Hand gels – click here for the whole article

Now that we need to wash our hands more frequently to prevent further spread of the Corona virus, hand gels are more popular than ever.

We receive many questions about the labeling and positioning of these products. Can a hand gel be seen as a cosmetic product or does it fall under the biocide regulation? We have listed it for you below:

A hand gel “simply” intended for washing hands, normally based on mild soap, is a cosmetic product. For this product you must comply with the European Cosmetics Legislation (EU) 1223/2009: you will have to compile a PIF (Product Information File) and have it registered with the CPNP. The label must contain all information required for cosmetics.

As soon as a claim like “anti-bacterial” is stated, it becomes tricky.

An alcohol based hand gel is cosmetics ór biocide, dependent on the claims. Below we give you some examples:

  • The product is/remains cosmetics if the label states for example: “for hand cleaning, hygienic, fast drying (due to the high concentration of alcohol)”.
  • It is a “borderline product” (that sounds strange, but that’s what it is called), if the label does not state too prominently “antibacterial” in combination with explicit claims for hand cleaning. Hand cleaning is the primary claim, whereas antibacterial is the secondary effect. You might be  careful with your words, but the authorities can dispute this at any time. For example, if you claim something different on your website than on the packaging.
  • If you claim “antibacterial” loud and clear on, for example, the front of the hand gel, then this product is almost inevitably a biocide. This is because the secondary claim has changed to a primary claim.
  • If you put texts on the label like “kills 99% of the bacteria” or “disinfects”, the hand gel is always a biocide. The claim “disinfectant” implies that it kills bacteria, yeasts and fungi.

Latest actual info:

  • Anti-viral agents: although viruses are non-living organisms, anti-viral agents are biocides.
  • To increase the manufacture and supply of disinfectants on the European market, ECHA is supporting EU/EEA authorities to apply derogations from the normal authorisation requirement for biocidal products.