Organic UV-filters and freshwater organisms: data gaps impede a robust retrospective environmental risk assessment

Background

For use in cosmetic products, 32 substances have been authorised in the EU as UV-filters as of August 2022 (Annex VI of the EU Cosmetics Regulation (EC) No 1223/2009). Although these substances can enter the aquatic environment directly through bathing, authorisation for use in cosmetic products does not require a specific environmental risk assessment, whereas risks to human health are specifically assessed. Furthermore, no environmental quality standards have been proposed at EU level. For the current review, data on freshwater ecotoxicity, physicochemical properties, environmental fate and measured exposure were retrieved from ECHA registration information and public databases and assessed for reliability and relevance. Environmental quality standards (EQS) were proposed based on the EU technical guidance for EQS for the Water Framework Directive (WFD).

Results

From a WFD perspective, there were significant or complete gaps for acute and chronic effects data, sediment organisms and rarely tested organisms at the time of data retrieval, as well as gaps for measured environmental concentrations in the assessed databases. The reliability of the reported data could not always be verified due to missing information. As expected from the heterogeneity of molecular structures, ecotoxicity data and environmental fate parameters vary considerably between the different substances. Our assessments indicate that the use of some of the substances in direct contact with surface water may pose a repeated risk to aquatic organisms.

Conclusions

We recommend a revision of the process for the inclusion of UV-filters in the EU Cosmetics Product Regulation, taking into account the potential environmental risks. A full assessment of all UV-filters using standard test organisms as well as rarely tested species for acute and chronic effects and bioaccumulation would require, among other things, a large number of fish tests. Therefore, new assessment methods (NAMs) are recommended, including the use of fish cell lines for acute toxicity testing and alternatives for the assessment of chronic toxicity.