Regulatory Consultant for EU Cosmetics

We are a cosmetics brand seeking an experienced EU cosmetic regulatory expert to assist with a compliance matter involving naturally occurring trace heavy metals in a clay-based product. The heavy metal in question originates from the clay raw materials used in the formulation. Based on our current understanding, achieving levels below our measured range is technically unfeasible due to the natural mineral composition of the raw materials. At the EU level, there is no specific numerical limit for this substance in cosmetic products. The EU Cosmetics Regulation includes a provision that permits technically unavoidable traces of prohibited substances, provided the product is safe for human health and complies with applicable safety requirements. We believe our situation qualifies under this technical unavoidability provision. Scope of Work We are looking for a consultant who can: Review our regulatory situation and available documentation. Assess whether the technical unavoidability provision can be applied to justify the presence of trace heavy metals in our products. Evaluate whether a scientifically and legally defensible argument can be made that achieving lower trace levels is technically unachievable for these clay-based formulations. Prepare a technical-unavoidability justification supported by scientific evidence.