September 19, 2019

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EC Requests Scientific Opinion on Three Coatings for Nano Forms of Zinc Oxide as a UV Filter in Dermally Applied Cosmetic Products

On August 19, 2019, the Scientific Committee on Consumer Safety (SCCS) posted a request from the European Commission (EC) for a scientific opinion on three coatings for nano zinc oxide as an ultraviolet (UV) filter in dermally applied cosmetic products — methicone, silica, and isostearic acid.  SCCS previously reviewed nano zinc oxide and the coatings triethoxycaprylylsilane, dimethicone, dimethoxydiphenylsilanetriethoxycaprylylsilane cross-polymer, and octyl triethoxy silane.  SCCS concluded that the use of nano zinc oxide as a UV filter in sunscreens, with the characteristics laid out in its opinion, and at a concentration of up to 25%, can be considered to “pose no or limited risk for use on the skin as UV filter in sunscreen formulations.”  Regarding the use of other coatings not covered in the opinion, SCCS concluded that “[o]ther cosmetic ingredients can be used as coatings as long as they are demonstrated to the SCCS to be safe and do not affect the particle properties related to behaviour and/or effects, compared to the nanomaterials covered in the current opinion.”

In its request, the EC asks whether:

  • SCCS considers safe the use of methicone with a maximum concentration of 3% as coating on nano zinc oxide for use as UV filter in dermally applied cosmetic products;
  • SCCS considers safe the use of methicone with a maximum concentration of 3% when applied in combination with 8% silica as coatings on nano zinc oxide for use as UV filter in dermally applied cosmetic products;
  • SCCS considers safe the use of isostearic acid with a maximum concentration of 4% when applied in combination with 2.0% triethoxycaprylylsilane as coatings on nano zinc oxide for use as UV filter in dermally applied cosmetic products; and
  • SCCS has any further scientific concerns regarding the use of nano zinc oxide coated with the above-mentioned materials when used as UV filter in dermally applied cosmetic products.

The deadline for SCCS’s opinion is March 2020.

©2019 Bergeson & Campbell, P.C.

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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Owner of Bergeson & Campbell, P.C. (B&C®), Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy...

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Carla Hutton, Bergeson Campbell PC, global regulatory attorney, public health activists lawyer, metals industry legal counsel, Toxic Substances Control Act law
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.

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