European Organization of Cosmetic Ingredients Industries and Services
UNITIS
UNITIS regroupe les fabricants d'ingrédients cosmétiques d'origine naturelle au niveau européen.
ID: 872947115617-45
Lobbying Activity
Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation
1 Nov 2021
UNITIS, the European organization of cosmetic ingredients industries and services, representing SMEs manufacturing natural cosmetic ingredients, supports the general objectives of Chemicals Strategy for Sustainability (CSS) and green growth agenda. We will make our best contribution to the Revision of the Cosmetic Products Regulation (CPR) taking into account the following particular points which guarantee the safety of cosmetic products and the interest of the consumers:
- The Scientific Committee on Consumer Safety (SCCS) is a very experienced independent committee that has demonstrated his essential expertise in the safety assessment of cosmetic substances. His knowhow is internationally recognized as well as his specific experience on the use of alternative methods to achieve and maintain the animal testing ban provisions under the CPR. It is crucial to keep this scientific committee with the same level of skills and the same topical expertise.
- Cosmetic Products Regulation already prohibits CMR substances and it must evolve to manage other hazardous substances identified as a first priority under the CSS but Generic Risk Management Approach (GRA) must recognize “safety” as an overriding principle and must include a derogation process in case of a demonstrated safety of use by SCCS. Application of GRA without a workable derogation mechanism would certainly lead to unjustified loss of ingredients with demonstrated safe use, including natural and plant-based substances. This exclusion of some ingredients, which are nevertheless perfectly safe for human health in their cosmetic applications, would unjustifiably penalize the cosmetic industry and the consumer interest.
- The essential use concept must be based on the notion of suitable alternatives to the use of a substance in a particular product when the safety is not guaranteed but the concept of essential use is not relevant when the use is safe.
- We support “One Substance, One Assessment” for the determination of hazard and then the assessment of risk of a substance for each specific sector but we raise the question of the use of animal data for hazard assessment under the cosmetics regulation from an ethical and a legal point of view.
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