On 20 February 2024, the European Commission published the updated version of the Borderline Manual of Cosmetic Products including two new entries:

• Glues and adhesives intended to fix articles like fake nails, false eyelashes, jewellery on teeth, etc.
• Magnetic eyeliners

The Borderline Manual is a guide created by the EC Working Group on cosmetic products. It aims to assist companies in determining whether their products fall within the scope of the EU Cosmetics Regulation. However, in any case, a decision on the qualification of the products has to be made by the national competent authorities, on a case-by-case basis, and taking into account all characteristics of the product.

Adhesives and glues

Adhesives and glues used to secure items such as false nails and false eyelashes meet two elements of the cosmetic product definition: the composition of the product and the application area. However, the presence of a primary cosmetic function should be evaluated depending on the circumstances. In this regard, the Borderline Manual explains that if the adhesive can alter the appearance of the application area on its own, it can be considered a cosmetic product. Conversely, if the adhesive serves a specific function, such as attaching an item to the external part of the human body, it cannot be classified as cosmetic due to the lack of a cosmetic function.

Glues used to attach fake nails have to be distinguished from substances and mixtures that are to be applied to the nails to create artificial nails. Those substances and mixtures applied on the nails during the process of forming artificial nails are likely to fulfil the third criteria of the cosmetic product definition,
i.e. the exclusive or main cosmetic purpose, and therefore are likely to be considered as cosmetic products

Magnetic eyeliners

A magnetic eyeliner,is an eyeliner which is applied on an eyelash line like a regular eyeliner, but which can also have a secondary purpose: apart from changing the appearance of the part of the skin on which it is applied it can also allow false lashes to be attached to the eyelid. According to the Borderline Cosmetic Products Manual, if the primary function of the product is the same as that of a regular eyeliner and the product's content is appropriate, it can be classified as "cosmetic." In this case, its other function can be evaluated as secondary.

The manual can be found here.