OpenLobby.EU
Explore

Cosmetics Europe

Cosmetics Europe represents the cosmetics and personal care industry in Europe, working with EU institutions to achieve balanced policies that encourage innovation and support a competitive industry serving consumer needs.

Lobbying Activity

Meeting with César Luena (Member of the European Parliament)

26 Jan 2026 · Chemicals Omnibus

Meeting with Paul Speight (Head of Unit Environment) and PETA Science Consortium International e.V. and The European Federation for Cosmetic Ingredients AISBL

22 Jan 2026 · The CE – EFfCI Joint Position on Animal Testing Under EU REACH

Meeting with Christophe Clergeau (Member of the European Parliament, Rapporteur) and European Chemical Industry Council and

3 Dec 2025 · ENVI - ECHA

Cosmetics Europe supports ECHA reform, seeks to preserve independent safety committee

2 Dec 2025
Topic — Proposal to strengthen ECHA governance and transfer the Scientific Committee for Consumer Safety.
Message — The organization supports moving the Scientific Committee for Consumer Safety to ECHA but insists it must remain a stand-alone committee with preserved independence, expertise, and procedures. They want the chairperson elected by members, not appointed, and explicit recognition of nanomaterials safety expertise. They also seek a stronger ECHA role in promoting non-animal testing methods.1234
Why — This preserves their access to specialized cosmetics safety expertise while advancing non-animal testing methods.56
Read full response

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur) and International Fragrance Association

28 Nov 2025 · Chemicals omnibus - CRM and Cosmetics Regulation

Meeting with Peter Liese (Member of the European Parliament) and Beiersdorf

18 Nov 2025 · Austausch

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

13 Nov 2025 · Chemical omnibus - Cosmetics Regulation

Meeting with Jeannette Baljeu (Member of the European Parliament)

7 Nov 2025 · Chemicals omnibus

Meeting with Hans Ingels (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

6 Nov 2025 · Presentation of the Cosmetics Europe position in relation to the developments related in particular to the Commission Proposal on Simplification Omnibus VI on Chemicals

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

6 Nov 2025 · Simplification

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

6 Nov 2025 · Environmental Omnibus

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

30 Sept 2025 · Omnibus on Chemicals proposal, the upcoming REACH revision and the environmental omnibus.

Meeting with Eric Mamer (Director-General Environment) and

22 Sept 2025 · Urban Wastewater Treatment Directive, REACH revision, animal testing

Response to Revision of the 'New Legislative Framework'

2 Sept 2025

Cosmetics Europe welcomes the Commissions intention to revise the New Legislative Framework (NLF) to address market developments, circularity and digital changes, with the aim to reduce unnecessary regulatory burdens and market/regulatory failures. Through this contribution, Cosmetics Europe stresses in particular the need to adapt product information requirements to the 21st century through the promotion of digital information. Indeed, the European Commission identified this revision as an opportunity to facilitate the roll out of digital solutions such as the Digital Product Passport (DPP). Current horizontal and sectoral legislation require increasing product information to be communicated to consumers via the labels on packaging, while also mandating packaging minimisation. Consumer habits and preferences, as well as digital technologies, have significantly evolved over the last 10 years. The digital transition has become a global reality, integrated into daily life and the NLF in parallel with sectoral legislation must become able to respond to the changes in consumer habits and practices as well as the evolving communication technologies, and to anticipate future consumer information needs and the ways to address them. It is also essential to ensure coherence with existing legislation, such as the Ecodesign for Sustainable Products Regulation. The shift towards digital information will also help in addressing the negative impact on the environment and the legibility of on-pack labels. The only way to reconcile the increasing amounts of information with the reduced packaging, is to streamline on-pack labels by dematerialising certain information elements, accompanied by adequate transition provisions. Digital labels can also reduce financial and administrative burdens on companies by enabling them to swiftly update information and quickly adapt them to consumers, regardless of where they are in the EU. At the same time, they provide user-friendly experiences for consumers enabling them to access comprehensive information conveniently, in multiple languages and adapted to specific needs. Finally, it is also essential that the roll out of digital solutions for consumer and value chain information considers the international compatibility of consumer and digital information requirements.
Read full response

Cosmetics Europe urges flexible reporting on unsold consumer products

10 Jul 2025
Topic — This consultation specifies rules for disclosing information on discarded unsold consumer products.
Message — The industry recommends a risk-based verification approach instead of costly third-party audits. Companies need discretion when reporting preventive measures to protect confidential business data. They also propose aligning implementation deadlines to allow more time for data preparation.1234
Why — These changes reduce administrative expenses and safeguard proprietary operational information from competitors.56
Impact — Regulators and environmental advocates lose access to standardized data on product destruction practices.7
Read full response

Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

12 Jun 2025 · Urban Waste Water Treatment Directive

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Bertrand L'Huillier (Cabinet of Executive Vice-President Stéphane Séjourné)

5 Jun 2025 · Challenges faced by the European cosmetics industry and their impact on the competitiveness of the sector with the special focus on SMEs

Meeting with Denis Redonnet (Deputy Director-General Trade) and

4 Jun 2025 · In his mission letter Commissioner Maroš Šefčovič is tasked to “closely monitor the full enforcement of our trade agreements on market access and rules […]”.

Meeting with Emmanuelle Maire (Head of Unit Environment)

28 May 2025 · Proposal for the Directive on Green Claims

Meeting with Adam Jarubas (Member of the European Parliament)

21 May 2025 · Sytuacja sektora kosmetycznego w Polsce i Europie

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

19 May 2025 · discussions with Stanpa on Green Claims Directive

Meeting with Stefan Fuehring (Head of Unit Secretariat-General)

19 May 2025 · Exchange of views on the revision of the Regulation on the registration, evaluation, authorisation and restriction of chemicals (REACH) and or general simplification issues

Meeting with Laurence De Richemont (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

12 May 2025 · Exchange of views on the Commission’s simplification agenda

Meeting with Pietro Fiocchi (Member of the European Parliament) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien and Haleon

7 May 2025 · Tematiche ambientali

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

5 May 2025 · Challenges of the cosmetics industry

Meeting with Pablo Arias Echeverría (Member of the European Parliament)

22 Apr 2025 · Green Claims Directive

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

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

10 Apr 2025 · Impact of US tariffs

Meeting with Valdis Dombrovskis (Commissioner) and

9 Apr 2025 · Competitiveness

Meeting with Klaus Berend (Director Health and Food Safety)

7 Apr 2025 · Evaluation of ethanol under the Biocidal Products Regulation (BPR)

Meeting with Matthias Jorgensen (Head of Unit Trade)

1 Apr 2025 · Exchange of views on proposed EU countermeasures to US Section 232 tariffs on steel, aluminium, and derivative products

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

24 Mar 2025 · Implementation of the Urban Waste Water Treatment Directive (UWWTD), revision of the REACH Regulation concerning substances used in cosmetic products

