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Focus on Food Imitation Products

04/09/2018

CTPA has noted that, under the Rapex system, there has been a focus by Member States on cosmetics imitating food that may cause a choking hazard for children, in particular bath bombs in the shape of cupcakes, doughnuts, etc.  A search on the Rapex database using ‘cosmetics’ as the category and ‘choking’ as the descriptor shows the number of such instances.  Members are reminded of the requirements of the Dangerous Imitations Directive (87/357/EEC) and the specific reference in the Cosmetic Products Regulation (CPR) (Article 3).  Directive 87/357/EEC prohibits the marketing, importing and manufacture of products that look like foodstuffs. The Directive applies to all products which are not edible, but could easily be confused (especially by children) with foodstuffs due to their:

  • appearance;
  • smell; or
  • packaging.

And which might cause injury, e.g.

  • suffocation;
  • poisoning; and /or
  • choking.