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COSMED

COSMED aims at defending and promoting the interests of SMEs in the cosmetic industry, in France, in Europe and abroad within public authorities, political representatives and professional authorities related to the cosmetic industry.

Lobbying Activity

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

15 Jan 2026 · Cosmetics, chemicals policy

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

2 Dec 2025

COSMED welcomes the possibility to comment on the proposal which aims to strengthen the governance of ECHA. We fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is also essential to keep an efficient process ensuring a high level of protection of human health and a well-functioning internal market. Cosmed support the reallocation of SCCS under ECHA as a standalone committee, in charge of cosmetics, while maintaining its independence and unique expertise. However, in the context of this reallocation, COSMED highlight important consideration detailed in the attached document
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Response to Circular Economy Act

6 Nov 2025

COSMED fully supports the ambition of the Circular Economy Act to boost EU competitiveness while accelerating the shift to more sustainable production, circular models, and decarbonisation. However, we would like to stress that the transition towards a circular economy must be pursued without losing sight of the health and safety considerations specific to certain sectors. By way of illustration, the proposed Packaging and Packaging Waste Regulation (PPWR) establishes requirements and minimum targets for the incorporation of recycled materials in packaging. This objective is also of strategic importance to the cosmetics sector. Nevertheless, the use of recycled materials continues to raise substantial challenges in terms of packaging safety, quality assurance, traceability and supply availability.. It is therefore essential to design a supportive and coherent legislative framework, one that moves beyond prescriptive or dogmatic approaches and instead promotes the deployment of practical instruments, incentives, and a recognition of the diverse levers available to advance circularity. This is particularly pertinent in the context of recycled plastics. A key challenge remains the limited availability of recycled plastic of sufficient and consistent quality, which is necessary to enable companies, particularly small and medium-sized enterprises (SMEs), to meet circularity targets without compromising product safety. Accordingly, it is imperative that the European Union strengthens investment in the recycling industry within Europe and formally recognises chemical recycling as relevant in the calculation of recycled content. Supporting both mechanical and chemical recyclers will be critical to achieving a circular economy that safeguards health and safety while fostering industrial resilience and innovation. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 1000 members, in France and Europe. COSMED is involved in the development of cosmetic regulations, as well as in national and international standardisation bodies as the voice of cosmetic SMEs.
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Response to Revision of the 'New Legislative Framework'

7 Aug 2025

COSMED is the French cosmetic association for SMEs, with over 1000 members. Please find our position paper attached.
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Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market

7 Aug 2025

COSMED is the French cosmetic association for SMEs, with over 1000 members, in France and Europe. Please find our Position Paper attached.
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Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

Since its application in 2013, the CPR has continuously demonstrated its performance in achieving those 2 objectives and CPR is still considered as the global standard for international cosmetic regulations. We emphasize that CPR is the only regulation requiring a safety assessment of every product placed on the market. The methodology for assessing product safety under the responsibility of qualified toxicologists is robust, highly protective and consider specific product usage and exposure as defined in Annex I of Cosmetic Regulation. Substances risk assessment is deeply rooted in the philosophy of the Cosmetic Regulation, and is based on the experience of the SCCS, an independent committee, whose knowledge and experience on the use of alternative methods is internationally recognized. To maintain technical excellence and ensure a common level in risk assessment, SCCS Notes of guidance for the testing of cosmetic ingredients and their safety evaluation is a tool published by the SCCS and continuously updated to include the latest developments. The effectiveness of this safety assessment has been confirmed in the report of the Commission of 7 november 2018 following a review of CPR as regards endocrine disruptors. The report concluded that the Cosmetics Regulation provides the adequate tools to regulate the use of cosmetic substances that present a potential risk for human health and to take the appropriate regulatory measures based on a scientific assessment of available data concerning human health. Considering the future, new challenges will have to be addressed in terms of process with the expected increase of substances classified as CMR, and endocrine disruptors. In line with the risk-based approach of the CPR, safety must be assessed for these substances, considering both use and exposure. The existing provisions of the CPR allow for amendments in the light of scientific progress and will enable to put in place a viable and robust process in terms of generic risk management of such substances. The European Union is the world's leading exporter of cosmetics. In the current economic context, maintaining a high level of R&D and innovation capacity remains crucial. In the light of the ban on animal testing in the CPR, we stress the need to increase the acceptance of NAMs for the development of new ingredients. We also underline the importance of supporting SMEs in their R&D activities In addition, certain new trends and technologies should be included in the CPR. In particular digital labelling should be recognised as a real opportunity to improve communication with the consumer and to reduce and lighten the packaging. It is also necessary to further clarify the framework for the sale of products without packaging, in order to give economic operators greater clarity for the development of this concept, in line with the environmental objectives aimed at reducing packaging. The distinction between CPR and other chemicals legislation remains essential but greater consistency is needed to ensure that sectoral specificities are addressed when defining horizontal restrictions. Appropriate exposure level and relevant application timeline must be considered to avoid any disproportionate and unrealistic requirements. While the CPR framework has allowed to ensure a harmonised European market over the last 15 years, by defining common rules to be applied uniformly across all EU countries, consistency needs to be guaranteed to prevent national divergences in the implementation and interpretation of the rules, which have a significant impact on SMEs. In addition, challenges remain to better control imported products and to ensure they only enter EU market if compliant. To this end, there is still room for improvement to support customs control of importers and products entering the EU market and solutions could be envisaged with CPNP portal. COSMED is the French cosmetic association for SMEs, representing SMEunited.
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Meeting with Sandro Gozi (Member of the European Parliament)