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

Cosmetics Europe welcomes the evaluation of the Cosmetic Products Regulation (CPR) and looks forward to contributing to the process to ensure the European cosmetics and personal care industry can remain competitive, innovative, sustainable and a pillar of European excellence. The CPR has successfully met its primary objectives by ensuring a unique single EU market for cosmetic products and the safety of European consumers. The CPR has long been considered a gold standard and international reference worldwide, thereby fostering a globally competitive cosmetics sector and the current evaluation presents an opportunity to critically assess and potentially enhance the regulatory framework. The firm principles that are at the core of the CPR collectively contribute to a robust regulatory framework that protects consumers and ensures the high safety, quality and efficacy of cosmetic products in the EU market. These principles include a comprehensive risk-based framework, legally binding principles for claims, comprehensible and accurate labelling of cosmetic products, adherence to recognised Good Manufacturing Practices standards, and an efficient in-market control system. The CPR has traditionally been a model of risk-based, safety assessment, incorporating consumer exposure and best science. This foundational principle of the CPR must remain and possibly even strengthened. The evaluation should assess the current ingredients management processes, to ensure cosmetics manufacturers can continue to work in a clear and scientifically accurate risk-based environment that provides companies the required ingredients palette, as well as room to adapt, comply and further innovate. The CPR requires comprehensive consumer information to be physically labelled on packaging, while consumer habits and preferences, as well as digital technologies, have significantly evolved over the last 10 years. The digital transition has become a global reality, integrated into daily life. The evaluation is an opportunity to reflect on the future of consumer information under the CPR. The evaluation process should include a forward-looking approach that considers how to apply the valid principles of the CPR to recent policy developments, technological progress, digital advancements, scientific evolution, and fast-moving consumer expectations, to ultimately minimize regulatory burden for all companies and support the European cosmetics industry as a pillar of European excellence. Please see the attached file for further details on Cosmetics Europe position.
Read full response

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

18 Mar 2025 · Urban Waste Water Treatment Directive

Meeting with Dolors Montserrat (Member of the European Parliament)

17 Mar 2025 · Current situation of the cosmetic industry in the EU

Meeting with Emmanuelle Maire (Head of Unit Environment) and L'Oréal

7 Mar 2025 · Exchange of views on the Green Claims Directive (“GCD”) and the Bioeconomy Strategy

Cosmetics Europe Demands Revision of Wastewater Funding Rules

4 Mar 2025
Topic — The European Commission is developing a multi-annual strategy for water resilience.
Message — The industry calls for a revision of wastewater rules to ensure all polluters pay. They request a centralized list of micropollutants to streamline reporting and avoid burdens.12
Why — Shifting to a substance-based approach would lower financial liabilities for cosmetic firms.34
Impact — Other polluting industries would face new costs if funding is spread across more sectors.5
Read full response

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

25 Feb 2025 · UWTTD and others

Meeting with Michel Sponar (Acting Head of Unit Environment)

19 Feb 2025 · Discussion on the implementation of the recast Urban Wastewater Directive

Cosmetics Industry Urges End to National Trade Barriers

31 Jan 2025
Topic — The European Commission's 2025 strategy for strengthening the EU Single Market.
Message — The organization calls for shifting from directives to regulations to ensure consistent rules across all Member States. They recommend introducing a competitiveness check and a Single Market test for all new legislative proposals.123
Why — Harmonised rules would prevent costly production changes and reduce administrative burdens for smaller companies.45
Impact — National governments lose the ability to implement specific local consumer protection and environmental labels.67
Read full response

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

30 Jan 2025 · UWWTD, REACH

Meeting with Hans Ingels (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and International Fragrance Association

29 Jan 2025 · Increasing numbers of harmonised classification of substances as carcinogens, mutagens and reprotoxicants category 1B and consequences for cosmetic products

Meeting with Jessika Roswall (Commissioner) and

15 Jan 2025 · Exchange on implementation of the European Green Deal legislation including on chemicals regulation and REACH and Urban Waste Water Treatment Directive

Meeting with Patrick Child (Deputy Director-General Environment) and

9 Jan 2025 · Meeting on UWWTD, Classification of substances, Cumulative impact assessment exercise, REACH, Animal testing, ECHA funding, ESPR, Green Claims

Meeting with Massimiliano Salini (Member of the European Parliament)

9 Dec 2024 · REACH

Meeting with Marta Wcisło (Member of the European Parliament)

27 Nov 2024 · Discussing future of European cosmetics

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and Procter & Gamble

5 Nov 2024 · discussions on Green Claims Directive

Response to Commission Roadmap to phase out animal testing

14 Oct 2024

Cosmetics Europe welcomes the opportunity to contribute to the European Commissions roadmap to phase out animal testing in chemical assessments. Our contribution has been uploaded.
Read full response

Meeting with Christophe Clergeau (Member of the European Parliament)

10 Oct 2024 · Chemicals

Meeting with Andrey Novakov (Member of the European Parliament)

3 Oct 2024 · CLP Regulation / REACH Regulation

Meeting with Maria Grapini (Member of the European Parliament)

24 Sept 2024 · Standards Harmonization and Intellectual Property

Meeting with César Luena (Member of the European Parliament)

17 Jul 2024 · Cosmetics Regulation and REACH

Response to Environmental Implementation Review 2025

5 Jul 2024

Cosmetics Europe supports the objective of the EGD to enhance environmental protection and go towards a more sustainable economy and agrees that the Commission and the Member States must ensure that policies and legislation are enforced and delivered effectively to create a level playing field for businesses operating in the single market. Therefore, minimum binding requirements are necessary to ensure harmonization across the single market, especially when it comes to directives, in line with the Better Regulation initiative to simplify the regulatory framework and avoid disharmonized application of rules among Member States. Furthermore, as also outlined in this initiative regarding the Impact Assessments, it is fundamental to use robust data and sound scientific evidence for effective policymaking and to assess the cumulative impact of legislation and to systematically perform a competitiveness check in the context of the evaluation of any new policy initiative. Taking the example of the UWWTD and considering its ongoing recast, it is important to make sure that any new requirements are fit for purpose and the implementation at national level is ensured and practically workable. This piece of legislation being a directive implies the possibility for Member States to apply the various requirements in a more flexible manner. Nevertheless, it has to be ensured that clear rules are established for Member States to be able to reach the objectives so as to guarantee a harmonized implementation within the single market. The ongoing revision is lacking the minimum rules that would ensure a proper implementation of the EPR schemes by national authorities (e.g., a defined list of relevant substances to be considered as micropollutants to establish the costs for the producers and for monitoring purposes, the models for calculating the costs, collecting and distributing the fees, the setting up of PROs). Furthermore, since ultimately the implementation of the rules will have a cascade effect on the business landscape, it is worth highlighting that the underlying impact assessment did not properly evaluate the role of all sources, leading to an overestimation of the cosmetics and personal care sectors impact to the water pollution, and that the competitiveness check have largely underestimated the impact of new requirements on this sector (especially on SMEs) in terms of financial contributions to the EPR schemes. Another example concerns the P&PW legislation. Whereas the shift from a directive to a regulation is certainly a positive step towards a more harmonized framework and its implementation, free movement rules envisaged in the draft text raise concerns, nevertheless. Such rules leave the door open for Member States to adopt diverging sustainability and information requirements. The consequent fragmentation of the single market may lead to several unintended consequences such as product scrappage (companies will not be able to send unsold products to other Member State markets unless they can be re-packaged/re-configured); reduced flexibility in supply logistics; possible increase in packaging weight and volume to accommodate various national information requirements. Such scenarios could in turn lead to inefficiencies and additional packaging waste generation. Besides free movement rules, it is also worth noticing that the PPWR entails a significant implementation effort through over thirty secondary legislation measures, e.g., on minimum PCR plastic content or packaging minimisation. In light of such a complex regulatory landscape, the regulation should set clear end goals and provide a sufficient level of flexibility for companies on the means to achieve them. In doing so, the Commission should also ensure clarity on the interpretation of the primary provisions and clarify remaining uncertainties when developing secondary legislation, through a collaborative approach involving Member States and industry stakeholders.
Read full response

