Policy Regulatory Technical Notification 02-2025
Dear CTFA member
Please find this week’s notification for information and consideration.
Regulations for the Management of Mercury in South Africa now in force
Cosmetics are generally excluded from requirements in the regulations if mercury is not intentionally added to products, and there are further allowed exceptions
The Department of Forestry, Fisheries and the Environment has published the Regulations for immediate implementation (6 February 2025), with some requirements already due by 1 April 2025. The Regulations are intended to manage mercury and possible environmental contamination, as well as align the country to the outcomes of the fifth Minamata Convention on Mercury (to which South Africa is a party) that was held in 2023.
South Africa does not have a good history with mercury environmentally, so these regulations are a positive step for the country.
During their development it was important for CTFA to ensure that unintentional trace amounts of mercury (for example in cosmetics) would not form a part of the Regulations. Although this is the case and the understood intention, it is strongly advised that the Regulations are reviewed, especially the sections on cosmetics; mercury-added products; mercury; and mercury compounds.
Small areas of ambiguity still exist in the wording of the Regulations, therefore CTFA will confirm further clarity with DFFE in due course during its bilateral discussions.
A copy of the Regulations is available from CTFA.
European Commission - Borderline Manual on Cosmetic Products
New Addition
The manual of the Working Group on Cosmetic Products (sub-group on borderline products) on the scope of application of the Cosmetics Regulation (EC) No. 1223/2009 (art. 2(1)(a)) has been updated. The Working Group have agreed to include a new entry, 3.3.34, related to ‘Products in a vial or ampoule’ addressing the question on whether they could be considered as cosmetic products.
A copy of the latest version of the Manual is available from CTFA.
Should there be any queries or if you would like further information/documentation, please do not hesitate to contact: Dr Glen Malherbe - glen@ctfa.co.za / 082 908 3383 or Nadia Rashid - nadia@ctfa.co.za
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