Information about chemicals in consumer products

For all non-food products, the EU “Safety Gate” rapid alert system provides information on dangerous products that have been identified by the national surveillance authorities and on which action has been taken.

Definition: According to the European Chemicals Regulation REACH a solid object (“article”) is an „object which during production is given a special shape, surface or design which determines ist function to a greater degree than does ist chemical composition“. REACH considers a welding rod, a candle or a glowstick to be mixtures. Ballpoint pens and printer/toner cartridges are "mixtures in a container", a wet wipe is a "mixture on a carrier material".

Relevant EU Legislation: When you use your REACH consumer right allows you to obtain information from the product supplier about "substances of very high concern" (SVHCs) in most articles of daily use, if their concentration exceeds 0.1 percent by weight (per substance). These articles include, for example, household items, textiles, shoes, sports goods, furniture, do-it-yourself products, toys, electrical appliances, cars, bicycles or packaging.

Exceptions are mixtures like liquid products, and paste-like or powdery products (e.g. paints and lacquers) or certain separately regulated products, such as cosmetics, detergents, medical devices, pharmaceuticals, food, and animal feed. Under REACH a mixture does not have a special shape, surface or design which determines its function to a greater degree than does its chemical composition.

Recommendations: Take advantage of your right to information under ⁠REACH⁠! A request to the supplier can be sent quickly and easily by using the smartphone app Scan4Chem or the Scan4Chem Web app. Show the suppliers that you don’t want to buy products containing SVHCs! Quality labels that mark green and user-friendly products can also aid purchasing decisions. We recommend looking for products with the Blue Angel eco-label. Become a regular reader of environmental and consumer magazines. They contain a lot of information on both safe and unsafe products and chemicals in addition to test reports. Visit the consumer portal of the German Environment Agency (German). You can do the environment a big favour by purchasing durable products or simply by reducing buying and consumption. Such action would result in fewer resources consumed, fewer chemicals entered into the environment and the food chain, and less waste incurred. Extend the lifetime of products, e.g. by mending them instead of buying new ones.

Definitions: A chemical substance means a chemical element (e.g. sodium) or a compound (e.g. sodium chloride) in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability, and any impurity deriving from the process used, but excluding any solvent used for the production of the substance. A mixture is composed of two or more substances.

In some cases, pure chemical substances are sold to consumers, e.g. citric acid as a limescale remover. Chemical mixtures supplied to consumers include washing powder, rust removers, or varnishes and paints.

Relevant EU Legislation: If such products display properties that lead to a classification as hazardous according to the Classification, Labelling and Packaging Regulation (CLP Regulation), they have to be labelled with pictograms, and information has to be provided about safe handling. You can find an explanation of the pictograms here.

In addition, Annex XVII of the European Chemicals Regulation (REACH Regulation) prohibits the placing on the market or use of certain chemical substances. For example, substances classified as cancerogenic, mutagenic or reprotoxic (CMR substances) as well as mixtures that contain such substances are usually prohibited for supply to the general public.

Recommendation: Study the packaging, instruction leaflet and all available information and directions for use before you buy or use chemical substances or mixtures. Avoid products with hazardous substances as far as possible.

Definition: A detergent is a substance or mixture containing soaps and/or other surfactants intended for washing and cleaning processes. Detergents may be in any form (liquid, powder, paste, bar, cake, moulded piece, shape, etc.) and marketed for or used in households, or for institutional or industrial purposes.

Relevant EU Legislation: Detergents have to be labelled according to the CLP Regulation (see 2) and the Detergents Regulation. According to the Detergents Regulation the following provisions on labelling apply to the packaging of detergents sold to the general public:

1. The following classes of constituents have to be listed irrespective of their concentration:

• enzymes,
• disinfectants,
• optical brighteners,
• perfumes,
• preservation agents.

2. If added at concentrations exceeding 0.01 % by weight, allergenic fragrances
(on the list in Annex III of the Cosmetics Regulation) have to be listed.

3. The following constituents have to be listed in weight percentage ranges where they are added at a concentration above 0.2% by weight:

• phosphates,
• phosphonates,
• anionic surfactants,
• cationic surfactants,
• amphoteric surfactants,
• non-ionic surfactants,
• oxygen-based bleaching agents,
• chlorine-based bleaching agents,
• EDTA (ethylenediaminetetraacetic acid, a complexing agent) and derived salts,
• NTA (nitrilotriacetic acid) and derived salts,
• phenols and halogenated phenols,
• paradichlorobenzene,
• aromatic hydrocarbons,
• aliphatic hydrocarbons,
• halogenated hydrocarbons,
• soap,
• zeolites,
• polycarboxylates.

