Module 18 2021

Borderlines with Cosmetics

Whether a product is a cosmetic or a medical device will relate mainly to the claims made for it. The majority of borderlines of this nature are between medicinal products and cosmetics, rather than medical devices, and will centre on whether there are ‘medicinal’ claims for the product concerned. There are, however, a few products on the borderline with medical devices: e.g.

Hair conditioner – cosmetic Hair product intended to aid the removal of lice with a head lice comb – accessory to the medical device (comb) and therefore a medical device.

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What is PPE? ‘personal protective equipment’ (PPE) means:

(a) equipment designed and manufactured to be worn or held by a person for protection against one or more risks to that person's health or safety; (b) interchangeable components for equipment referred to in point (a) which are essential for its protective function; (c) connexion systems for equipment referred to in point (a) that are not held or worn by a person, that are designed to connect that equipment to an external device or to a reliable anchorage point, that are not designed to be permanently fixed and that do not require fastening works before use; - Regulation (EU) 2016/425 on personal protective equipment

In short – PPE is equipment intended to protect the individual against (a set of) specific hazards.

Some specific products are excluded e.g. motorcycle helmets, dishwashing gloves, equipment specifically designed for use by armed forces/police

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