Cosmetics Europe demands safety committee autonomy in chemicals overhaul

2 Apr 2024
Topic — The consultation concerns improving chemical data sharing and re-allocating scientific tasks.
Message — The industry insists the Scientific Committee on Consumer Safety remains a stand-alone body. They also demand that risk assessment remains the primary basis for safety decisions.12
Why — This preserves specialized industry standards and prevents broader bans based only on hazard.3
Impact — Consumers lose out as safety evaluations become less precautionary and more complex.4
Read full response

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

8 Dec 2023 · Green Claims Directive

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

23 Oct 2023 · Packaging and packaging waste regulation, chemicals legislation

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and FoodDrinkEurope

12 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with César Luena (Member of the European Parliament)

12 Oct 2023 · PPWR

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Confederation of Finnish Industries EK

18 Sept 2023 · Green Claims

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

12 Sept 2023 · Green Claims Directive

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur) and Fern

7 Sept 2023 · PPWR

Cosmetics Europe warns export ban threatens industry competitiveness

31 Jul 2023
Topic — EU proposal to prohibit the export of hazardous chemicals banned within the European Union.
Message — The group supports restrictions on substances proven to pose an unacceptable risk through assessment. They oppose banning products based solely on hazard classification, arguing this ignores safe use and exposure.123
Why — Preserving risk-based assessments ensures the industry remains competitive and prevents the relocation of manufacturing.4
Impact — EU workers and regions lose as manufacturing shifts to areas with different safety requirements.5
Read full response

Cosmetics Europe urges harmonized rules and longer implementation timelines

18 Jul 2023
Topic — New EU rules requiring companies to scientifically substantiate their environmental claims.
Message — The industry requests a harmonized verification process and a 36-month implementation period. They also advocate for digital disclosure to protect sensitive business data.12
Why — Extended deadlines and digital summaries would minimize market disruption and compliance costs.34
Impact — Environmental rating apps and NGOs would face new, burdensome regulatory constraints.5
Read full response

Meeting with Daniela Rondinelli (Member of the European Parliament)

12 Jul 2023 · Various

Meeting with Martin Hojsík (Member of the European Parliament)

8 Jun 2023 · Classification, labelling and packaging Regulation, Cosmetics Regulation

Cosmetics Europe urges harmonisation and chemical recycling recognition

21 Apr 2023
Topic — The Commission is reviewing design requirements to reduce packaging waste across Europe.
Message — Cosmetics Europe seeks explicit recognition for chemical recycling to meet recycled content targets. They also advocate for harmonised labelling and flexibility in packaging design to prevent product standardisation.12
Why — These measures would protect brand identity while providing the industry with investment security.34
Impact — Member States would lose the power to implement specific national environmental labels.5
Read full response

Meeting with Pietro Fiocchi (Member of the European Parliament, Shadow rapporteur)

13 Apr 2023 · Urban wastewater treatment (recast)

Cosmetics Europe warns chemical rules threaten natural ingredients

30 Mar 2023
Topic — The European Commission is revising the classification, labelling and packaging rules for chemical substances.
Message — The industry requests that experimental test data take precedence over theoretical calculations for chemical classifications. They also demand that grouping substances for regulatory purposes be based on specific scientific evidence rather than structural assumptions.12
Why — This would prevent the automatic banning of numerous natural ingredients used in cosmetic products.3
Impact — Regulators would see a slower process for classifying and restricting groups of hazardous chemicals.4
Read full response

Cosmetics Europe demands fairer fees and narrower micropollutant definitions

14 Mar 2023
Topic — The European Commission is revising rules for urban wastewater treatment and infrastructure financing.
Message — The group wants a narrower micropollutant definition limited to substances requiring extra treatment. They advocate for a specific chemical list to ensure harmonized rules across Europe. They argue the financing scheme must target all polluters, not just cosmetic firms.123
Why — This would prevent the industry from paying fees that exceed their actual pollution impact.4
Impact — Other industrial sectors would face new costs if the financing scheme is broadened.5
Read full response

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Neste Oyj and

1 Mar 2023 · PPWR

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

26 Jan 2023 · Urban wastewater treatment

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

20 Dec 2022 · Ecodesign for Sustainable Products Regulation

Meeting with Alessandra Moretti (Member of the European Parliament, Rapporteur)

25 Nov 2022 · Framework for setting eco-design requirements for sustainable products

Cosmetics Europe urges non-animal testing in chemical safety rules

18 Oct 2022
Topic — The consultation concerns new hazard classes for the classification, labelling and packaging of chemicals.
Message — The organization wants the EU to include modern non-animal testing methods as supporting evidence for all chemical classifications. They propose a harmonized framework to ensure that animal testing is strictly used as a last resort.12
Why — Adopting these methods would allow the industry to avoid the costs and delays of animal testing.3
Read full response

Meeting with Thierry Breton (Commissioner) and

13 Oct 2022 · Overview of the situation of the European cosmetics industry, including in relation to the current energy crisis, and exchanges on upcoming legislative reforms affecting the cosmetics industry

Cosmetics Europe demands SCCS remain a standalone committee within ECHA

10 Oct 2022
Topic — A proposal to update governance and financing of the European Chemicals Agency.
Message — Cosmetics Europe insists the Scientific Committee on Consumer Safety must remain a standalone committee. This approach preserves specialized expertise and supports the continued development of non-animal testing methods.12
Why — Maintaining specialized committees ensures the industry remains competitive by avoiding slow review processes.34
Impact — The European industry suffers if discontinued review processes hinder placing products on market.5
Read full response

