EU Releases Technical Guidance on Leave-On Hand Gels

On November 12, 2020, the
European Commission released a technical guidance document that provides a
non-exhaustive list of product claims that do not support the classification of
leave-on hydro alcoholic hand gels as cosmetic products due to perception.

The document was published
following the findings of the Sub-Group on Borderline Products on October 8,
2020, which were endorsed by the Working Group on Cosmetic Products via written
procedure on October 23, 2020 and at its meeting on 12 November 2020.

The technical document complements the latest
borderline manual and the guidance on the applicable legislation for leave-on hand cleaners and hand

Labeling elements that
would not support a main cosmetic function of leave-on hydro alcoholic hand
gels (not to be used on cosmetic products):


  • Antibacterial, antimicrobial, antiviral,
    virucide, antifungal (and their attributes, such as ‘antiviral
    properties’, ‘antibacterial ingredients’, ‘inhibits bacterial growth’)
  • Disinfecting, disinfectant, disinfection,
    sanitizer, sanitizing
  • Antiseptic
  • Kills X% bacteria/viruses/microbes
  • Decontaminating
  • Formulation recommended by the World Health
    Organisation (WHO)
  • Anti-COVID-19, anti-coronavirus, anti-SARS

References or allusions to:

  • Infection, pandemic, diseases
  • COVID-19, coronavirus, SARS-CoV-2
  • Microorganisms, bacteria, viruses, pathogens,
    germs, fungi
  • Disinfection
  • Medical use
  • Percentage of alcohol in the product
  • Safe hands

Pictures or graphical elements of:

  • (Corona)virus, bacteria, microbes
  • (Red) cross (when suggesting a medical
  • Shield (when indicating protection against
  • STOP sign (when indicating
    preventing/controlling the spread of a disease or infection or microbes)
  • Any sign related to hospital, pharmacy,
    ambulance, first aid, etc.
  • CLP pictograms

SGS Hand Sanitizer and Disinfectant Services

SGS offers a comprehensive range of testing and
compliance solutions to help manufacturers and suppliers deliver safe and
compliant products to their target markets. Learn more about SGS’s Hand Sanitizer and Disinfectant Services.

SGS SafeGuardS keep
you up to date with the latest news and developments in the consumer goods
industry. Read the full EU Commission Publishes Borderline Working Document on
Leave-On Hand Gels

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For further information contact:

Ho-yan TSE

Assistant Technical Service Manager

Tel: +852 2765 3672



LinkedIn: sgs-consumer-goods-&-retail

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