Cosmetic Toiletry and Perfumery Association
CTPA
Representing all types of companies involved in making, supplying and selling cosmetic and personal care products, the Cosmetic, Toiletry and Perfumery Association Ltd.
ID: 121080737200-72
Lobbying Activity
Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation
29 Oct 2021
• Generic Risk Approach (GRA) should be implemented and used appropriately, in a way which is specific for cosmetic products. CTPA supports the objective of the CSS, to ensure a high level of safety for human health and the environment, and achieving this objective does not require automatically banning substances with demonstrably safe use within cosmetic products. An incorrect application of the GRA could lead to substances being banned based on an isolated hazardous property, or based on inappropriate grouping of substances which do not share exactly the same properties.
• The CPR is still seen as a gold standard in many areas of the world; however, taking an approach which introduces the possibility to ban safe ingredients due to hazard considerations could compromise the regulatory reputation of the EU in other global markets.
• The animal testing ban under the CPR must not be compromised. Implementing a ‘One Substance/One Assessment’ approach under the CPR would not be feasible, as industry would not be allowed to use certain data from animal testing for the scope of the specific sectorial safety and risk assessment. This could compromise our ability to use important and safe ingredients because they have been subject to animal testing, not just at EU level but also within the UK and other international markets.
• CTPA and the UK cosmetics industry strongly support the maintenance of the SCCS and its independent, risk-based approach for management and assessment of the safety of cosmetic ingredients, which is very specific.
• CTPA and the UK cosmetics industry support the harmonisation of the definition of nanomaterial.
• CTPA and the UK cosmetics industry support the implementation of a digital label that would allow consumers to have access to part of or all the labelling information online.
• From the perspective of a third country whose main trade partner is still the EU, changing the way cosmetic ingredients are assessed for safety and risk management will cause a remarkable impact to trade. Some companies within the UK who may want to continue to sell in the EU market, as well as companies within the EU who may want to continue to sell to the UK market, may not be able to sustain the development of duplicate products as well as duplicate supply chains as a consequence of the need to develop completely separate product due to the different ingredients requirements. This will have negative economic effects in both the EU and UK, and reduce consumer choice.
• Increased difficulties for EU companies to trade their products with the UK and other international markets will also arise from having a separate formulation that does not perform as efficiently as those manufactured elsewhere, which are still safe, means a reduced attractiveness of EU products to third country markets, including the UK. Reducing EU exports of cosmetic products to international markets can significantly impact the EU economy and the success of the EU cosmetics industry.
• The legal basis provided for under trade agreements, such as the UK/EU Trade and Cooperation Agreement, shall be taken into account in regard to future cooperation between the EU and the UK and possible TBTs that could arise and compromise trade.
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