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

27 Sept 2022 · Implementation of the European Green Deal, in particular circular economy and chemicals policies

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

27 Sept 2022 · Implementation of the European Green Deal, in particular circular economy and chemicals policies

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

18 Jul 2022 · Discuss the forthcoming revision of the Cosmetics Products Regulation

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

1 Mar 2022 · Chemicals strategy; CLP Regulation

Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

29 Oct 2021

Cosmetics Europe, representing the cosmetics and personal care industry in Europe, welcomes the opportunity to respond to the Inception Impact Assessment on the Revision of the Cosmetic Products Regulation (“CPR”) and looks forward to contributing throughout the revision process. Safety being our number one concern, we support the CSS objective of a robust chemicals policy framework that protects consumers and the environment. Any revision of the CPR should acknowledge the long history of high level of safety of European cosmetic products and keep at its core the principle of “demonstrated safe use”. Any change should also support the industry’s innovation capacity and global competitiveness, maintaining the CPR as the global “Gold Standard” and reference. This can only be achieved through a strong sectorial regulatory framework, that is science-based, proportionate, effective and efficient for consumers, industry and authorities. Generic Risk Management Approach European cosmetic products are recognised globally as representing the highest standard of consumer safety, due to a strict risk-assessment approach. A Generic Risk Management Approach (GRA) must not supersede “demonstrated safe use” and must include a workable derogation mechanism for demonstrated safe uses. The GRA mechanism already existing under the CPR could be adapted to manage the risks of the most harmful substance mentioned as first priority in the CSS. Further extension of GRA to hazards that can be fully addressed under the mandatory Cosmetic Product Safety Assessment is not justified. Essentiality Essentiality assessments should focus on the substance, not the product and should be based on the non-availability of suitable alternatives for the use or function of a substance. Such assessments must be done by a competent body and in a defined, transparent and timely process. Essentiality assessment should ensure the efficiency of the GRA-derogation process but must not become a ‘knock-out’ criterion for safe uses. The overriding principle of ‘demonstrated safe use’ should apply, i.e. If the use of a chemical is demonstrated safe, the question of essentiality of that use becomes irrelevant. Combination effects In line with Commission Guidelines, cosmetic-product safety assessors of already consider potential combination effects of ingredients as part of their routine practice. Furthermore, the GRA approach on CMR Cat. 1 substances systematically considers the safety of aggregate exposure from all uses. One Substance One Assessment A “One Substance One Hazard Assessment” approach could be a useful common departure point for sector specific risk assessments but cannot replace them. Cosmetics risk assessment requires a scientific committee with sector-specific experience, which upholds the principles of scientific excellence, independency, and effectiveness and has significant experience on the use of alternative risk assessment methods. Nanomaterial definition Discrepancies between the nanomaterial-definition in the CPR and the horizontal Commission Recommendation have led to diverging national practices. Cosmetics Europe supports a clear and workable nanomaterial-definition, based on an update to the Commission Recommendation. Digital Labelling The revolution in digital communication means and technologies has led to significant changes in consumers’ behaviour and expectation. Today’s labelling approach for cosmetics has remained unchanged for decades and is thus increasingly outdated. Cosmetics Europe welcomes and supports the consideration of digital labelling and of information simplification in the revision of the CPR. The digitalisation of information provides a range of opportunities for consumers, control authorities, the industry, as well as for the environment. Any specific environmental information that may be required should be done under the CPR to ensure it is helpful and actionable for consumers in terms of safe use and disposal.
Read full response

Response to Review of the general product safety directive

4 Oct 2021

Please see the Cosmetics Europe feedback in the attached document.
Read full response

Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

19 Jul 2021

Cosmetics Europe is the European trade association for the cosmetics and personal care industry. We welcome the opportunity to provide comments on this draft regulation. Cosmetics Europe believes that every cosmetic product made available on the European market must be safe for consumers to use and to manufacture and must be safe for our planet. We believe that animal testing is not the way to ensure that our products and their ingredients are safe. Please find attached our response.
Read full response

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

Cosmetics Europe is the trade association representing cosmetic and personal care product manufacturers in Europe. We support the objectives of innovation and a high level of protection of health and the environment, while preserving the free movement of products in the internal market and enhancing competitiveness of the industry. As downstream users, we support a targeted opening of REACH, building on what works, maintaining policy coherence, regulatory predictability/stability and strengthening enforcement to prevent import of non-compliant products. Any new data requirements need to be clear and contribute to measurable improvements to human and environmental safety. New information requirements (hazards of concern, documentation of safe use, registration of certain polymers, and information on the environmental footprint) should be consistent with the requirements of Article 13 of REACH and not lead to an increase of animal testing. A lot of progress has been made in the area of non-animal (eco)toxicology and risk assessment and we believe that this review is the opportunity for these methods to find full regulatory acceptance and promotion. Indeed, a paradigm shift may be necessary, moving away from in-vivo testing as the gold standard. Any increase of animal testing as a consequence of the proposed new data requirements should be considered in an impact assessment. New data requirements will result in higher costs for chemical manufacturers and will render many chemicals commercially unviable and no longer available to downstream users. This may include ingredients that are essential to allow cosmetic products to play a significant role in physical, social and mental wellbeing, as well as ingredients supporting small-scale producers in economic vulnerable regions. Rather than introducing new data requirements in a ‘check-box’ approach, they should be assessed against the real added value they bring to chemicals safety. The current registration system is inadequate for polymers and a specific framework would be needed, with polymer-specific, clear and implementable data requirements, tonnage thresholds and testing schemes. Polymers of low concern should be exempted from registration. Mixtures Assessment Factor (MAF) is proposed as a practical and workable approach to deal with unintentional mixtures. It will directly impact on the outcome of existing and future risk assessments (human and environmental). Any MAF should be based on current scientific knowledge and be subject to impact assessment. A range of MAFs could be applicable depending on the exposure scenario. Cosmetics Europe experts stand ready to provide scientific input into this debate. Whatever the future process for Restriction/Authorisation, it is very important that risk management remains based on scientifically sound risk assessments and conditional to a proven risk rather than ‘suspected’ hazards. Safeguards, such as derogation mechanisms, must be introduced to avoid one-size-fits-all generic bans and restrictions of uses that are safe for consumers and environment. The future process should fully take onboard the methodology for Analysis of Alternatives and Socio-economic analysis developed over the years and successfully applied in authorisation. CSS creates new links between the horizontal chemicals and downstream legislations, including the Cosmetic Products Regulation, CPR. We support that certain elements of the chemicals management (hazard identification and overall environmental risk assessment of substances) are cross-sector. However, risk management measures should be set under vertical regulations and not be split between REACH and sector legislation. The discussions on “essential use” show the need to further address fundamental issues around this concept before putting it in operation as a regulatory decision tool. We support a study to clarify these issues and encourage a broad societal debate on the merits and risks of the approach.
Read full response

