https://gazettes.africa/archive/rw/2016/rw-government-gazette-dated-2016-02-29-no-9.pdf

The ministerial order published in the gazette no. 09 of 29/02/2016 introduces a list of harmful prohibited and regulated cosmetics in Rwanda. With the policy, the Ministry of Health in collaboration with Rwanda Standards Board (RSB), The Rwanda Food and Drug Authority and other concerned stakeholders have established mandatory standards for cosmetics in accordance with national and international standards.

Strict enforcement and educational campaigns and programmes significantly reduce the risks stemming from hazardous chemicals in cosmetic products. A specific focus on skin-lightening creams targets the issue of beauty standards based on white skin. These creams are often already used for young children and among adolescents who are at special risk from chemicals like mercury, and their health impacts. The same accounts for pregnant women who can pass on toxic chemicals to the unborn baby.

Apart from health benefits, this law has also a positive effect on the environment as it eases the path to prevent empty product containers of such harmful chemical-infused cosmetics to end up in the environment after usage, causing the toxic chemicals to harm the ecosystem.

Our “Best Policies” are those that meet the Future Just Lawmaking Principles and recognise the interconnected challenges we face today. The goal of principled policy work is to ensure that important universal standards of sustainability and equity, human rights and freedoms, and respect for the environment are taken into account. It also helps to increase policy coherence between different sectors.

Sustainable use of natural resources

• The policy does not directly address the sustainable use of resources. However, it prevents toxic chemicals from being released into the environment through activities such as showering after using products containing toxic chemicals or improper disposal of containers with residual toxic chemicals. This measure helps safeguard wildlife and ecosystems from potential harm.
• The law and the existing awareness-building programmes influenced the general public to use more environmentally friendly, natural and healthy products.

Equity and poverty eradication

• As the issue of using cosmetics with harmful chemicals especially affects women. Thus, the harms associated are equally unevenly distributed. During pregnancy, the harmful effects of mercury or other harmful chemicals and heavy metals can pass from a mother to her baby, as well as through breastfeeding after birth.
• The law addresses social justice by prohibiting hazardous chemicals in cosmetics irrespective of their price. It ensures that cheap cosmetics meet the same requirements as expensive products from well-known brands. This approach evens the playing field by providing the same level of protection to all people in the country, irrespective of their income.

Precautionary approach

• The law provides a provision for labelling of the cosmetics to provide users with the ingredient’s information. This empowers the Rwanda Bureau of Standards to test cosmetic products before they enter the market and those products that are already available in the local market for prohibited chemicals.
• As a precautionary measure, the government of Rwanda has been conducting awareness-building programmes that educate people against the harmful effects of toxic cosmetics containing toxic cosmetics.

Public participation, access to information and justice

• The awareness-building programmes for manufacturers and consumers about the harmful effects and illegality of using prohibited chemicals in cosmetics involve different stakeholders and the government in the law’s implementation.

Good governance and human security

• The Ministry of Health, the Rwandan Bureau of Standard and the Rwandan Food and Drugs authority are collaboratively responsible for governing the implementation of the law.

Integration and interrelationship

• The law is adopted by the Ministry of Health and implemented together with the Rwanda Standards Board (RSB) and The Rwanda Food and Drug Authority. There exists a good interrelationship between the different branches related to the Law.
• The government is also eager to raise awareness among distributors and consumers about the effects of harmful chemicals in cosmetics and discourages them from their use and sale.

Common but differentiated responsibilities

• The law provides strict regulation against harmful chemicals and heavy metals that have been used in cosmetics.

Many experts relate the culture of colourism in Africa to the colonial era. Film and literary characters or toys like dolls, etc. tend to have paler skin tones which are associated with power and beauty in African countries like Rwanda. For most people, having paler skin is more desirable. As a result, the use of harmful chemicals infused cosmetics, that bleach their skin, making it paler, has been an important part of their lives. According to the World Health Organisation (WHO) at least four out of every 10 women in Africa bleach their skin. A big part of the Rwandan population used to have cosmetics infused with hazardous chemicals for daily usage. However, the use of these harmful chemicals as forming part of cosmetics is extremely bad for human skin and health in general. The heavy metals and other harmful substances existing in cosmetics can cause many diseases, including cancers. Some toxic chemicals found in cosmetics can also harm foetuses in the womb of the consumer and can harm breastfeeding babies if the mother uses such products.

The purpose of this regulation is to protect the people of Rwanda from the harmful effects of chemicals that exist in cosmetics. The aim is to protect the consumer’s right to have access to products that are not harmful to their health and to protect nature.

To achieve this, the policy makes it mandatory to label cosmetics before they reach the local markets, control the manufacture, import, distribution and use of cosmetics that have chemicals and heavy metals harmful to human skin and health. Market raids or inspections are conducted to maintain the standards of cosmetics according to the rules.

The gazetted law sets out the labelling procedure for all the prohibited and regulated chemical substances and heavy metals. The law also dictates which exact words that should be used on the labels of products that contain certain chemicals. Furthermore, it sets limits concerning the use of certain chemicals and heavy metals in cosmetic products and their residue traces.

The law further provides a list of prohibited and regulated chemicals and heavy metals. The use of some common heavy metals in cosmetics has been prohibited (such as Mercury, Lead, Nickel). Some chemicals have been regulated by providing a limit of the chemicals to be used in a product (such as Hydroquinone is limited to 0.3% as colouring agent and 0.2% in artisan nail system).

The law also opens the opportunity to regulate markets and conduct awareness-building programmes. The Ministry of Health along with the help of the Rwanda Standards Board (RSB) and The Rwanda Food and Drug Authority holds regular market supervision and helps to build awareness against the use of cosmetics that contain harmful chemicals.

The results of this regulation in Rwanda are positive as the government is trying to strictly follow the rules set forth in the Gazette to regulate the cosmetics market. The market inspections evidence considerable efforts in stopping the import and sale of cosmetics containing harmful chemicals. There are now difficult to acquire. However, some people, especially women, overlook the risks, using the black market to get their usual cosmetic, that may be listed as harmful.

To tackle this, the government of Rwanda and the Ministry of Health is also conducting several awareness-building and educational programmes such as the ‘black beauty’ campaign among retailers, manufacturers and consumers. Despite some shortcomings in the implementation in rural areas, the government of Rwanda is determined to implement the regulation as much as possible. This commitment is evident in the statement made by the Rwandan Police, that in 2020 alone, they confiscated around 13,596 units of skin-lightening products containing harmful chemicals in them; this number increased to 39,204 confiscated units in 2021. The Food and Drug Authority of Rwanda updates the list of products that are registered in Rwanda, on a regular basis, with the name of all the ingredients and the amounts of active chemical ingredients used in the cosmetic products. The authority also reviews the list and updates accordingly from time to time. There have also been recalls of products from certain companies that did not comply with the chemical and labelling rules laid in this law.

Bans on skin bleaching, whitening and other cosmetics containing harmful ingredients are not a new phenomenon in Africa. Countries like Ghana, Kenya, Ivory Coast, Uganda, Tanzania and South Africa have also taken similar steps against cosmetics with harmful chemicals. However, many of them do not reach as far or are not as strong in the implementation. The example of Rwanda may thus provide an example for further African countries, motivating them to implement similarly strong laws against these harmful cosmetics products, and to improve measures already taken.

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Fihlani, P. (2013). Africa: Where black is not really beautiful. BBC. https://www.bbc.com/news/world-africa-20444798.

Kagabo, K. S. & Kaitesi, S. (2021). Embracing All Shades of Beauty. Teakisi. https://teakisi.com/embracing-all-shades-of-beauty/.