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Beiersdorf

Beiersdorf steht seit über 140 Jahren für innovative Hautpflege und wegweisende Hautforschung.

Lobbying Activity

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and Procter & Gamble and

27 Jan 2026 · Omnibus VI

Response to Proposal for a basic regulation of the European Chemicals Agency

26 Nov 2025

As part of the European Commissions initiative to establish a Basic Regulation for the European Chemicals Agency (ECHA), we wish to express our strong support for maintaining the Scientific Committee on Consumer Safety (SCCS) as an independent, sector-specific expert body within the future structure of ECHA. The SCCS has built a unique and internationally recognized expertise over more than four decades in the safety assessment of cosmetic ingredients and products. Its work is guided by the principles of scientific excellence, independence, and transparency, and its opinions are not only foundational to EU regulatory decisions but also serve as benchmarks in regions such as ASEAN and Latin America, facilitating global trade and regulatory alignment. We fully endorse the positions articulated by Cosmetics Europe and the German Chemical Industry Association (VCI) in the context of this consultation. The scientific integrity and independence of the SCCS must be preserved in any future structure. This includes maintaining its fundamental working methods, such as the practice of appointing the chair from among its members and ensuring that its members are selected based on highly specialized qualifications. In addition to the criteria outlined in Article 14(5) of the proposed regulation, SCCS members should possess additional expertise in key areas critical to modern safety assessment, including: Grouping and clustering of substances Safety assessment of nanomaterials Computational toxicology Exposure assessment At least two members should meet each of these individual qualification criteria to ensure the committee remains at the forefront of scientific innovation and regulatory relevance. This level of specialization is essential for the SCCS to continue developing and applying state-of the-art safety assessments such as New Approach Methodologies (NAMs) and Next Generation Risk Assessment (NGRA), which are vital for application of non-animal testing under the Cosmetic Products Regulation. Any reassignment of the SCCSs responsibilities must preserve its sectoral focus and scientific autonomy. We therefore advocate for the SCCS to remain a standalone committee within ECHA, composed of qualified experts in cosmetic safety, and operating under a governance model that ensures independence from broader chemical risk committees such as the Risk Assessment Committee (RAC) and Committee for Socio-Economic Analysis (SEAC). This structure would support the One Substance, One Hazard Assessment (OSOA) approach while allowing for sector-specific risk assessments that reflect real-world use and exposure scenarios. In conclusion, the SCCSs continued high level of qualification, expertise, independence and sectoral specialization are essential not only for regulatory coherence but also for the competitiveness and innovation capacity of the European cosmetics industry. We urge the European Commission to uphold these principles in the final design of the ECHA Basic Regulation.
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Meeting with Peter Liese (Member of the European Parliament) and Cosmetics Europe

18 Nov 2025 · Austausch

Meeting with Dennis Radtke (Member of the European Parliament)

24 Sept 2025 · Rolle der Kosmetikindustrie in der europäischen Wirtschaft

Meeting with Florika Fink-Hooijer (Director-General Environment) and L'Oréal

18 Mar 2025 · The Value of Beauty Alliance Event

Response to Commission Roadmap to phase out animal testing

13 Oct 2024

Beiersdorf welcomes the opportunity to comment on the European Commissions call for evidence on the roadmap to phase out animal testing in chemical safety assessments. Beiersdorf highly appreciates the European Commissions ambitions on the abolishment of animal testing beyond cosmetic products across legislative frameworks and Member States. The cosmetics sector is a key contributor to non-animal methods, such as with the International Collaboration on Cosmetics Safety (ICCS). As a developer, user and advocate of non-animal methods, Beiersdorf understands the time and resources required for the development and validation of new test methods. Through the dedication and commitment from all stakeholders, the EU cosmetics regulation exemplifies how new test methods can be applied and chemical safety assessment can be accepted without the use of animal testing. 1. Beiersdorf calls on the European Commission to assure a holistic and systematic approach for the roadmap, with acceptance of models and risk assessment frameworks rather than a focus and reliance on the validation of individual assays. Successful implementation of the roadmap depends on how results of non-animal methods, even if not all officially validated, can be applied and used in practice across legislative frameworks beyond the EU cosmetic products regulation. 2. We request the European Commission assess the skills and resources needed to support the science with education, training, and certification. As highlighted in the roadmap, the regulatory context must consider the expertise needed for performing and evaluating safety assessments with the new approaches of using non-animal methods. For instance, under the EU Cosmetic Products Regulation, there are qualification requirements for the safety assessor with courses available on the use of non-animal methods. 3. We would like to underpin the necessity for a high level of scrutiny to be applied to ensure regulatory authorities and agencies can accept the new approaches and methods. The Commission initiative therefore impacts Member State authorities as well as EU agencies with regards to the steps and procedures for decision-making at the EU level.
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Meeting with Stefan Köhler (Member of the European Parliament)

