Scope
BVL’s 2017 announcement/report gives orientation values for technically avoidable heavy-metal contents in cosmetic products. The values apply to cosmetic products in general, toothpaste, and named decorative or theater/fan/carnival make-up exceptions.
Exact limit and units
| Species | Matrix | Limit | Basis |
|---|---|---|---|
| Pb | cosmetic products in general except listed higher-lead make-up categories | 2.0 mg/kg | cosmetic product |
| Pb | make-up powder, rouge, eye shadow, eyeliner, kajal, and theater, fan, or carnival make-up | 5 mg/kg | cosmetic product |
| Pb | toothpaste | 0.5 mg/kg | cosmetic product |
| Cd | cosmetic products in general | 0.1 mg/kg | cosmetic product |
| Cd | toothpaste | 0.1 mg/kg | cosmetic product |
| tHg | cosmetic products in general | 0.1 mg/kg | cosmetic product |
| tHg | toothpaste | 0.1 mg/kg | cosmetic product |
| tAs | cosmetic products in general except theater, fan, or carnival make-up | 0.5 mg/kg | cosmetic product |
| tAs | theater, fan, or carnival make-up | 2.5 mg/kg | cosmetic product |
| tAs | toothpaste | 0.5 mg/kg | cosmetic product |
| Sb | cosmetic products in general | 0.5 mg/kg | cosmetic product |
| Sb | toothpaste | 0.5 mg/kg | cosmetic product |
How tested
The report says the German Monitoring Scheme used a standardized convention method that brings the elements into solution under defined conditions. It cites BVL method K 84.00-29:2011-03 for pressure digestion to determine elements in cosmetic products.
Enforcement posture
The table gives technically avoidable orientation values. It explains that values above the listed levels are considered technically avoidable under good manufacturing practice, while product safety must still be demonstrated case by case under the EU cosmetic safety framework.
History of changes
The report replaces older German Federal Health Office orientation values from 1985 and 1990, which BVL considered outdated because lower heavy-metal levels had become achievable in cosmetic products.
How it compares
These German values are generally lower than the ASEAN-style 20 ppm lead and 5 ppm arsenic/cadmium cosmetic guidance limits, especially for toothpaste and most non-decorative cosmetics. The source treats arsenic and mercury as element-level contaminants without speciation detail.
Sources
Update history
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