Division 3.5 Normal and reasonably foreseeable use

The section on normal and reasonably foreseeable use of the product is essential for the safety assessor to be able to determine a relevant exposure scenario. The intended use should be appropriately communicated to the consumer in order to avoid misuse of the product.

In addition, warnings and other explanations on the labelling should be consistent with the identified normal and reasonably foreseeable use, and the reasoning justifying their inclusion is to be given.

A clear explanation of the normal intended use and the reasonably foreseeable use should be provided. For instance, in the case of a shampoo, the normal intended use would be to use it on the scalp; an (unintended) reasonably foreseeable use would be for it to be used as a shower gel. Ingestion would be a clear misuse.

To this end, a practical approach may be useful. For example, one could include a photo of the packaging or the artwork in the cosmetic product safety report to show the presentation of the product and its intended use. It would also be useful to make the link with the warnings and labelling, as highlighted by Annex I to Regulation (EC) No 1223/2009 on this point.