped products have a restriction in relation to the Cosmetics Statutory Order. In Appendix A (chapter 4) is a list of the 66 constituents with the stated restrictions.

In the table below is shortly described what the individual restriction of the constituents means. Please note that the latest edition of the INCI list from the project start (from 24 February 2006) has been used. This means that among other things the latest changes with colouring agents and partly also the 26 fragrances are not in the INCI list in the database.

Table 4.8: Overview of the restrictions with which selected constituents in the products are marked in the Cosmetics Statutory Order.

Please note that one of the substances (benzyl alcohol) has both a III/1,x restriction and a VI/1,x restriction and therefore the sum here is 67 constituents.

It is primarily for colouring agents and preservatives where restrictions in relation to the Cosmetics Statutory Order are found. The restrictions are stated as maximum allowed concentrations and possible limitations, such as “only to be used in products to be washed off”.

Please note that the 26 fragrances to be declared separately also have restriction via appendix 3 section 1 (III/1) but not all of these fragrances appeared from the used INCI list and, if above a certain content, the latest restriction on separated declaration has not been stated in the used INCI list. Only benzyl alcohol is mentioned with restriction but benzyl alcohol is also a preservative. Therefore, fragrances are not a part of the above in general.

4.3.10 Specification of number of constituents

Based on the declaration of content on the products it is stated how many constituents each product contains. The number of constituents varies from 3 to 36 different chemical substances. In Figure 4.1 a distribution of the number of constituents in the mapped products is seen. The products contain 16 constituents (16.2) on average.

For products being alike except for the colour the different colouring agents being used in the series can be marked with “+/-“ or “may contain” in the declaration of content. This is seen for some of the mapped products. In these cases, all colouring agents of the product are noted in the database even if the product with a particular colour might only contain one of the stated colouring agents. This means that the number of constituents as stated in the database for certain products is larger than the real number.

Figure 4.1: Distribution of the number of constituents in the mapped products.

4.3.11 Content of perfume

There is a declared content of perfume in 153 of the 208 products. This means that there is perfume in 74% of the mapped cosmetic products for children. The product type tooth paste (in total 19 products) has no products with a declared content of perfume and furthermore 11 products lack the declaration of content for some reason. If these products are left out there is a declared content of perfume in 86% of the mapped products.

Table 4.9: Overview of products with perfume divided on the type of the cosmetic products for children

Table 4.9 states how many of the products within the individual product type that contain perfume. As seen all deodorants, eau de toilette, hair dyes (rinsing colours), hairstyling products and massage oils (only one product) contain perfume whereas none of the tooth paste products has a declared content of perfume.

4.3.11.1 The 26 fragrances mandatory to declare

According to the Cosmetics Statutory Order (Stat. Ord. §25, 2006) all scented compounds are to be listed via the definition “perfume”, “perfum” or “aroma” only. According to appendix 3 of the statutory order, 26 fragrances must be stated in the declaration of content regardless of their function in the product when the concentration is higher than 0.001% in products which are not to be cleansed and 0.01% in products which are to be cleansed. This order with special definition of the fragrances mandatory to declare became effective in 2005 and applies for all cosmetics which are produced after 10 March 2005.

The 26 fragrances mandatory to declare can be seen in the table below. In the table is also stated which of these are found in the cosmetic products for children and the number of products. The most frequently applied fragrances are in the top of the table. The first 13 substances mandatory to declare are in the list of the 50 most frequently applied constituents in cosmetic products for children as stated in Table 4.5.

22 of the 26 fragrances mandatory to declare are found in the mapped products. The product group with the most frequent occurrence of these fragrances is “Bath confetti/caviar/fizzle salt”. It is seen that in general many of the scented products have not a content of the 26 fragrances. The reason may be that these fragrances are not used much or that the producers do not meet the regulation that these fragrances must be declared separately, but this is unknown. This will be considered when analyzing the products.

In total one or more of the 26 fragrances mandatory to declare are found in 71 different products corresponding to 34% of the mapped products.

Table 4.10: Occurrence of the 26 fragrances mandatory to declare in cosmetic products for children

With regard to tooth paste there is the special condition that 9 of the 19 mapped tooth pastes contain between 1 and 3 of the 26 fragrances that must be declared according to the Cosmetics Statutory Order even if “perfume” is not declared on the products.

