OpenLobby.EU
Explore

Detic asbl / vzw

Detic

Detic represents three main sectors, Cosmetics, Detergents maintenance products and Adhesives Sealants, as well as Biocial products and Aerosol technology in Belgium and Luxemburg.

Lobbying Activity

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

Detic is the Belgian and Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives, sealants, biocides and aerosols. Thank you for the opportunity to respond to the Call for Evidence. Detic is member of Cosmetics Europe (CE). We agree and support the contribution of CE and would like to add the following points on digital labelling information and consistency with other regulations. The EU Cosmetic Product Regulation (CPR) requires labelling information on physical packaging. According to Detic, digitalization is a tool and we need to make better use of it as well as icons to improve the understanding of the required labelling information. Belgium is a multilingual member state with 3 official languages. This makes it a real challenge to make readable labels with all the required information in the 3 languages. Cosmetic and personal care products are used every day and with consumers who are sometime travelling a lot, a multi-lingual label is an added value for the appropriate use of the products. In addition, with all European and international institutions in Brussels, the use of digitalization to improve labelling information has to be envisaged. A very good example of digital information is the COSMILE Europe App, an app-based entry point to the COSMILE Europe database on ingredients used in cosmetic products. This database provides comprehensive and objective information on ingredients which is useful for the consumers, authorities and for (health care) professionals. Both the database as well as the app are available in multiple languages including the three official languages of Belgium. Consistency with other chemical regulations: the CLP-regulation is hazard-based, while the CPR is risk-based. The interference of CLP-regulation to cosmetic ingredients becomes more and more complicated and difficult to manage, especially for SMEs. Reformulation for regulatory compliance happens more often, which reduces the resources available for innovation. In addition, the strict timing imposed by the CLP-regulation, makes it very challenging to reformulate and relabel timely. It is of paramount importance to be regulatory compliant, but it must be feasible and cost efficient. The continuous change on label should be facilitated with more digitalization, to avoid waste of labels or even packaging. Detic is therefore calling for a streamlined change in labelling with sufficient transition time, taken into account the seasonal effects on some products categories. Ideally, companies should be able to work by campaign of modifications, i.e. introducing all changes at once, on a regular basis, unless the absence of information could constitute an imminent risk to the user.
Read full response

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

7 Oct 2022

Detic is the Belgian-Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives and sealants, biocides and aerosols. Thank you for the opportunity to comment on the proposal for a basic regulation for EChA. Detic supports the comments made by A.I.S.E. and Cosmetics Europe. In general, we support a basic regulation for the funding of EChA. A sustainable financing model should be put into place to ensure the future working of EChA, but we would like to emphasize on the need for a proper impact assessment when fees are to be requested from companies. This is particularly the case for fees related to the implementation of BPR. In our opinion, the fees asked by EChA in Regulation 564/2013 are not proportionate, especially for Union Authorizations. The role of EChA is mainly administrative, while the evaluating Member States are assessing the dossiers. As, on top of EChA fee, companies have to finance member state fees as well as all the costs to prepare their dossier, this is getting very difficult, quasi impossible, for SMEs to submit Union Authorization dossiers. Detic wishes also to submit its comments on how the future regulation should integrate the Scientific Committee on Consumer Safety (SCCS) within EChA. Whilst we support the CSS objective of improving effectiveness, efficiency and coherence of safety assessments across EU legislation, our views is that any re-allocation of SCCS work to EChA should uphold the specific and unique cutting-edge expertise that the SCCS has built up over more than 40 years with regards to safety of cosmetic ingredients and products. This can only be achieved if the SCCS remain a stand-alone committee within EChA. Please find attached more details about our comments on maintaining a strong expert committee on cosmetics safety assessment.
Read full response