global cosmetic industry platform contributed by ICADA eV association

Eyelashes sera: controversial prohibition-initiatives by authorities

The market for eyelashes-growth influencing sera has grown, because these products are highly efficacious.

By new official statements German authorities try to ban these cosmetic products from the market. They started the new wave of prohibition-attempts with a lecture by a representative of German authorities at a symposium in March 2019. Afterwards some regional market surveillance authorities tried to ban individual products, but did fail yet. You find the ICADA-comment on the relevance and the missing compliance of the arguments to cosmetic regulations here

Abstracts of the ICADA-objections: the criticism by the authorities are incorrect , not scientific based and not in compliance to cosmetic regulations:
1.The proof of a pharmaceutical effect in the case of classification as a functional drug is missing
2. “significant (!) pharmacology effect” for classification as a functional drug is missing (they even do not know the cosmetic working-mechanism of prostaglandins)
3. no scientific studies on hair growth regulation by active substances are presented
4. no safety assessment due to CPR 1223-2009 is presented (no assessment of hazardous substance data and resulting risk assessment)
5. Lack of evidence of practical relevance (no SUE cases or Rapex notifications are documented, from which one could justify actual risk

ICADA has prepared a position-paper, to document the legal compliance of lashes-growth influencing cosmetic products (see here)

ICADA has successfully defended eyelash sera for years and will also present further arguments against intended prohibitions in the future.

Therefore, we will now document the safety of eyelash growth sera and invite your company to benefit not only from our opinion and documentation, but also from the results of the ICADA documentation with the objective to defend eyelash-growth influencing products.

We recommend the following procedure, to defend yourself your products and contribute to the industry-surveillance

  1. document the number of sold units of eyelash growth sera since the market-introduction
  2. document “serious undesirable effects/SUE” since market introduction **

in relation.

To support the ICADA-industry-survey, we kindly ask for your two figures to (1) and (2) ** via mail(at)icada.eu. We’ll keep you updated with the results and future events. Your ICADA team

The strongest K.O. criteria against prohibition argument are to be read here: Inventory of the most important statements on eyelash growth serums
(to be downloaded here)

  1. the positive EMA report from 2004
  2. the positive EU borderline manual entry
  3. 2 minutes of the meeting of the Cosmetics Commission
  4. the statements of 2 German investigation offices
    the opinion of a cosmetic expert in the civil service
    the AGES report
    ICADA Review of Prohibition Arguments and Corrections

** Your information is of course confidential, discretely treated and anonymised after the addition of all reported market figures. The more companies contributing to the pay pool, the more significant this ICADA score will be in terms of the ability to defend the marketability of eyelash growth scars, WHIMPERNSERUM PROHIBITION