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Danish Association of Cosmetics and Detergents

The Danish Association of Cosmetics and Detergents represents the Cosmetics industry as well as the industry for soaps, detergents and maintenance products in Denmark.

Lobbying Activity

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

The association's detailed position is attached. This is an executive summary of our position. The Danish Association of Cosmetics and Detergents welcomes the opportunity to comment on the call for evidence for the evaluation of the Cosmetic Products Regulation, which is of great interest to our members. Nearly 300 companies in Denmark manufacture, import, or distribute cosmetics and personal care products for both the Danish and international markets. The vast majority of these are SMEs, geographically spread across the country. Our industry is growing, and since 2015, the number of companies in the sector has increased by 30%. During the same period, the number of full-time employees within the sector has grown by 15%. It is essential that the EU regulatory framework continues to support the advancement of the European cosmetics sector through clear and implementable legislation. This will foster European excellence, enabling the cosmetics industry to grow and to maintain its strong export market and ensuring that European products remain globally recognized benchmarks. With the EU Green Deal, the European cosmetics industry faces the challenge of adapting to numerous new and revised pieces of legislation within a short period of time, including revised chemical legislation, new sustainability-related requirements, including packaging requirements, new restrictions under chemical legislation, requirements concerning microplastics and upcoming EPR scheme for urban wastewater treatment. We recognize and support the EU Green Deals tendency towards more sustainable business practices and the political vision of phasing out harmful chemicals from consumer products. However, the overlapping new requirements and significant administrative burdens challenge companies attempting to be compliant while simultaneously allocating resources to innovate sustainably. SMEs in particular are affected, as they have only limited resources to meet the growing compliance demands. Therefore, the evaluation of the Cosmetics Regulation cannot be conducted in isolation. It must consider the broader regulatory landscape, which has changed dramatically through the recent years. The EU Cosmetic Products Regulation is a sector-specific framework providing clear benefits. It serves as a comprehensive reference for businesses of all sizes and origins, enabling them to place products on the unified EU market without having to navigate fragmented national regulations. The regulation applies a risk-based assessment model for ensuring the safety of cosmetic ingredients and finished products. However, the shift in general chemical legislation toward a hazard-based approachwhere usage and exposure initially are not consideredposes a significant risk to sector-specific regulations and the fundamental principles of the Cosmetics Regulation. It is crucial that safety assessments of cosmetic ingredients continue to account for exposure levels to ensure the safety of cosmetic products. The evaluation of the regulation should ensure its future viability and alignment with the rapidly evolving regulatory landscape. While consumer safety remains a top priority, new requirements related to sustainable design, circularity, and packaging must also be addressed. These aspects must be clearly communicated to consumers via product labeling, allowing them to make informed choices regarding ingredients, environmental impact, packaging composition, and waste sorting. Current labelling requirements for cosmetic products are already extensive, making it difficult for companies to fit all mandatory information in a readable fontespecially on small packaging, such as lipstick, mascara, or nail polish. With new legislation adding to this challenge, the evaluation should explore solutions, such as allowing certain mandatory labeling elements to be provided digitally via a QR code or another digital format. /The Danish Association of Cosmetics and Detergents
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Response to Revision of Regulation (EC) 648/2004 on Detergents

27 Jul 2023

The Danish Association of Cosmetics and Detergents thanks the Commission for the opportunity to provide comments to the proposal for a new Detergents Regulation. We would like to highlight the following issues, which will have great impact on the industry: 1) The requirements for the digital product passport should be applied through the horizontal Ecodesign Regulation rather than the Detergents Regulation to ensure complete harmonization. 2) The boundaries and interactions between the different economic operators need to be clarified more explicitly in order to ensure that they can be held responsible for their obligations. 3) The implementation of mandatory CE marking for all detergents will put a disproportionately large burden on companies particularly SMEs with no significant added benefits to consumers. Please find the attached document for an exposition of the highlighted issues.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