4 Feb 2025 · Cosmetics

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Please find enclosed the contribution of Cosmed, the cosmetic association for SMEs.
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Response to Improving access to and availability, sharing and re-use of chemical data for the purpose of chemical safety assessments

4 Apr 2024

COSMED, the French Cosmetic Association for SMEs, supports the main objective of the OSOA package. We however would like to draw attention on some key elements (definition, relevance of data, use of NAMs, study notification, confidentiality, access and use of data). Regarding the re-attribution of scientific and technical tasks to the ECHA, the best available expertise should be used. We then insist again that the SCCS (with internationally recognized expertise in risk assessment of cosmetics, especially without animal data use) should remain in charge of the safety assessment of cosmetics, as a standalone committee within ECHA. Please find our detailed contribution attached.
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Response to Ensuring that hazardous chemicals banned in the European Union are not produced for export

31 Jul 2023

COSMED warns on the disproportionate consequences that such intention could have in harming EU industries global competitiveness and more specifically SMEs in the event the manufacture and export of cosmetic substances and products would be prohibited without proper risk assessment while authorized outside EU. In contrast, COSMED will support any initiative at EU level aimed at stimulating cosmetic market to develop safe, sustainable and efficient alternatives, to strengthen the credibility and values of EU cosmetic industry while avoiding export ban that would be damaging to the social economy, the environment and even the safety of workers. Please find our full contribution in attachment.
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Response to Environmental claims based on environmental footprint methods

19 Jul 2023

First of all, COSMED supports overall objectives of the Green Claim Directive to protect consumers and companies against greenwashing. However, we alert on the need to maintain a rationale balance to avoid disproportionate burden on companies and especially on SMEs and to leave the possibility for SMEs to make voluntary environmental claims in an accessible way. The approval process must distinguish environmental claims that companies should demonstrate based on relevant and robust data versus environmental label that would require specific certification scheme. Any evaluation and scoring methodology to assess product environmental footprint must be sector specific considering the significant and relevant impacts of a sector. In addition, COSMED advocate an EU harmonized framework to keep the single market principle effective and alert on the need for realistic timeline to allow the implementation of the new rules. Please find enclosed our full input in attachment.
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

COSMED confirms that Cosmetic SMEs remain engaged to achieve the objectives of the green deal and further improve the sustainability of cosmetic products. However, considering all ongoing initiatives we insist on the need to wait for the implementation of these other initiatives and for industry proposals before updating the impact assessment and setting additional requirements for cosmetics. Please find COSMED contribution in attachment.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

21 Apr 2023

COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the proposal for a regulation on packaging and packaging waste. First of all, COSMED support this proposal for a regulation on packaging and packaging waste to harmonize rules in European Union and to move towards a more circular economy. Cosmetic SMEs are strongly committed to reduce packaging and packaging waste and share the ambition of the circular economy action plan. However, COSMED highlight that obstacles prevent the achievement of some objectives and stress that consideration on feasibility, operational reality, maturity of the market and technologies, and impact shall be taken into account to adapt some targets especially considering SMEs situation. Please find our contribution in attachment
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

30 Mar 2023

COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the revision of the CLP regulation. COSMED welcomes the initiative to simplify the legal framework of chemicals but warns the Commission of the counterproductive effects of certain measures leading to overcomplexity and administrative overload for the industry, impacting even more SMEs, without any benefit for the health of consumer nor the environment. Thus, COSMED calls for: - An adapted, scientific and proportionate approach to the classification of multi-constituent substances, which would allow the use of relevant available data on the substance itself. - The recognition of the complexity of natural extracts and essential oils rather than an over simplification of the rules for classification which would lead to significant negative impact on the use of naturals in consumer goods, without benefit for the consumer nor the environment. - Avoiding the fragmentation with the UN GHS. - The need for a structured and transparent process for a reassessment of harmonized classifications, that could be initiated by individual companies or groups of them. Please find attached our detailed position.
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Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

COSMED, the french cosmetic association for SMEs welcome the opportunity to comment on the Revision of the Urban Wastewater Treatment Directive. Please find COSMED input enclosed.
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Response to Introducing new hazard classes–CLP revision

18 Oct 2022

COSMED and the Essential Oil Consortium thank the European Commission for the opportunity to provide comments on the draft act, which introduces new hazard classes and criteria for classification, labelling and packaging in the regulation (EC) N°1272/2008. Our position regarding the definition and classification criteria is detailed in the attached document.
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Response to Proposal for a basic regulation of the European Chemicals Agency

10 Oct 2022

COSMED welcomes the possibility to comment on the proposal which aims to adjust the mandate and structure of ECHA. We embrace the objective of the CSS and fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is essential to keep an efficient process ensuring a high level of protection of human health and the environment and a well-functioning internal market. This is why the expertise, experience and independence of the Scientific Committee on Consumer Safety (SCCS) in assessing specific risks for cosmetics and in considering alternative methods principles should be kept for cosmetics. Please find our detailed comments in the attachment.
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

10 Apr 2022

Cosmed is the French cosmetic association for SMEs, a non-profit seeking association with over 960 members, in France and Europe. Please find our full contribution in attachment.
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Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

29 Oct 2021

COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 930 members, in France and Europe. Please find our full contribution in attachment.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

COSMED welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. Please find our full contribution in attachment. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 920 members, in France and Europe
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

COSMED welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. Please find our full contribution in attachment. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 920 members, in France and Europe.
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