Cosmetics destruction, cleaning and chemical product disposal

What is cosmetics destruction?

Cosmetics destruction is the controlled withdrawal of unsellable cosmetics, cleaning and chemical products from the market and their destruction or recycling at a licensed facility. Expired, damaged, quality-defective and recalled products all fall within this scope, because cosmetic products can contain flammable, toxic and explosive substances. Scrap runs cosmetics destruction in line with environmental regulation and documents every step from collection to the destruction minutes.

Handing an expired product to the bin is uncontrolled disposal. In many cases the product does not stay there: someone collects it, repackages it and sells it. We explain how this risk arises in our article on uncontrolled disposal, and why an expired cosmetic cannot stay in sales stock in our article on expired cosmetics.

Which cosmetic, cleaning and chemical products are destroyed?

Any cosmetic, cleaning or chemical product that is expired, damaged, quality-defective or recalled falls within the scope. These are the groups we meet most often:

• Skin care and make-up products: creams, moisturizers, make-up and similar items.
• Hair, perfume and oral care products: shampoo, styling products, perfume, fragrance, and mouth and dental care products, destroyed under notary supervision.
• Hygiene and disinfectant products: these can be flammable or toxic, so they require controlled destruction.
• Surface, dishwashing and laundry products: surface and area cleaners, dishwashing and laundry products.
• Consumer and construction chemicals: chemical groups destroyed at licensed facilities.
• Special-purpose and agricultural chemicals: specific-purpose chemicals and agricultural chemicals.

Cosmetics destruction methods

We choose the method after analyzing the product’s flammable, toxic or explosive properties.

Biological decomposition also applies to suitable batches. The outcome is written item by item in the destruction minutes.

Legal basis of cosmetics destruction

Cosmetics destruction touches environmental, product and tax legislation at the same time, so we set up the process with all three in mind.

• Environment: the Environmental Law No. 2872 and the Waste Management Regulation require waste to be collected separately, recorded and sent to a facility holding a permit or environmental license. For this reason we destroy products only at licensed facilities.
• Product: the Cosmetic Products Regulation requires the distributor to verify, before making a product available on the market, that its minimum durability date has not passed. An expired product therefore does not stay in sales stock.
• Tax: Article 278 of the Tax Procedure Law provides that the value of goods whose worth has fallen significantly is set by the Valuation Commission. Article 278/A covers goods that must be destroyed because of spoilage, decay or expiry. The assessment and the destruction minutes are the basis for expensing the stock cost.
• VAT: Article 30/c of the VAT Law governs VAT on lost goods. For destroyed goods, the tax office and the Council of State hold different views; choose the route with your accountant once the documents are in hand. Details: VAT on destroyed goods.

Cosmetics destruction minutes and reporting

The destruction minutes are the official record of which product we destroyed, in what quantity, on what date and by which method. At Scrap the minutes come as part of a document set:

• the assessment record we complete together with the authorities,
• the licensed facility’s destruction records and the notary-certified, documented process,
• photo and video records of every batch,
• steps tracked throughout on the Online Tracking System,
• the Sustainable Transformation Report: recovery and carbon data that feed directly into your ESG reporting.

This set answers “was the product really destroyed?” with a single file, in tax audits and brand reviews alike.

Destruction after a cosmetics recall or market withdrawal

A recall and a market withdrawal are not the same thing. A recall aims to bring back the product that end users hold; a withdrawal stops the product inside the supply chain. In most cases the two run together. Under the Cosmetic Products Regulation, the responsible person who finds a product non-compliant takes corrective measures immediately, and informs the Turkish Medicines and Medical Devices Agency if the product poses a risk to human health.

When the product cannot be made safe, destruction becomes unavoidable. In that case the Agency may destroy it in part or in full, and the economic operator pays the costs. Collected product that becomes waste falls under the Waste Management Regulation. We separate the batch by the batch or serial number on the label, keep the returned product apart from sales stock, and move it in sealed vehicles to a licensed facility, so the product never returns to the market. See the steps in our recall and disposal article.

How cosmetics destruction works with Scrap

The process starts with the request form. We first analyze the flammable, toxic or explosive properties of your products, then present the proposal. We file the official applications and book the appointments. Then we move the products in sealed ADR vehicles to a facility licensed by the Ministry of Environment, where we destroy them by neutralization, incineration or chemical conversion, or recycle them. Typical duration is about 21 business days. At the end you receive the minutes, photo and video records and the Sustainable Transformation Report; for every cosmetics destruction project a tree is planted and a child joins a nature education programme. Label and logo packaging disposal, which protects your brand, is part of the same flow.