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

Cosmetics Europe is the trade association representing cosmetic and personal care product manufacturers in Europe. We recognise that safe use of chemicals requires as a first step the identification and communication of hazards. This should be done in a predictable and internationally compatible way at national, regional and global level, in line with the international GHS system to minimize divergence. However, regulatory consequences of classifications, i.e. product safety assessments and regulatory risk management should be implemented through sector specific legislations that consider relevant, real life use. The introduction of new classification criteria will lead to new information requirements. These should be consistent with Article 7 of CLP and not lead to an increase of animal testing. Indeed, a paradigm shift is necessary to move away from in-vivo testing as the gold standard. A lot of progress has been made on non-animal (eco)toxicology and risk assessment and we believe that the CLP review is an opportunity for these methods to find full regulatory acceptance for the classification of chemicals. An increase of animal testing, as a consequence of the proposed new hazard categories, should be assessed in an impact assessment. The CSS will create new links between CLP and downstream legislations, including the Cosmetic Products Regulation, CPR. Such links should recognise the limitations of hazard identification and be relevant and proportionate for downstream sectors. Safeguards, such as exemption procedures, must be introduced both under REACH and sector-specific legislation to avoid unjustified bans of uses that are safe for consumers and the environment. Disproportionate action should be avoided for substances that are merely “suspected” of hazard properties. Regulatory links should be legally clear, also to avoid negative impact on SME’s being not aware of all regulatory changes. To guide use and disposal, information on products must be meaningful and understandable for consumers. Indicating the damage that a chemical mixture could cause under unrealistic, worst-case conditions (i.e. hazard) is not an effective way to communicate and should be reserved to situations where the real-life use/disposal cannot be foreseen by the manufacturer. When use/disposal are strictly pre-determined, there is clear evidence that targeted information and warnings are more easily understood by consumers. This principle has been successfully implemented since many years in the CPR for human safety of cosmetic products. The upcoming revision of the CPR and the Sustainable Products initiative provide an opportunity to introduce relevant consumer information on the environmental impact of cosmetic products, going beyond (eco)toxicological hazard information. Simple extension of CLP labelling to cosmetics would not add any useful consumer information and would often contradict the intended use/disposal. Generic Risk Approaches based on CLP classifications have significant economic impacts on downstream users. The IIA considers that increased investment and research will simply lead to innovative and safer chemicals. It is important that all sectors, including cosmetics, have equal and fair access to scientifically valid and regulatory-accepted tools for innovation that fully respect provisions and restrictions on the use of animal tests. We urge the Commission not to rush decision-making processes for new hazard classes in order to meet unrealistic deadlines set in the CSS, but to respect the principles and timelines of Better Regulation, including a comprehensive Impact assessment of the new classes on downstream users, including SMEs. Such impact assessment should take into account the feasibility of chemicals substitution, impact on animal testing, international trade compatibility, and the loss of products with health and social benefits. Realistic timelines for the phase-in of requirements must be set to mitigate these impacts.
Read full response

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

29 Mar 2021 · REACH; microplastics

Response to Revision of the Vertical Block Exemption Regulation

20 Nov 2020

Cosmetics Europe welcomes the conclusions of the Commission’s Staff Working Document on the Vertical Block Exemption Regulation (VBER) and the Vertical Guidelines (VGL), and the initial thoughts presented in the Inception Impact Assessment (IIA). Cosmetics Europe looks forward to being an active contributor to the revision process of the VBER & VGL. Cosmetics Europe agrees that there is a need to revise and update the VBER & VGL to adapt to new market developments. In particular, the revised VBER & VGL should fully recognize the fact that companies today frame their distribution to ensure at all moments a consumer omnichannel experience. Therefore, Cosmetics Europe is of the opinion that any policy options chosen by the Commission should be framed against that background, to give brand owners the flexibility to organise the distribution of their products in the most appropriate way, with the ultimate objective to always respond to consumer demand and evolving trends. In the attached documents, Cosmetics Europe provides its initial feedback on the policy options included in the IIA. We look forward to participating in the forthcoming public consultation.
Read full response

Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals

16 Nov 2020

Pls find in the attached file Cosmetics Europe response to the consultation of the European Commission on “amending Annexes VII to XI to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)”
Read full response

Response to Sustainable Products Initiative

16 Nov 2020

Cosmetics Europe welcomes the opportunity to engage with the European Commission. We consider the following aspects are critical elements for the upcoming European Commission policy discussion on the Sustainable Products Policy Framework: • Overarching product sustainability principles should be clear, objective and adaptable to the wide variety of product categories.  This set of principles need to ensure the nature of the products is taken into consideration, as not all methods and criteria that apply to articles for continued use, are equally relevant for consumables • As the cosmetics industry is investing significantly in the development of more sustainable products, these principles should enable companies, including SMEs, to voluntarily implement and communicate those improvements to consumers and value chains with the necessary agility. It would also be essential for maintaining the incentive to innovate in this fast-moving domain, both at the product and at the methodology level. • Regarding the objective to increase recycling and recycled content, and before setting any threshold the availability of recycled content, supply of sufficient quality and quantity must be secured and specificities of the different product categories must be considered. The European Union must also ensure that there are no discrepancies at Member State level and that harmonisation in the internal market is guaranteed. • With regard to mandatory product-related sustainability information, a tailored approach is needed for the various sectors, based on the relevant environmental characteristics of their products, to provide meaningful information to consumers – and support their informed choice - as well as to relevant actors along value chains. o The use of digital information channels should be encouraged. Digital provision of information has the potential to communicate to consumers more information, more efficiently, and in an adapted way. It can also, for example, contribute to reducing packaging waste. o In our view it is unlikely that one method alone (such as the Product Environmental Footprint – PEF) could be used for all the sectors concerned to reduce the environmental impacts of goods and services taking into account supply chain activities. Rather than a mandatory implementation of the PEF tool across all products and sectors, alternative and complementary sectorial approaches based on various robust and science-based methodologies should be allowed in order to accurately address the diversity of environmental features that could be communicated to consumers. • The cosmetics and personal care sector is keen to avoid as much as possible the destruction of unsold products that are suitable for consumption and its potential negative impact on the environment. o There are already many industry-led initiatives conducted to improve recycling, reuse and donation of cosmetics and personal care products. These industry initiatives should be promoted and supported. o Depending on the nature and characteristics of their unsold products, and to take into account the technical challenges associated the recycling of certain materials and the legal and business risks associated with the donation of certain products, manufacturers and distributors should be free to decide whether and how to recycle, reuse and/or donate their unsold products. o In particular, donations may present the risk of supplying parallel markets for products operating through selective distribution channels. These parallel markets themselves create major risks of counterfeiting and not meeting cosmetic products’ safety standards. Therefore, manufacturers should be free to donate their unsold products when they can do it in a safe and legal way for themselves, beneficiaries and distributors.
Read full response

