Cosmetic products aren’t recalled for safety reasons too often – but it definitely does happen, so it’s something you should prepare for as a brand.

Earlier this month, Hunter Lab undertook a voluntary product safety recall of their Daily Face Fuel due to potential microbial contamination. The product was sold individually and in gift packs over a period of 8 months (hopefully not too many were Christmas presents!) both online and in large retailers including David Jones, Adore Beauty and The Iconic.

Hunter Lab stated on its website: “It has recently been discovered through our routine quality assurance testing and customer feedback that a batch of Daily Face Fuel 100mL does not meet our product standards. It may contain an unsatisfactory level of microbial activity that can cause product deterioration, discolouration and/or a change in scent over time.”

And from the ACCC website: “The affected batch of moisturising cream can be contaminated with bacteria Pseudomonas aeruginosa and Klebsiella oxytoca …. which can cause infection or illness, especially in people with weakened immune systems.”

Here are 3 key takeaways:

• The risk of microbial contamination is very real due to the nature of cosmetics – particularly with the above bacteria being commonly found in soil and water. Even with proper product preservation, contamination can occur for various reasons during the manufacturing process. This is why quality assurance procedures are so important as an extra line of defence, including keeping batch records and samples, as well as a register of any customer feedback or complaints about your products. If you see any concerning trends, this should trigger you to test your batch samples to identify any potential safety issues.

• Having a product recall procedure is also essential – now, hopefully you won’t ever need to use it, but the last thing you’d want to happen in the above situation is to be scrambling around – unsure of what to do, who to contact and what processes to follow. There are also legislatively prescribed timeframes to meet for notifying the Government about recalls.

• Batch numbers currently aren’t required by law in Australia for cosmetics – but they play a huge role in product recalls. Both retailers and consumers can look at the batch number on the label or packaging to work out whether their batch is affected, rather than ALL potentially affected batches of that product needing to be binned. That would be a total waste of product, money and packaging (not great from a sustainability or financial perspective right?).

If you want to learn more about product recalls, it’s something we cover in the Compliance Confidence course on Australian cosmetics regulations.

The ACCC also has some useful resources, and new product safety recall guidelines will be published in early 2023.