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The Purview Of Heavy Metal Limits For Cosmetic Products Imported To India

The inclusion of heavy metals in cosmetics is an inevitable truth. Cosmetics, either natural or artificial do contain some amount of heavy metals in them. These can be present as manually added ingredients or just contaminants. Nonetheless, the presence of heavy metals cannot be ignored due to their far reaching negative effects on the human metabolism and health.

However, the addition of heavy metals is a necessity for some cosmetic products. This in turn requires the regulatory authorities to draft strict and scientifically safe limits for their composition in cosmetics. As a matter of fact, many cosmetics used on a daily basis, such as lipstick, nail colour, eyeliner, etc, contain heavy metals. 

What are heavy metals and what is their impact on human health?

In layman terms, a heavy metal is a metal with high density. Examples of some common heavy metals are lead, arsenic, mercury, cobalt, cadmium. Heavy metals are generally toxic for the body because they produce free radicals which causes damage to biological molecules(enzymens, hormones, DNA, etc) and can lead to neurotoxicity and even carcinogenesis.

While our bodies need a small amount of some heavy metals, their excess can cause serious health problems. 

Heavy metals in cosmetics and requirements for importing such products in India

As already mentioned, heavy metals can be found in most cosmetic products. Mostly as contaminants but sometimes also as resulting ingredients. Cosmetics containing dyes, colours (synthetic or natural) and pigments generally have heavy metals as ingredients.

The most common heavy metals in question are Lead, Arsenic and Mercury.
For obtaining a cosmetic import license from CDSCO, an applicant has to submit form number 42 along with several other supporting documents. One such important document is the certificate of analysis which mentions the amount of heavy metals present in the cosmetic product in question. 
This certificate of analysis has to be created by the manufacturer in the country of manufacturing of the cosmetic. This small form clearly mentions the product’s name, it’s batch number and other characteristic properties such as colour, odour and the level of heavy metals.

According to CDSCO, a certain level of heavy metals in cosmetics is permissible. To be specific: 
  • Less than 2 ppm (parts per million) of Arsenic calculated as Arsenic Trioxide
  • Less than 20 ppm of Lead calculated as Lead
  • Less than 1 ppm of Mercury
  • Less than 100 ppm of total heavy metals other than Lead
Apart from these, no cosmetic product shall be imported in India that contains hexachlorophene and mercury compounds.

A non-compliance of these limits, if found upon inspection(if deemed necessary by the authorities) will result in either the confiscation of the entire batch for destruction, or will result in the importer shipping the batch back to the country of import of manufacture.

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