For such constituents the range of the weight percentage has to be given:

• less than 5 %
• 5 % or more but less than 15 %
• 15 % or more but less than 30 %
• 30 % or more.

In addition, the manufacturers have to make available on a website all ingredients used in a detergent in order of decreasing abundance by weight. The website address has to be given on the packaging. Access to the website shall not be subject to any restriction or condition and the content of the website shall be kept up to date.

Recommendation: Information about eco-friendly washing and cleaning can be found here (in German) on the UBA website.

Definition: A ‘cosmetic product’ means any substance or mixture intended to be placed in contact with the external parts of the human body (skin, hair, nails, lips, or external genital organs) or with the teeth and the mucous membranes of the oral cavity (e.g. mouthwash) exclusively or mainly with a view to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition, or correcting body odours.

Relevant EU Legislation: According to the European Cosmetics Regulation cosmetic products made available on the EU market shall be safe for human health when used under normal or reasonably foreseeable conditions of use. Potential environmental impacts are not covered by the Cosmetics Regulation. They are considered under the European Chemicals Regulation REACH, but without any corresponding labelling requirements for cosmetics. Cosmetics are exempted from the CLP Regulation.

In Annex II of the Cosmetics Regulation more than 1600 substances are listed which may not be used in cosmetic products because of their potential effects on human health. Annex III contains more than 320 substances which are restricted in cosmetic products to a certain extent. In addition, colourants, preservatives and UV filters, including those that are nanomaterials, must be explicitly authorised by the European Commission prior to their use in cosmetics.

The use of substances classified as carcinogenic, mutagenic or reprotoxic (CMR substances) in cosmetics is allowed in exceptional cases after evaluation by the Scientific Committee on Consumer Safety (re-evaluation every five years). Specific labelling in order to avoid misuse of the cosmetic product has to be provided, taking into account possible risks linked to the presence of hazardous substances and the routes of exposure.

Cosmetic products can be made available on the market only where the packaging bears the list of ingredients. An ingredient is any substance or mixture intentionally used in the cosmetic product during the process of manufacturing. For practical reasons the list of ingredients may be mentioned on an enclosed or attached leaflet, label, tape, tag, or card, if it cannot be provided on the packaging. For very small products it is sufficient if this information appears on a notice in immediate proximity to the container in which the cosmetic product is displayed for sale. The ingredients are listed in descending order of their weight at the time they are added to the cosmetic product. Ingredients at concentrations of less than 1 % may be listed in any order after those contained at concentrations above 1 %.

• Perfume and aromatic compositions and their raw materials have to be referred to by the terms ‘parfum’ or ‘aroma’. Moreover, the presence of certain restricted substances (Annex III Cosmetics Regulation) has to be indicated in the list of ingredients in addition to the terms ‘parfum’ or ‘aroma’.
  
  
• All ingredients present in the form of nanomaterials are indicated in the list of ingredients as “(nano)”. For more information about nanomaterials in cosmetics visit the European Union Observatory for Nanomaterials (EUON).
  
  
• Colourants other than colourants intended to dye the hair may be listed in any order after the other cosmetic ingredients. For decorative cosmetic products marketed in several colour shades, all colourants other than colourants intended to dye the hair used in the range may be listed, provided that the words ‘may contain’ or the symbol ‘+/-’ are added.
  
  
• Impurities in the raw materials used do not have to be listed. The presence of a small quantity of a prohibited substance, stemming from impurities of natural or synthetic ingredients, the manufacturing process, storage, migration from packaging, which is technically unavoidable in good manufacturing practice, is permitted provided that the product is still safe when used under normal or reasonably foreseeable conditions and complies with the provisions of the Cosmetics Regulation.

The quantitative composition of the cosmetic product and, in the case of perfume and aromatic compositions, the name and code number of the composition, as well as existing data on undesirable effects and serious undesirable effects resulting from use of the cosmetic product have to be made accessible to the public on request. However, the quantitative information regarding the composition of the cosmetic product required to be made accessible is limited to substances classified as hazardous according to the CLP Regulation (see 2).

Recommendation: Avoid unnecessary cosmetics. Limit yourself to using few products and check their composition before you buy them. Certain smartphone apps can also help you with this, e.g. they indicate which ingredients have an effect on the hormone system or whether microplastics are contained in the product. In the app COSMILE companies themselves provide information about the ingredients of their cosmetic products. Nevertheless, especially in the case of known intolerances, attention should always be paid to the legally binding information on the products themselves. Please report serious and adverse effects of cosmetics either yourself (see German BVL flyer, “check list” or template) or through your doctor.

Definition: A biocidal product is any substance or mixture intended to destroy, deter, render harmless, prevent the action of, or otherwise exert a controlling effect on any harmful organism by means other than mere physical or mechanical action.