Response to Review of the general product safety directive

1 Sept 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. The vast majority of Europe’s 500 million consumers use cosmetic and personal care products on a daily basis to protect their health, enhance their well-being and boost their self-esteem. Ranging from dermo-cosmetics, antiperspirants, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in all stages of our life. We welcome the opportunity to engage with the European Commission on the New Consumer Agenda and related files. In regard to the Commission’s roadmap on the review of the General Product Safety Directive (GPSD), Cosmetics Europe considers the following principles are critical elements for the upcoming European Commission policy discussion in this field: • The GPSD fundamental approach, scope and principles are still very much up to date and valid. The GPSD and its implementing Guidance documents provide a useful general framework, addressing all necessary aspects to address consumer safety across all kinds of consumer products. It also leaves room to more detailed and often further-going requirements in sector-specific legislation that is tailored to specific product categories. •As a consequence, regarding cosmetics, many of GPSD requirements are not applicable because of more specific requirements under the Cosmetic Products Regulation 1223/2009 (CPR). However, other, mainly horizontal, provisions under the GPSD remain a useful complement to the CPR. • The cosmetics and personal care industry do agree that the overall GPSD framework does not sufficiently address new technologies and online distribution channels which can impact product safety. Due to their horizontal and universal nature, these aspects are better addressed at horizontal level than in sector specific legislation. o Online intermediaries should have an identified stronger share of responsibility for ensuring compliance of products that are made available on their platforms. Voluntary commitments (Safety Pledge) are not sufficient to improve the safety of products purchased online. o Effective instruments for online market surveillance should be developed to strengthen Member States enforcement of products sold online. It should be considered, however, whether this should be done under the framework of the GPSD or rather under the recently published Regulation on Market Surveillance and Compliance of Products (Regulation (EU) 2019/1020). Cosmetics Europe is of the opinion that any policy options must appropriately address this gap, by strengthening the online-sales platform’s Product Safety Pledge and provide more guidance and support for online-market surveillance activities of Member States. Any option should also create more clarity on the scope of RAPEX. The scope of RAPEX is intended – and presented – as covering products which pose a ‘serious risk’ to consumers. However, we observe is a growing tendency of notifications of products that are not necessarily ‘non compliant’ but do not pose a serious risk. Presenting such products under RAPEX as posing a serious risk is incorrect and potentially confusing for the consumers, consumer advocates and even competent authorities. There is a risk that the utility of RAPEX may be diluted by such practices. An alternative mechanism to address non-compliant products might be considered, or such product might be clearly annotated accordingly within RAPEX (as non-compliant rather than presenting serious risk), In addition, the GPSD should not go as far as systematically banning products that in one aspect or another are similar to food (e.g. smell, colour, etc.). In line with the GPSD objective, i.e. consumer safety, only such products should be banned that pose a real risk to consumers due to the fact that they imitate food. Cosmetics Europe looks forward to contributing actively to the future policy discussions on the review of the GPSD.
Read full response

Response to Empowering the consumer for the green transition

28 Aug 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. The vast majority of Europe’s 500 million consumers use cosmetic and personal care products on a daily basis to protect their health, enhance their well-being and boost their self-esteem. Ranging from antiperspirants, dermo-cosmetics, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in all stages of our life. Cosmetics Europe welcomes the opportunity to engage with the European Commission and considers the following principles are critical elements for the upcoming European Commission policy discussion on Empowering the consumer for the green transition: • It is crucial to define a clear and objective set of criteria and scientific methodologies to assess products’ environmental impact. These should be provided as a harmonised framework, rather than as specific legal requirements, and take into consideration each product category specificities. o It is important to note that not all methods and criteria are equally relevant for all product types, as for instance, ‘repairability’, ‘availability of spare parts’ or ‘software updates‘ can be important impact environmental characteristics for articles that are expected to be used repeatedly and over a long time; they are not relevant for cosmetics and personal care products. • To provide meaningful information to consumers and support an informed choice, a tailored approach is needed, based on the relevant environmental characteristics. • Regarding environmental claims and the risk of green-washing, we would like to highlight that, as recognised by the European Commission in its Report to the European Parliament and Council (COM (2016) 580 final), the “existing European regulatory framework for claims and advertising of cosmetic products is very comprehensive and ensures a high level of consumer protection.” It already includes a legal requirement for claims to be supported by evidence, in addition to them being legally compliant, truthful, honest, fair and allowing informed decision-making. This system establishes key principles that must be complied with whilst allowing a certain degree of flexibility for their application, to accommodate cultural and linguistic differences, scientific progress, evolving societal trends and consumer expectations, etc. In addition to having been proven to effectively protect consumers from being misled, this system also promotes innovation and fosters competition. • In our view, it is unlikely that one method alone (such as the Product Environmental Footprint (PEF)) could be used for all the sectors concerned. Furthermore, as it stands today, there are general issues with the PEF method concerning data quality and availability, standardisation, comparability etc., and therefore further development is necessary. A PEF case study that has been conducted on shampoo by Cosmetics Europe revealed that the PEF would not be specific enough to allow differentiation between products in a similar product category and has not provided indications on how its results could be clearly and meaningfully communicated to consumers. • The use digital information channels should be encouraged; digital provision of information has the potential to communicate more efficiently and in a personalized way, information to consumers, but also for example, reduce packaging waste.
Read full response

Response to Environmental claims based on environmental footprint methods

28 Aug 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. From dermo-cosmetics, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in consumers’ every-day lives. We welcome the opportunity to engage on the legislative proposal on substantiating green claims. Naturally, we support the objective to move towards a more harmonised approach for providing consumers with reliable environmental information, increasing simplification and reducing administrative burdens, especially for SMEs. We would like to contribute the following considerations to the inception impact assessment: 1. Regulatory context for cosmetic product claims (including environmental claims) As recognised by the European Commission in its Report to the European Parliament and Council (COM (2016) 580 final), the “existing European regulatory framework for claims and advertising of cosmetic products is very comprehensive and ensures a high level of consumer protection.” It already includes a legal requirement for all claims to be supported by evidence, in addition to them being legally compliant, truthful, honest, fair and allowing informed decision-making. This system establishes key principles that must be complied with whilst allowing a certain degree of flexibility for their application, to accommodate cultural and linguistic differences, scientific progress, evolving societal trends and consumer expectations, etc. In addition to having been proven to effectively protect consumers from being misled, this system also promotes innovation and fosters competition. 2. Preservation of the Internal Market – need for a European approach Cosmetics Europe supports a common European basis, e.g. a framework of principles or criteria, for the substantiation of environmental claims. This would avoid different national approaches and methods leading to a fragmented internal market which would be detrimental to consumers and companies alike. Such a single European approach should be scientifically based, workable and simple, therefore also appropriate for use by SMEs. It should also be adaptable to the various sectors and product categories within those sectors. 3. Environmental Footprint Methodology In our view, it is unlikely that one method alone (such as the Product Environmental Footprint (PEF)) could be used for all the sectors concerned. Furthermore, as it stands today, there are general issues with the PEF method concerning data quality and availability, standardisation, comparability etc., and therefore further development is necessary. A PEF case study that has been conducted on shampoo by Cosmetics Europe revealed that the PEF would not be specific enough to allow differentiation between products in a similar product category and has not provided indications on how its results could be clearly and meaningfully communicated to consumers. 4. Suggested approach For the reasons outlined above, a European sectoral/value chain harmonised framework would make sense for the cosmetics industry, using reliable and scientifically robust standards or methods to maintain flexibility and adaptability to the different cosmetic product categories and to the diversity of environmental claims. As the cosmetics industry is investing significantly in the development of more sustainable products, a flexible framework or standards would allow companies to voluntarily communicate those improvements to consumers with the necessary agility. It would also be essential for maintaining the incentive to innovate in this fast-moving domain, both at the product and at the methodology level, to ultimately support the Commission’s goals in this area. Facilitation of value chain and sectoral collaboration on methodology, data collection, provision and metrics would be necessary to make the process as simple and efficient as possible.
Read full response