19 Sept 2024 · Politischer Austausch

Meeting with Oliver Schenk (Member of the European Parliament)

19 Sept 2024 · UWWTD

Meeting with Svenja Hahn (Member of the European Parliament)

8 May 2024 · Exchange on current affairs

Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

2 Apr 2024

Currently, various agencies and scientific committees provide advice and risk assessment to the Commission due to the diverse uses of substances and chemicals, leading to different laws and agencies responsible for their assessment. This approach of conducting risk assessments under specific legislation makes sense but can result in conflicts when the hazard assessment is not aligned or conducted simultaneously. In principle, we welcome to standardize hazard identification and progress towards a unified hazard assessment of substances. However, we like to emphasize that hazard assessment must be only the first step to regulate the use of substances. In contrast, risk assessments are the essence to protect the EU consumer and should be at the focus of regulatory agencies. Risk assessment must remain the primary criterion for decision-making because it involves evaluating practical and realistic product exposure situations. Any harmonization that concentrates solely on a hazard-based approach is not considered state-of-the-art in risk assessment. For instance, it would ignore the state of cosmetic risk assessment science proven successful over several decades. Scientifically unsound hazard-based bans could ultimately lead to less consumer product choices without improving consumer protection. Our stance is in favor of enhancing the efficiency, effectiveness, and consistency of safety evaluations under EU regulations. However, we want to emphasize that if the SCCS is re-allocated to ECHA, it should preserve its exceptional and distinctive knowledge and input to regulatory decision making in the safety assessment of cosmetic ingredients and products, which has been developed and successfully practiced over four decades. This can only be accomplished if the SCCS is maintained with absolute independency. It is imperative to emphasize that any strategies for executing the OSOA must respect that cosmetic ingredients cannot be subjected to animal testing. The reduction of administrative workload should never take precedence over our obligation to prevent animal testing by adopting a centralized approach, Beiersdorf believes that safety standards can be upheld, and risks can be managed effectively. We welcome the idea develop a common open data platform on chemicals to facilitate the sharing, access and re-use of information on chemicals coming from all sources and call for a state-of-the-art interface to share information between industry and authorities. We would like to emphasize the significance of having a system in place to verify the strength of the data prior to incorporating it into a common data platform. An OSOA approach could identify reference values, such as a "no observable adverse effect level," which could serve as the starting point for risk assessment specific to the sector. However, it is crucial that all relevant committees, including SCCS, are involved in the decision-making process regarding these reference values. We highly welcome the establishment of a new database containing information on regulatory processes on individual substances or groups of substances that are planned, ongoing or have been completed. To facilitate the use of such a platform as much as possible, the data should be provided via an application programming interface (API) as well. Harmonization of the substance assessment framework should also entail New Approach Methods and Next Generation Risk Assessment to become the cross-sectorial standard. Coordinated exchange of information and acceptance between agencies can speed up the assessment process, improve its quality, and prevent avoidable animal tests. We call for maximizing the use of NAMs to generate new data and sharing best practice on the use of such data for regulatory decision-making. A re-allocation of the work of the SCCS to ECHA could nevertheless also represent the opportunity to promote risk assessment methodologies based on non-animal data in chemical regulation.
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Meeting with Florika Fink-Hooijer (Director-General Environment) and L'Oréal and International Flavors & Fragrances

31 Jan 2024 · Short speech connecting the topic of cosmetics with environmental aspects at the “Value of Beauty” launching event.

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

31 Jan 2024 · Participating to launching event of the Value of Beauty Alliance representing the cosmetics sector value chain