An article treated with biocidal products may also fall within this definition provided that a primary biocidal function can be attributed to the article. This is understood to mean an intended external biocidal function at the user. The biocidal active substance
is released from the article to the outside in order to control harmful organisms. A frequently mentioned example is a mosquito net treated with an insect repellent.

Biocidal products may be used as disinfectants (for humans, animals, materials, food, drinking water etc.), preservatives that prevent microbial and algal development (e.g. in surface coatings for wood or other materials), products used for pest control (e.g. of rodents, molluscs, or insects), antifouling products, or embalming and taxidermist fluids.

Relevant EU Legislation: Biocidal products may not be made available on the EU market or used unless authorised in accordance with the Biocidal Products Regulation (BPR). The authorisation procedure is a stepwise approach. First, the active substances used in biocidal products have to be approved in the European Union (EU). Second, the biocidal products which contain these active substances need to be authorized in the respective EU member state. The list of active substances and their approval status can be viewed on the website of the European Chemicals Agency (ECHA).

Biocidal products have to be classified and labelled according to the CLP Regulation (see 2). In addition they have to provide the following information on the label or in an accompanying leaflet:

• names and concentrations of the active substances contained,
• information about nanomaterials contained as “(nano)”,
• the uses for which the biocidal product is authorised,
• instructions for use,
• details of likely direct or indirect adverse side effects,
• where applicable, the categories of users to which the biocidal product is restricted
• information on any specific threat to the environment, particularly concerning the protection of non-target organisms (e.g. bees) and avoidance of contamination of environmental compartments.

The Biocidal Products Regulation also contains stipulations on ‘treated articles’, i.e. any substance, mixture or article which has been treated with, or intentionally incorporates, one or more biocidal products. For example, a sock that contains silver fibre to prevent odour or a paint that contains an in-can preservative are considered as treated articles. According to the BPR, articles can only be treated with biocidal products containing active substances approved in the EU for the relevant product type and use. Manufacturers and importers of treated articles need to ensure that products are labelled according to both the CLP Regulation (see 2) and the additional requirements defined by the BPR.

The BPR requires manufacturers and importers of treated articles to label treated articles when:

• a claim that the treated article has biocidal properties is made and
• it is a condition of the approval of the active substance contained in the biocidal product used to treat the article.

Where necessary due to the size or the function of the treated article, the labelling shall be printed on the packaging, on the instructions for use, or on the warranty. The labels need to be easily understandable and visible for consumers. Notwithstanding these labelling requirements, the supplier of a treated article shall, where a consumer so requests, provide that consumer, within 45 days, free of charge, with information on the biocidal treatment of the treated article.

Recommendation: Biocidal products can pose a risk to the environment and human health even if applied properly, and their use should be minimised wherever possible. Information about preventive management measures and non-chemical alternatives to the use of biocides can be found, e.g. on the biocides portal (German) and the SCOTTY website (English) of the German Environment Agency (UBA).

Definition: Plant protection products are chemical or biological products which are used to protect plants or plant products from harm caused by animals (e.g. insects and rodents) or diseases such as fungal diseases. Products used to eliminate unwanted field weeds are also classed as plant protection products. Plant protection products contain one or more active substance and other co-formulants (substances which are supposed to have a positive effect on the production, storage or use of a product).

Relevant EU Legislation: Under the EU Plant Protection Products Regulation, PPPs have to be authorised before they can be sold on the EU market. The risk to human health and the environment posed by the use of PPPs must be acceptable. Additionally, they must have a sufficient efficacy. These points are evaluated as a part of the authorisation procedure. In general, PPPs are always authorised for one or more specific uses, e.g. on apple trees, or for tomatoes, either in glasshouses only or on fields. This specific use also determines the maximum application rate and the timing of the application of the PPP, depending on the growth stage of the crop. An authorisation may include conditions of use and risk mitigation measures, e.g. distances to surface water bodies or off-field areas, the mandatory use of drift reducing nozzles when spraying, waiting periods before harvesting after application, etc. This is considered as the first column of the EU legislation.

Information about authorised plant protection products in Germany can be found here. In addition, PPPs have to be classified and labelled according to the CLP Regulation (see 2).

However, there are some severe gaps in the assessment of the environmental risk caused by PPP use, e.g. the risk caused by the combination of PPPs used in a crop over a season remains unclear and the impact of PPPs on biodiversity due to food web effects is not assessed. Therefore, the EU aims to reduce the overall use and risk of PPPs. In 2009, the EU Directive on the sustainable use of pesticides was put into force with the objective of introducing the rules of integrated pest management as a standard concept in agriculture, effectively reducing the use of PPPs. This is considered as the second column of the EU legislation. EU member states implemented these requirements into national action plans. The current German National Action Plan can be found here.