Response to A New Consumer Agenda

11 Aug 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. From dermo-cosmetics, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in consumers every-day lives. We welcome the opportunity to engage on the New Consumer Agenda (NCA). We consider that a primary objective of the NCA should be to enhance consumer empowerment and trust in an evolving digital environment and that the following elements merit specific attention: Consumer information • We acknowledge the Commission’s goal to empower consumers to make informed healthy and environmentally sustainable choices. Digital provision of information has the potential to communicate more efficiently and in a personalized way, information to consumers, but also for example, reducing packaging waste. In the context of future initiatives, the Commission should consider digital as an efficient tool to meet mandatory consumer information requirements. • Ensuring consumers can make an informed choice, ahead of any purchase off/on-line is essential to build consumer trust and enable consumer empowerment in the green and digital transitions. While digital tools may be effective and user-friendly tools to inform consumers, it remains essential to ensure non-mandatory consumer information provided by any operator off-/on-line abide by principles such as accuracy, transparency, reliability (including from a science perspective) and fairness. The NCA and other related upcoming Commission initiatives should consider these elements for all consumer product information provided through any means, including third parties, but also taking account of the products’ fundamental nature. For example, mobile applications (Apps) have recently been increasingly developed with the exclusive purpose to inform and help consumers choose a product. Apps often may be operated by third party providers. Though these service providers typically do not sell the products they assess, they should be subject to the same obligations as manufacturers/distributors such as substantiating claims. For example, when rating a cosmetic product based on the presence/absence of an ingredient evaluated by a European Scientific Committee and approved for use under the Cosmetic Products Regulation (CPR) , such digital services providers should accurately inform the consumer about the ingredients’ regulatory status. Online Sales, Single Market & Market Surveillance Consumers need to be able to trust that products they buy are safe for human use and for the environment. Placing on the market of safe products is provided by horizontal legislation such as the General Product Safety Directive (GPSD)1 or sectorial such as the CPR.2 Ensuring consumer protection rules are equally enforced off-/on-line is essential. According to recent national authorities market surveillance activity reports a non-negligible number of non-compliant cosmetic products could be found online for sale on the EU market, notably on platforms and e-commerce websites registered outside the EU.3 Rules and enforcement mechanisms should be reinforced to guarantee consumer safety and the same level of trust for products sold on-/off-line. • National initiatives, for example in the environmental field, also divergent interpretation and enforcement of existing EU legislation can undermine the Single Market, which can lead to adverse consequences for consumers and industry. Maintaining Single Market integrity through uniform enforcement of existing legislation, taking into consideration national level resources to ensure a consistent market surveillance for all distribution channels and preventing national measures distorting free flow of goods are important objectives for the NCA. 1 EC 1223/2009 2 2001/95/EC 3 e.g. DGCCRF 2019 activity r www.economie.gouv.fr/files/files/directions_services/dgccrf/dgccrf/rapports_activite/2019/resultats-dgccrf-2019.pdf
Read full response

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

3 Aug 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. Ranging from antiperspirants, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in in all stages of our life. European citizens use cosmetic products as part of their daily lives, serving their essential needs and expectations. These needs and expectations drive our industry as well as delivering innovative products that enhance consumers’ well-being and quality of life and boost their self- esteem. We welcome the European Commission’s European Green Deal announcement and share the overarching goals of the European Union to mitigate the impact of climate change by 2050, contribute to the United Nations Sustainable Development Goals and enhance competitiveness and growth. In regard to the Commission’s roadmap on “Essential requirements for packaging and reduce (over)packaging and packaging waste”, Cosmetics Europe considers the following principles are critical elements for the upcoming European Commission policy discussion: • The European Single Market is one of the European Union’s greatest achievements, underpinning the competitiveness of European businesses and establishing the EU as a key global market and export partner to third countries. A level playing field must be ensured through the Single Market protection and harmonization. The gradual fragmentation of the Single Market must be prevented, and its smooth functioning and the free movement of goods, so vital to competitiveness and growth, must be assured by removing barriers. o A functioning Single Market for secondary raw materials with harmonised rules on packaging is key, as it allows the free movement of packaging and packaged goods in the European Union. • Safeguarding the specificities of the cosmetics and personal care industry as regards product safety and protection of the consumers is paramount in the context of packaging’s functionality, namely its role in: a) Protecting the product and through it the safety of the consumer, b) Product application, enabling correct application and use of the product, c) Increasing shelf-life and contributing to product waste reduction, and d) Facilitating transport, handling and distribution. Measures to increase the recyclability and re-usability and/or to reduce waste generation must take into account the critical aspects of packaging for cosmetic products highlighted above. • Any policy measures designed to stimulate demand for plastic recyclates must take into account the regulatory, technical, quality, and supply chain barriers to include recycled content within packaging for categories of products such as personal care products for which packaging delivers essential functionalities, as outlined above. • The cosmetic and personal care industry believes there is a need of strengthening the market for secondary raw materials through: o Optimal implementation and enforcement of existent legislation, o Establish harmonised collection and recycling systems across Europe, o Timely investment in Member States’ infrastructures for return/separate collection, sorting and recycling, o Availability of secondary raw materials at competitive prices and of appropriate quality ensuring consumer and product safety, based on EU-wide definitions of recyclability and minimum quality standards for recyclates. • A holistic assessment of the environmental impact of packaging whereby environmental performance is assessed throughout the entire life cycle of the packaged product is key. Mechanically recycled, chemically recycling and biobased plastics should be evaluated based to their circularity potential. Cosmetics Europe looks forward to contributing to the future policy discussions on the essential requirements for packaging and reduce (over)packaging and packaging waste.
Read full response

