Regulations on dangerous substances are becoming increasingly strict. They are based in particular on the French “AGEC” law and European regulations such as REACH. These substances, classified as CMR (carcinogenic, mutagenic, reprotoxic), endocrine disruptors, or SVHC (Substances of Very High Concern) must be identified and controlled throughout the product lifecycle.
In this context, traceability of hazardous substances is a key challenge for manufacturers and distributors. The beCPG PLM has therefore integrated a dangerous substance management system. This makes it possible to monitor and analyze their presence and ensure better regulatory compliance.
Identification of dangerous substances in packaging
A dedicated space in beCPG PLM
In beCPG, data on the presence of dangerous substances can be directly stored within “packaging” entities. A dedicated list is now available: the “Dangerous substances” list.
The beCPG database includes a selection of substances to be configured as dangerous, along with their associated hazard types (carcinogenic, mutagenic, etc.), in accordance with Article 57 of the REACH regulation. Then, within each packaging item, the relevant substances can be added with their quantity and migration rate, that is, the proportion of the substance likely to transfer from the material to the final product. Using this data, the PLM can automatically calculate the actual quantity of the substance present in the packaged final product.
Automatic generation of claims related to danegrous substances
Under the AGEC law, specifically article 13, manufacturers and market players must inform consumers if their products contain dangerous substances above a certain threshold. This obligation particularly applies to SVHC substances or identified endocrine disruptors. As such, when a listed substance is present at more than 0.1% w/w, a declaration is required.
In beCPG, these claims are generated automatically from the data entered in the packaging. The system checks if any relevant substances are present and whether their concentration exceeds the regulatory threshold. For example, if packaging contains more than 0.1% lead, the claim “Packaging without SVHC” cannot be displayed. However, if no such substances are detected above the threshold, the claim can be considered as valid.
In short, claims like “Packaging without SVHC”, “Packaging without dangerous substances” or “Packaging without endocrine disruptor” are directly tied to the data entered into the system.
Identification of dangerous substances in raw materials
Dangerous substance management also applies to raw materials. Simply add the substance as an ingredient in the raw material, and it will automatically be accounted for in the dangerous substances list. It will appear there with its used quantity, making it easy to track its impact on the final products.
This is a common situation, especially in cosmetics, where some ingredients can be classified as substances of concern. Thanks to this logic, it becomes easy to spot their presence in a formula. This avoids the need to manually check the ingredient list.
It is also possible to manually add the substance directly in the “hazardous substances” list if needed.
Finished products: a comprehensive view
Automatic formulation of dangerous substances from packaging and raw materials
beCPG also allows tracking of dangerous substances directly in finished products. A dedicated list is automatically generated based on the raw materials and packaging used in the recipe. As soon as an ingredient or packaging contains a dangerous substance, it is automatically identified. It then appears in the dangerous substances list for the finished product, with its name, category (CMR, SVHC, ED, etc.) and quantity.
It’s also possible to display detailed origins of each substance, with a precise breakdown between raw material and packaging contributions. This level of detail makes it easy to see where a substance is coming from and how it impacts the product.
Taking into account the migration rate from packaging to product
Management does not stop at the mere presence of the substance. The system also considers migration rate, where available. This gives a more accurate view of what’s actually present in the final product. This is useful for food or cosmetic products, where packaging can impact the formula.
For instance, some materials used in packaging or cooking may release unwanted substances into food. This is the case with some plasticizers in bottles, inks on food pots, or fluorinated compounds (PFAS) (source: Le Monde). Bisphenol A (BPA), also of concern, is now subject to a European regulation (EU) 2024/3190. This regulation bans its use in materials that come into contact with food.
Given this context, companies have every interest in identifying these substances early to remove or replace them if necessary. With a tool like beCPG, it becomes easier to detect them in raw materials or packaging, and stay in line with regulatory requirements.
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