From Table 4.11 it can be seen that the limonene is the fragrance which is in all 9 tooth pastes. The explanation for this is probably that limonene is a fragrance from citrus fruits and is added to give the tooth paste a special taste. Correspondingly, linalool comes from oranges and is probably added to give taste. Eugenol and cinnamal come from clove oil and cinnamon oil respectively and have probably been added with the same purpose.

Furthermore, one of the products contains benzyl alcohol which besides being a fragrance is a preservative too. It might be due to this function that the substance is added.

Table 4.11: Content of fragrances in tooth paste that must be declared

4.3.12 Content of preservatives

132 of the 208 products contain a preservative (where the function preservative is stated via the INCI list). In total, 23 different preservatives are found in the 208 mapped products. These are listed in the table below after frequency.

Table 4.12: Appliedd preservatives in cosmetic products for children

¹ According to Appendix 5 in the Cosmetics Statutory Order (Stat. Ord. 422, 2006).

² The mixture of methylisothiazolinone and methylchloroisothiazolinone is also called Kathon.

The allergenic preservative MG (methyldibromo glutaronitrile) being mentioned much during the last couple of years is not found in any of the mapped products.

4.3.12.1 Preservatives with application limitations

In general, there are concentration limitations on all the applied preservatives. Furthermore, two of the preservatives have application limitations.

5-bromo-5-nitro-1,3-dioxane must only be applied in products which are to be cleansed of after apply. This preservative is found in totally 15 products and all these products are body shampoo/bath gel or bobble bath; that means products being cleansed of after apply.

Iodopropynyl butylcarbamate must not be used for oral hygiene or for the lips and if the concentration is higher than a certain level for products not being cleansed of after apply it must be stated on the product that it contains iodine. Iodopropynyl butylcarbamate is only in one product which is a balsam; that means a product being cleansed of after apply.

4.3.13 No content of triclosan

None of the 208 mapped products contains triclosan.

4.3.14 Content of colouring agents

119 of the 208 products contain a colouring agent (where the function hair dyeing or cosmetic colorant is stated via the INCI list). In total 45 different colouring agents are found in the 208 mapped products. These are listed in the table below after frequency.

Table 4.13: Applied colouring agents in cosmetic products for children

The EU Commission bans 22 substances in hair dyes as per 1 December 2006^[3]. None of these 22 colouring agents is found in the mapped cosmetic products for children.

4.3.14.1 Colouring agents with application limitations

According to Appendix 4 in the Cosmetics Statutory Order (List of colouring agents allowed in cosmetic products), all the CI colouring agents in the list are permitted in all cosmetic products (application area 1). However, there are limitations on maximum permissible concentration in the end product for a number of the colouring agents.

According to Appendix 4 in the Cosmetics Statutory Order (List of colouring agents permitted in cosmetic products), CI 12085 must as a maximum occur in a concentration of 3% in the end product.

According to Appendix 4 in the Cosmetics Statutory Order (List of colouring agents permitted in cosmetic products), CI 45350 must as a maximum occur in a concentration of 6% in the end product.

According to Appendix 4 in the Cosmetics Statutory Order (List of colouring agents permitted in cosmetic products), CI 45380 must as a maximum occur in a concentration of 1% and 2% in fluorescein and monobromfluorescein respectively.

According to Appendix 4 in the Cosmetics Statutory Order (List of colouring agents permitted in cosmetic products), CI 45430 must as a maximum occur in a concentration of 1% and 3% in fluorescein and monobromfluorescein respectively.

According to Appendix 4 in the Cosmetics Statutory Order (List of colouring agents permitted in cosmetic products), CI 77289 must be free of chromate ion.

HC Blue No. 2 (CAS no. 33229-34-4) is in Appendix 3 section 2 in the Cosmetics Statutory Order which is a list of temporarily permitted substances in cosmetic products. It is permitted until 31 December 2007^[4] in a maximum concentration of 2.8% (w/w).

HC Orange No. 2 (CAS no. 85765-48-6) is also in Appendix 3 section 2 – List of temporarily permitted substances in cosmetic products. It is permitted until 31 December 2007^[5] in a maximum concentration of 1.0% (w/w).

Correspondingly, HC Violet No.  2 (CAS-nr. 104226-19-9) is in Appendix 3 section 2 – List of temporarily permitted substances in cosmetic products. It is permitted until 31 December 2007^[6] in a maximum concentration of 2.0% (w/w).