30 Mar 2023

The Danish Association of Cosmetics and Detergents welcomes the opportunity to give feedback to the legislative proposal of the CLP Regulation. In particular, we would like to highlight the following items that we find important to point out: - The industry is already dedicated to reduce the use of packaging, and therefore it is welcomed warmly that criteria for refill sales are articulated in the proposal. The responsibilities among the different actors (manufacturer and retailer) are, however, not explicitly and unambigously indicated, which may lead to unclarity in terms of who is responsible for a product sold in a refilled container. Additionally it is important to point out that the proposal should take into account sector specific differences and requirements. E.g. the requirements for packaging varies between cosmetic products and detergents. - Originally, the purpose of the hazard label was to provide the user a comprehensive and easily understandable overview of the hazards of a mixture. New and additional requirements have been added, resulting in unmanageable and overcrowded labels that often confuse instead of inform a user. We suggest making the mandatory information more end user relevant by moving the information not necessary for safe and correct use to a digital platform instead of on the physical label. - We welcome the opportunity be able to provide label elements online, since it establishes a long waited standardized model for digital labelling in general, but we would also like to emphasize that the current issues regarding double labelling on physical labels (e.g. detergents must provide some ingredients twice due to requirements from the CLP Regulation and the Detergents Regulation respectively) should be appropriately addressed right away for the digital label as well to avoid having to resolve such requirements later in the development of the digital label.
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Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

he Danish Association of Cosmetics and Detergents welcomes the opportunity to comment on the public consultation of the Revision of the Urban Wastewater Treatment Directive. The Danish Association of Cosmetics and Detergents is the leading Danish industry association and represents more than 80 Danish and international companies, which predominantly consists of SMEs. The proposed changes to the Urban Wastewater Treatment Directive will impose an additional financial burden to companies manufacturing and selling cosmetic products. Therefore, it is essential that the new requirements will be implemented transparently. Overall, we support the European Commission in their strategic focus to ensure that we protect our environment. However, after having read the proposal, we have some concerns about how the different initiatives will be implemented in practice so that the EPR of the cosmetic industry rests on the right terms and conditions and that the cosmetic industry is held responsible only for its own discharge of micropollutants. Overall it is therefore essential that the financial model for the EPR-fee scheme is proportional to the contribution to the overall micropollutant load originating from the cosmetic industry. Introducing the polluter pays principle would mean, that the companies should only pay for micropollutants that are not sufficiently removed in wastewater treatment plants and therefore trigger the need for upgrading from third to fourth treatment stage. Thus the scheme must only include micropollutants, that require a fourth treatment stage and not substances removed by the third treatment stage or can be proven biodegradable. Please see attached document for further elaboration of our main points
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Response to Revision of Regulation (EC) 648/2004 on Detergents

19 Oct 2021

The Danish industry of detergents represented by the Association of Cosmetics and Detergents, "Kosmetik- og Hygiejnebranchen", strongly welcomes this initiative from the European Commission. The Detergent Regulation should only regulate cleaning products - The Detergent Regulation should continue to regulate the sector as a separate regulation. Such a modification would not grant any benefits. - The scope of the Detergent Regulation should remain for cleaning products only, including microbial cleaning products. Overlaps and inconsistencies should be addressed - Double obligation has resulted in overlaps particularly between the Detergent Regulation and CLP in regard to labelling of ingredients, specific perfuming substances and preservatives. Such discrepancies should be addressed to accommodate a transparent and unambiguous consumer guidance. Information on pack should be legible, consistent and useful - CLP should regulate the information required on the label of the product, as is the case for chemicals in general. - The Detergent Regulation should only apply to the sector specific conditions of detergents not already regulated by other pieces of legislation. - Digitalization provides an opportunity to finally take care of the challenges connected to the requirements of CLP and the Detergent Regulation by making specific information elements from the label available online instead. Evaluation of ingredients should exclusively be done through REACH - Restrictions on specific substances by the detergent regulation may accidentally result in consumers losing their confidence in other regulations such as REACH. - To support the aim of "one substance, one evaluation", substance specific restrictions should therefore remain a topic addressed only by REACH. The Detergent Regulation should comply with the real world - Historically the adoption of the Detergent Regulation included the aim of protecting the environment against environmentally harmful substances. This thoughtfulness and consideration for the environment is fundamental for the Detergent Regulation and should be retained as an essential feature when the regulation is revised. - For example, laundry detergents should be able to address specific conditions such as the cleaning temperature or dosage for a specific amount of clothes. - The Detergent Regulation should also comply with the real world – a typical washing machine is capable of washing at least 8 kg of clothes, whereas the Detergent Regulation defines the standard washing machine load to equal 4,5 kg. - A growing trend is the sale of detergents in bulk and refillable packaging. While such initiatives may lead to potential benefits by reducing the amount of packaging required, the legislation should ensure proper consumer safety and hazard communication. Please see the attached file for the detailed feedback.
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