Updated: Oct 20, 2020
Wearing face masks are key steps to preventing COVID-19. But we are seeing more and more articles as well as social media testimonies talking about skin irritation from face masks. Skin may become red, sensitive and rough and some mask wearers have been complaining about ‘maskne’
In April, the NHS published a guidance ‘Helping prevent facial skin damage beneath personal protective equipment’ to provide staff with guidance and recommending keeping skin clean and well moisturised.
There has been a strong demand in deep cleansing skincare products and we are starting to see new marketing claims on the market regarding prevention of maskne or skin redness / irritation reduction due to face mask. Although the role of skincare products to keep skin in good condition is critical, cosmetics cannot treat or prevent an adverse condition. Companies should therefore be aware of the legislation and ensure that their product claims are acceptable.
Prevention or treatment of acne (e.g. Acne vulgaris) or other inflammatory lesions of the skin (such as papules and pustules) do not fulfil the definition of a cosmetic product and, as such, should not be placed onto the EU market under the cosmetics regulatory framework. For example, a product that is presented as an ‘anti-acne’ product should not be marketed as a cosmetic product.
Eczema / dermatitis:
Protect /prevent eczema, dermatitis and psoriasis. These are all adverse medical conditions which can be exhibited by dry, inflamed, scaly and itchy skin and products will fall to be either medicinal products or medical devices depending on their mode of action.
Skin redness / irritation:
A claim referring to "soothing irritations / redness", for example, may sometimes be acceptable for a cosmetic product. It will depend on the overall presentation of the product, its primary function and its way of action.
As a rule, cosmetic claims should emphasise the cosmetic use of the product i.e. cleansing, moisturising, perfumery, keeping the skin in good condition. It is true that the cosmetic definition envisages that a cosmetic product may have a secondary preventative (but not curative), purpose. However a case by case assessment should be performed by the company to ensure that the product has a primary cosmetic function (e.g. moisturizer) and is not presented as a medicinal product.