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Restriction of D4 and D5 in Personal Care Products

Belinda Carli – Jun 18, 2018

TAGS:  Skin Care      Hair Care      Toiletries     Silicone Alternatives   

Restriction of D4 and D5 in Personal Care ProductsOn 10th January 2018, Commission Regulation (EU) 2018/35 was added, specifically restricting the input of octamethylcyclotetrasiloxane (D4) and decamethylcyclopentasiloxane (D5) to less than 0.1% in wash-off cosmetic products. This restriction will come into effect by 31st January 2020, after which time all products being sold in the EU market must comply.

You would more commonly know these materials as cyclomethicone or cyclopentasiloxane – low molecular weight volatile siloxanes, providing an extremely light and dry after feel in personal care products because of their volatility – the ability to partially or wholly evaporate from the hair or skin.

Why have they been restricted?

These materials are not harmful to human health, but instead, represent issues to our environment. D4 has been identified as a ‘persisitant, bioaccumulative and toxic (PBT)’ substance, as well as a ‘very persistant very bioaccumulative (vPvB)’ substance.

D5 has been identified as a vPvB substance. This means that once they are washed off and enter our waterways, they do not biodegrade and hence accumulate, and pose risk to aquatic organisms with unpredictable long-term detriment to our environment.

What does this mean for the personal care industry?

This restriction means that neither of these substances, on their own or when part of blended materials, are able to be added to a personal care formulation at an input of greater than or equal to 0.1% in wash-off products.

This includes any product that through normal use should be washed off after application. Examples of such products include facial and body washes, shampoos, conditioners and treatment products, where washing off shortly after the application is part of the normal directions for use.

What about leave-on cosmetic products?

Use of D4 & D5 in Hair Oils and Color CosmeticsSince D4 and D5 will commonly evaporate from the skin or hair over 1-3 hours of application, their use in leave-on products has not considered an issue yet. Consider this: by the time the user would wash their face, hair or body containing these materials, there would be little if any residual material left over to enter our waterways.

Their use in leave-on products is much wider – the most common uses are in leave-on hair oils and color foundations. You would recognize their volatility in the non-greasy, powdery-dry and weightless softness imparted by these finished production types to the hair and skin respectively. If non-volatile materials were used, by comparison, the hair would be left feeling lank and oily and the skin feeling greasy.

What are the solutions?

Fortunately for this restriction, D4 and D5 are not commonly used in wash-off products since their light, volatile feel is required more commonly in leave-on products compared to wash-off products, where other materials may serve similar purposes.

Commercially Available Silicone Grades!
Where these materials are being used in wash-off products, suitable alternatives could include:

  • Silicone copolyols: Dimethicone materials with PEG or PPG (or both) in the INCI name, which means part of the substance is hydrophilic – providing wet conditioning while any excess is easily washed off.

  • Dimethicone and amodimethicone emulsion blends: These emulsion blends enable the light, silky emolliency of silicone derivatives to be applied to the skin or hair, but as part of the emulsion delivery system, have the excess washed off for a near weightless after-feel.

  • Volatile alternatives: There are only a few truly volatile alternatives at this point that are biodegradable, but we’ll be sure to see more soon. Examples that exist now include:
    There are many other D4 & D5 alternatives with light, silky and dry after feel even without the volatility.

  • If volatility is important then look for materials with low vaporization temperatures; but if volatility is not important, then there are many alternatives providing a similar dry after-feel – look for this information when investigating the suitability of materials.

What is the future outlook?

The European Chemicals Agency (ECHA) has put forward a submission to have similar restrictions placed on D4 and D5 in leave on personal care, among other household products in March 2018.

This submission has however been met by opposition from the household cleaning and personal care industries. While this proposal is still under consideration by the Regulatory Authorities, our Industry is answering the call for alternatives – we are seeing multiple suppliers continue expanding their D4 and D5 replacement portfolios.

By the time any restrictive legislation gets passed (if it does in fact succeed), we should find suppliers who have answered the call for silky, light, volatile and biodegradable substances with multiple suitable replacements.

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