In 2020, the European Commission published its “Farm to Fork Strategy”. A 50 percent reduction in the use of plant protection products by 2030 is a core requirement. In 2022, the European Commission published its draft Regulation on the sustainable use of plant protection products (SUR). It is to replace the EU Directive on the Sustainable Use of Pesticides and is to be legally binding.

More detailed information on PPPs, their impact on the environment and their regulation is provided on the UBA website.

Recommendation: In practice, PPPs are mostly sold to and used by professionals. However, non-professionals can also buy and use PPPs that are explicitly approved for use in gardens and allotments. But hobby gardeners can grow healthy plants and crops without PPPs. Information on how you can protect your plants from pests or plant diseases without PPPs can be found on the UBA website (German) or in this UBA brochure (German).

(Information taken from the website of the German Federal Ministry of Food and Agriculture, the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection and the German Federal Office of Consumer Protection and Food Safety, November 2023)

Definition: ‘Food’ or ‘foodstuff’ means any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans. ‘Food’ includes drink, chewing gum and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment.

Relevant legislation: How food must generally be labelled and what minimum information must appear on the packaging is regulated uniformly throughout the EU in the European Food Information Regulation. The EU Regulation is directly applicable in all EU member states. It can be supplemented or specified in certain points by the member states.

As a general rule, all ingredients contained in a pre-packaged food must be included in the list of ingredients on the packaging.

• The ingredients are listed in descending order of weight as recorded at the time of production. In certain cases, the weight percentage of an ingredient must be indicated, for example if an ingredient is mentioned in the name of the food or if it is highlighted by means of images on the packing.
  
  
• The list of ingredients must also contain any food additives and flavourings used. Food additives must generally be listed with the name of their category followed by their specific name or E number. The category name illustrates what purpose the substance serves in the food (e.g. colour), and the chemical designation or E number shows the exact substance (e.g. curcumin or E 100).
  
  
• The presence of any of the 14 most important substances or products causing allergies or intolerances, such as nuts, or soy, must be highlighted in the list of ingredients. In addition, the alcohol content of alcoholic beverages above 1.2 percent by volume must be indicated, as well as the use of imitation foods, the origin of refined vegetable oils and fats, and caffeine or formed meat and fish.
  
  
• All ingredients present in the food in the form of engineered nanomaterials must be included in the list of ingredients. The name of such ingredients must be followed by the word "nano" in brackets.

Pre-packaged foods must generally be labelled with a nutritional declaration. This must usually be presented as a table. To facilitate comparison, the nutrient content must always refer to 100 g or 100 ml amounts.

So much for the information that has to be labelled on the packaging of the food. But what about contaminants in foodstuffs? A contaminant is any substance that is not intentionally added to the food but is present in it as a result of extraction, manufacture, processing, preparation, treatment, presentation, packaging, transport, storage or as a result of environmental contamination. Concentration limits for such contaminants are laid down in the European Regulation on maximum levels for certain contaminants in food. In Germany, the Federal Ministry of Food and Agriculture (BMEL) and (for environmental contaminants) the Federal Ministry for the Environment, Nuclear Safety and Consumer Protection (BMUV) are responsible for the regulations in this area. The BMUV provides consumer tips on its website. Food contamination is monitored by the responsible enforcement authorities of the German Federal States. They publish information on foods that have been recalled by the producers or rejected by the authorities in their national rapid alert systems. If these foodstuffs have been marketed in more than one European country, the information is also published in the European Rapid Alert System for Food and Feed (RASFF).

In Germany, the Federal and Laender authorities collect data on the detection of substances that are harmful to health in foodstuffs, cosmetics and consumer goods on the German market (reference). Undesirable substances include residues of plant protection products, pesticides, or veterinary medication, as well as heavy metals, mycotoxins, various organic chemicals, or microorganisms. The national portal lebensmittelwarnung.de gives current warnings when authorities have identified food-related issues and provides information about products that have been recalled in Germany.

In accordance with the EU regulation on maximum residue levels of pesticides, the Federal Office of Consumer Protection and Food Safety (BVL) reports annually on the results of the investigations of foodstuffs for residues of plant protection products.

You can find more information about food safety in Germany on the web sites of the Federal Ministry of Food and Agriculture (BMEL), the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) the Federal Office of Consumer Protection and Food Safety (BVL) and the Federal Institute for Risk Assessment (BfR).

Recommendation: Choose a healthy food mix and prefer fresh, regional, rather unprocessed food, if possible from organic farming.

Before any use of medical devices or medicinal products, the risks and benefits must be weighed against each other. Always read the package insert of medicines and ask your doctor or pharmacist.