The European Commission Scientific Committee on Consumer Safety (SCCS) recently published a draft opinion on solubility of Synthetic Amorphous Silica (SAS). The draft is out for public comments until 17 May 2019. 

The SCCS states e.g. that 'the hydrophilic and hydrophobic SAS materials can therefore be regarded as “insoluble” to “very slightly soluble'. However for nano SAS they say 'In regard to the nanomaterial definition in the Cosmetic Regulation, none of the SAS materials (hydrophilic or hydrophobic) included in the dossier can be regarded as soluble.'

SCCS also states furhter, with regard to nano SAS that 'In the context of the definition of nanomaterial under the Cosmetics Regulation, which relates to insoluble materials in conjunction with other size/particle related parameters, the question of solubility of a nano-structured material needs to be seen in perspective for use in cosmetics. For nano-structured materials, with the exception of the materials that are completely soluble, it is important to establish whether a proportion of these materials would still exist in undissolved form comprising nanoparticles, at the given use level in a cosmetic formulation.'


NIA Members are invited to contact NIA with detailed views on the preliminary opinion to forumlate an NIA comment by the deadline.