4-amino-3-nitrophenol (CAS no. 610-81-1) is in Appendix 3 section 2 – List of temporarily permitted substances in cosmetic products. It is permitted until 31 December 2007^[7] in a maximum concentration of 3.0% (w/w).

Finally, 3-nitro-p-hydroxyethylaminophenol (CAS no. 65235-31-6) is in Appendix 3 section 2 – List of temporarily permitted substances in cosmetic products. It is permitted until 31 December 2007^[8] in a maximum concentration of 6.0% (w/w).

4.3.15 Design of packaging and CE labelling

Some of the cosmetic products for children are designed as various figures, for instance Winnie the Pooh, Barbie, Minnie Mouse, a mobile phone and some small bobble bath products in soft plastic designed as animals and things. According to the Toys Statutory Order (see section 3.2.1 ”Safety requirements to toys”), products ”which clearly are designed or determined for play purposes for children below 14 years” must be CE labelled (Stat. Ord. 1116, 2003).

Table 4.14 states the distribution of the number of products on the stated packaging types.

Table 4.14: Distribution of the number of products on the stated packaging types

Thus, 27% of the mapped products are designed as a particular figure.

It is a matter of interpretation whether for instance a bobble bath product designed as a heart “clearly” is intended for playing purposes whereas it is more certain that a bobble bath product designed as for instance a cow or a Barbie figure will be seen as a toy from a child’s point of view.

Therefore, products from category 4 have been sent to the Danish Safety Technology Authority who is the competent authority in this area. The Danish Safety Technology Authority has given an indicative statement where 19 of the 56 products in category 4 are assessed to be comprised by the rules for toys.

4.3.16 Plastic type of the packaging

f the in total 208 products in the database 8 products are stated to be of PVC. The figures are three Barbie products, four Disney products and one shampoo with a preventive head lice shampoo. Of all products, 120 products have not stated the plastic type. They are primarily products like tooth paste and bobble bath products designed as various figures (for instance a frog, a cow). Common feature of the majority of these products is that the packaging is made of soft plastic.

4.3.17 Bar code

For all products with a printed bar code, this bar code has been registered. In total 175 of the 208 mapped products has a bar code. To print a bar code (EAN No.) on a product is voluntary. The two first digits state in which country the product is registered but not necessarily where it is produced. 57 is the code for Denmark (27 of the products are registered with the bar code starting with 57).

4.3.18 Batch number

According to the Cosmetics Statutory Order cosmetic products must be labelled with the number of the production series or a reference specification, i.e. a batch number so that date and place of production can be identified (Stat. Ord. 422, 2006). In total, 184 of the 208 mapped products have a batch number. For in total 14 of the mapped products the producer/importer has sent the declaration of content or we have found the declaration of content on the Internet and for these product which we have not had in our hand physically, the batch number is unknown and therefore it has not been entered into the database. The remaining 10 products have no information about declaration of content and other general information including batch number (for eight products), and for two products the batch number itself is missing.

Footnotes

^[3] Press release “Commission bans 22 hair dye substances to increase consumer safety”, 20.07.2006. IP/06/1047. Found on http://europa.eu.int.  http://europa.eu.int/rapid/pressReleasesAction.
do?reference=IP/06/1047&format=HTML&aged=0&
language=EN&guiLanguage=en

^[4] According to Statutory Order no. 877 of 17.8.2006 (Stat. Ord. 877, 2006) the date of the temporary permission of the substance is changed from 31.12.2006 to 31.12.2007.

^[5] According to Statutory Order no. 877 of 17.8.2006 (Stat. Ord. 877, 2006) the date of the temporary permission of the substance is changed from 31.12.2006 to 31.12.2007.

^[6] According to Statutory Order no. 877 of 17.8.2006 (Stat. Ord. 877, 2006) the date of the temporary permission of the substance is changed from 31.12.2006 to 31.12.2007.

^[7] According to Statutory Order no. 877 of 17.8.2006 (Stat. Ord. 877, 2006) the date of the temporary permission of the substance is changed from 31.12.2006 to 31.12.2007.

^[8] According to Statutory Order no. 877 of 17.8.2006 (Stat. Ord. 877, 2006) the date of the temporary permission of the substance is changed from 31.12.2006 to 31.12.2007.

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Version 1.0 October 2007, © Danish Environmental Protection Agency