Posted on July 05, 2022.

Cosmetics Europe unveiled last week its recommendations to the European Commission as part of the public consultation on the targeted revision of the Cosmetic Products Regulation (CPR) [1]. The organization that represents the cosmetics industry at European level calls for the adoption of strong a regulation with the aim to foster a competitive cosmetics sector in the context of the environmental and digital transition.

In line with the objectives of the European Green Deal and of the Chemicals Strategy for Sustainability (SCCS), the European Commission is considering a modification of the European Regulation on Cosmetic Products (CPR). The revision would include, among other points: the Generic Risk Management Approach, the concept of essentiality [2], the definition of nanomaterials, product labelling rules, safety assessment and combination effects. The public consultation launched on this issue at the end of March was closed on June 21.

In its contribution to the public consultation, Cosmetics Europe laid down its recommendations , urging the European Commission to take a holistic approach to the revision process and see it in the overall context of various legislations stemming from the European Green Deal so that coherence and consistency across legislations can be ensured.

Cosmetics Europe says it fully supports the objectives of the Chemicals Strategy for Sustainability (CSS) of increasing the protection of health and environment, whilst boosting innovation and promoting EU competitiveness. However, the organisation recommends that any revision of the CPR should:

- foster a sustainable (globally) competitive cosmetics sector, entrepreneurship and innovation capacity;

- strengthen its science-based, proportionate, effective and efficient approach, addressing human and environmental safety in the interest of consumers, industry and authorities;

- acknowledge the long history of a high level of safety of European cosmetic products and keep, at its core, the principle of scientific safety-based risk assessment;

- remain the “Gold Standard” and international reference worldwide;

- maintain a level of regulatory burden achievable and manageable particularly by SMEs; and

- be future-proofed by introducing digital labelling provisions.

According to Cosmetics Europe, this notably involves maintaining a dedicated independent scientific committee for cosmetics safety assessment, and derogations to the concept of essentiality where safety the safety of cosmetics containing the concerned substances can be unambiguously demonstrated.

Furthermore, Cosmetics Europe also says an additional systematic safety margin for all cosmetic ingredients should not be introduced. "It is not necessary and would have significant negative impacts on practically all cosmetic products, consumer choice and public health, without a demonstrated positive effect on consumer safety," the organisation states.

Eventually, while welcoming the introduction of a horizontal definition of nanomaterials and mandatory digital labelling requirements, Cosmetics Europe asks the Commission to ensure enough time for the industry to transition.

The pevious week, the International Fragrance Association (IFRA) raised concerns about the consequences of the European Commission’s strategy for the sustainability of chemicals. A new study, commissioned by the fragrance industry trade association, suggests a negative impact on the industry of up to EUR 2 billion per year.

Footnotes

[1] Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products

[2] According to the essentiality concept, certain substances of concern should be banned as soon as their use is not essential. It would be a faster approach than the risk-based approach that is currently in force. Certain substances could thus be prohibited provided there are alternatives.

Original Post: Cosmetics Europe calls for a science-based cosmetic products regulation