Response to Chemicals strategy for sustainability

19 Jun 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. We welcome the European Commission’s European Green Deal announcement and share the European Commission’s Chemicals Strategy for Sustainability (“CSS”) objective for a robust chemicals policy framework that protects consumers and the environment, highlighting that it needs to ensure industry’s competitiveness and innovation capacity. - Ranging from antiperspirants, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in in all stages of our life. European citizens use cosmetic products as part of their daily lives, serving their essential needs and expectations. These needs and expectations drive our industry as well as delivering innovative products that enhance consumers’ well-being and quality of life and boost their self- esteem. - Chemicals play an essential role in our daily lives, including cosmetic and personal care products. Cosmetics Europe joins the European Commission in recognising the strength of the EU Chemicals Regulation and the sectorial legislation, not only as a tool to protect consumers and the environment from the potential risk of certain chemical substances, but also as an enabler of innovative technologies and business models. Indeed, the main aim of the Cosmetic Products Regulation EC 1223/2009 is to ensure human safety by providing strict risk management procedures which guarantee a high-level of consumer protection. - As a science-driven, highly innovative sector, making large investments in R&D, ensuring innovation friendly policies and regulatory frameworks underpinned by a strong European Single Market and holistic industry policies is of utmost importance. Incentivising research, development and production will support innovation and allow the chemicals sector and its downstream use sectors – such as cosmetics and personal care products - to continue to innovate safe chemicals, products and materials that can help to address the big societal challenges facing the environment and the economy. In addition, innovation is essential in the development of new science and technologies which can be used in novel methods for the assessment of chemical hazards, and ways to manage and mitigate these. - The cosmetics industry has been at the forefront of developing alternatives to animal testing for regulatory safety assessment for more than 25 years and supports the goal of eliminating all unnecessary animal testing while respecting the state of the science and the international regulatory context. This has allowed the cosmetics and personal care sector, in close cooperation with the European Commission, to develop, test and use safer and more sustainable chemicals without recourse to animal testing. In this spirit, the Chemicals Strategy for Sustainability should explicitly foresee the support for the commercialisation of new sustainable initiatives. - The cosmetics industry shows strong, sustained commitment—and invests significant funds—to build on scientific progress, develop new approaches and drive innovative paradigm shifts in safety testing and safety assessment that meet regulatory needs, for both human health and the environment. From a scientific perspective, finding alternative approaches is a huge challenge to which the cosmetics industry is responding in order to maintain consumer safety as a priority. Cosmetics Europe is looking forward to contributing to the debate on the Chemicals Strategy for Sustainability as a constructive stakeholder.
Read full response

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

7 May 2020 · Discussion to introduce the cosmetics sector and certain issues of importance, especially in the current COVID-19 context

Response to A new Circular Economy Action Plan

20 Jan 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. We welcome the European Commission’s European Green Deal announcement and share the EU goals to mitigate climate change impact by 2050, contribute to the UN SDGs and enhance competitiveness and growth. We share the Commission’s New Circular Economy Action Plan objective to continue to transition towards a Circular Economy. Our industry is committed to continue playing its part in the transition to circular economy for instance: Individual member companies of Cosmetics Europe have already taken commitments to transition to the circular economy; an example is the reduction of the use of virgin plastic from packaging and accelerating innovation in relation to re-useable packaging and use of recycled material. Also, the industry has taken voluntary action to phase out solid plastic microbeads for exfoliating and cleansing from wash off cosmetics products; by 2018, 97.6% had been phased out. We consider the following principles essential to further the circular economy transition: - As a science-driven, highly innovative sector, making large investments in R & D, ensuring innovation friendly policies and regulatory frameworks underpinned by a strong European Single Market and holistic industry policies is of utmost importance. - The Single Market is one of the EU’s greatest achievements, underpinning European businesses competitiveness and establishing the EU as a key global market and export partner to third countries. It has improved everyday life of European businesses and citizens by stimulating investments and economic growth, boosting employment, and reducing costs and administrative/regulatory burdens. A level playing field must be ensured through Single Market protection and harmonization. Gradual fragmentation of the Single Market must be prevented. Its smooth functioning and free movement of goods, vital to competitiveness and growth, must be assured by removing barriers. - Optimal implementation and enforcement of existent legislation through the better regulation agenda is crucial. It is important to prioritise the reduction of bureaucracy and burdens. - Safeguarding the specificities of the cosmetics and personal care industry as regards product safety and protection of the consumers is paramount in the Circular Economy context. Consumer safety aspects must be considered strongly. In addition, individual consumer needs and expectations together with product safety requirements should always be taken into consideration when assessing circularity options of cosmetic and personal care products and particularly when assessing their lifecycle. While products themselves are linear, supply or value chains might offer potential for more circularity. For example, the use of recycled material for packaging purposes depends on the availability of both necessary quantities as well as their required level of quality to ensure product safety. The new action plan will foster a well-functioning and integrated internal market for secondary raw materials to ensure that they are safe, competitively priced and reliable; this is an essential element. A New Circular Economy Action Plan should enable a circular and sustainable EU economy while ensuring European industry remains competitive and innovative. - Empowering consumers in the circular economy is an important element. In this context, account should be taken of the specificities of the cosmetics sector and our obligations. Digital tools are important to consider, they offer huge potential to effectively communicate certain product information to consumers via means other than those on physical support e.g. the label, packaging or enclosed leaflet. Further, digital has the potential to reduce packaging waste. - The “one-in-one-out” principle & comprehensive impact assessments are vital better regulation enablers, as is focus on implementation and enforcing existing laws e.g. in waste acquis.
Read full response

Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

10 Dec 2019 · Courtesy meeting to introduce themselves and present their priorities

Response to Labelling fragrance allergens

21 Dec 2018

Cosmetics Europe has reviewed the European Commission Inception Impact Assessment in relation to fragrance ingredients about which consumers allergic to them need to be informed. We believe that this document is an accurate description of the various options for providing information to consumers and provides a balanced summary of the various impacts that these options will have. Cosmetics Europe appreciates to be considered a stakeholder by the European Commission in this area and will contribute to the consultations and events to be launched as from April 2019.
Read full response

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

27 Jul 2017 · Plastics Strategy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

26 Jul 2017 · Plastic Strategy

Response to Amendments following Article 15 of the cosmetic Regulation 1223/2009

24 Jul 2017

Please refer to the attached document for detailed Cosmetics Europe comments.
Read full response

Cosmetics industry urges potency inclusion in endocrine disruptor criteria

28 Jul 2016
Topic — The consultation addresses scientific criteria for identifying endocrine disruptors in biocidal products.
Message — Cosmetics Europe recommends including potency and full hazard assessments in the identification criteria. They argue the definition should distinguish substances posing real danger from those with negligible risk.12
Why — This would prevent safe cosmetic ingredients from being unfairly restricted or banned.34
Read full response

Cosmetics Europe Urges Inclusion of Potency in Endocrine Criteria

28 Jul 2016
Topic — A consultation on scientific criteria for identifying endocrine disruptors under European Union regulations.
Message — The industry supports the WHO definition but demands regulators distinguish real dangers. They recommend amending criteria to include potency and full hazard assessments.12
Why — This avoids banning safe ingredients, which protects the industry's existing product portfolios.3
Impact — Environmental groups lose a precautionary system that bans chemicals based on inherent hazard.4
Read full response

Meeting with Elżbieta Bieńkowska (Commissioner)

1 Dec 2015 · Regulations Cosmetics Industry

Meeting with Elżbieta Bieńkowska (Commissioner) and

1 Dec 2015 · 1) The Contribution of the Cosmetics Sector to the European Economy, and the role of SMEs; better regulation; TTIP

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

12 Feb 2015 · Vision of Cosmetics industry - link with Europe and internal market