ASOCIACION NACIONAL DE PERFUMERIA Y COSMETICA

STANPA

Representacion de los intereses colectivos del sector de perfumeria y cosmetica en España

Lobbying Activity

Meeting with Cristina Maestre (Member of the European Parliament)

27 Jan 2026 · Lavander

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

Stanpa, representing over 300 cosmetics companies in Spain, supports the European Commissions initiative to evaluate the Cosmetic Products Regulation (CPR). This regulation has ensured consumer safety, promoted innovation, and maintained the competitiveness of the European market. Strengths of the Regulation Consumer Safety: The CPRs risk-based approach effectively guarantees high safety standards, with an extremely low number of serious incidents. Industry Growth and Competitiveness: The European cosmetics sector leads globally, with a market value of 96 billion in 2023 and exports exceeding 33 billion in 2024. Innovation: While R&D investment is significant, excessive reformulation requirements not based on scientific risk assessment divert resources from true innovation. Harmonization and Global Competitiveness: The CPR serves as a global benchmark, allowing European companies to compete internationally. However, increasing regulatory burdens may threaten this leadership. Key Challenges and Areas for Improvement 1. Ingredient Management and Safety Assessments The shift from a risk-based to a hazard-based approach threatens regulatory stability. Methods such as worst-case scenarios, grouping, and extrapolations create unjustified concerns over safe ingredients. A science-driven, exposure-based safety assessment must be maintained, alongside promoting non-animal New Approach Methods (NAMs). 2. Article 15: CMR Substances and the Burden of Proof The automatic ban on CMR-classified substances prevents their use, even when proven safe in cosmetics. The exemption process is resource-intensive, unclear, and lacks sufficient time for dossier preparation. Greater clarity and coordination between the SCCS and the European Commission are needed to streamline evaluations. 3. Regulatory Complexity and Overlaps Increasing regulatory burdens impact SMEs, reducing their R&D investment capacity. A regulatory impact assessment is necessary to minimize redundancies and improve efficiency. 4. National Labeling Initiatives and Market Fragmentation Divergent national labeling requirements create trade barriers and administrative burdens. Reinforcing harmonization and promoting digital labeling solutions is essential. 5. Combating Counterfeiting Counterfeit cosmetics pose significant health risks, yet the CPR lacks specific measures to address them. Enhanced coordination between market surveillance authorities and mandatory traceability mechanisms are needed. The Role of Cosmetovigilance Data from Spains Cosmetovigilance system confirm the high safety of cosmetics, with very few serious adverse effects reported, validating the effectiveness of the CPRs risk-based model. Conclusion The CPR remains a robust and effective regulatory framework but requires targeted adjustments to address emerging challenges. Stanpa urges the preservation of risk-based assessments, reduction of regulatory complexity, harmonization of labeling, and stronger anti-counterfeiting measures to ensure continued consumer safety and industry competitiveness.
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Response to European Water Resilience Strategy

3 Mar 2025

STANPA, the Spanish National Association of Perfumery and Cosmetics, represents more than 400 companies, accounting for over 90% of the sector in Spain. As a key industry player, STANPA welcomes the European Commissions initiative to develop a European Water Resilience Strategy and appreciates the opportunity to contribute to this important discussion. Water is a strategic resource for the cosmetics industry, playing a fundamental role throughout the entire value chain, from ingredient sourcing and formulation to the final use of products. Given the increasing impact of climate change, particularly in the Spanish Mediterranean regions where over 55% of Spains cosmetics sector is concentrated, water scarcity and extreme weather events pose significant challenges. Addressing these issues requires an urgent and integrated approach to water management that ensures both environmental sustainability and industrial competitiveness. Recognizing the importance of water conservation, the Spanish cosmetics sector has been actively engaged in developing innovative solutions to optimize water use. Companies are investing in sustainable ingredient sourcing, the development of biodegradable formulations, and more efficient water management practices in manufacturing. Industry-driven initiatives, such as COSMEAU and COSME WATER FOOTPRINT projects funded with public funds, have provided valuable insights into water consumption patterns and have enabled businesses to improve efficiency while minimizing their environmental impact. These projects have also fostered collaboration with key stakeholders to enhance technological innovation in water management. From a regulatory perspective, STANPA emphasizes the need for a coherent and harmonized legislative framework at the EU level. Water-related policies should align with the overarching Water Framework Directive, ensuring a balanced approach that protects water resources while allowing businesses to operate competitively within the internal market. In this regard, the revision of the Urban Wastewater Treatment Directive (UWWTD) presents a critical challenge. The current Extended Producer Responsibility scheme places a disproportionate financial burden on the cosmetics and pharmaceutical industries to fund wastewater treatment upgrades. While the cosmetics sector is committed to contributing to water sustainability, STANPA strongly advocates for the fair application of the Polluter Pays Principle, ensuring that all sectors responsible for water pollution are held accountable based on robust scientific assessments. On top of that, it is critical in order to ensure an harmonize implementation of the Directive across the 27 Member States, the Commission to publish a list of water micropulluntants present in water after the tertiary treatment. Moreover, securing public and private investment is crucial to advancing water reuse, infrastructure improvements, and R&D in water-efficient technologies. Given Spains status as one of the most water-stressed countries in Europe, EU support for such initiatives is essential to guarantee long-term water resilience. In conclusion, STANPA fully supports an ambitious and coordinated EU Water Resilience Strategy that fosters regulatory clarity, scientifically sound environmental policies, and collaborative efforts between public and private stakeholders. The Spanish cosmetics industry remains committed to working with EU institutions to develop practical and effective solutions that contribute to a sustainable and water-resilient future.
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Meeting with María Soraya Rodríguez Ramos (Member of the European Parliament)

29 Nov 2023 · Extended producer responsibility - cosmetics sector