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International cosmetic and device association eV

ICADA eV

European nonprofit organization for small and medium size cosmetic enterprises  SME promotion by representing the interests, needs and opinions of European cosmetic SMEs to the EU institutions, national authorities and other international organizations.  social, economic and technical SME-situation-reports to competent authorities.  contributions to legal regulation-projects.  SME support with legal, scientific and technical information, association-services, joint marketing projects, quality-standards, best practice handbooks, seminars, conferences, SME-supplier-sourcing.  Support for an environment of innovations and of appropriate safety-standards; networking to transform basic research results into applied cosmetic-industry practice.  Consumer-protection to secure the products-variety to choose from and to defend consumer-favored and approved products from market-bans.  Trade- and consumer-information in the area of typical SME-markets.  Cooperation in netw (...)

Lobbying Activity

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

ICADA e.V. represents small and medium-sized companies in the German-speaking cosmetics industry. The EU Cosmetics Regulation (EC) 1223/2009 in its current form represents a successful, harmonized legislation at the EU level but here are some points showing room for improvement. The definition of cosmetic products should include parts of the ears that are considered external in order to avoid boderline issue (Art. 2(1) a). ICADA members support the Commission's initiatives to edit the CPNP portal (Article 13) to prevent suspicious registrations under SAAS. The CPNP portal could also be opened to consumers so that they can check whether or not the cosmetic product is registered in the portal. This could be used to monitor online trade. With regard to the application of Article 15 (CMR substances) ICADA e.V. is of the opinion that a harmonized classification of an individual substance should not trigger the prohibition of a natural complex substances (NCS) containing that substance. If the content of the identified CMR triggers concerns for human health safety, the Commission may request an opinion from the SCCS. If an NCS contains a substance in relation to Article 15(2) for which cumulative conditions are to be met, ICADA supports the approach that food safety should be considered to be in compliance with Article 15(2) a) if the substance is present in a single or a few foods worldwide. When analysing the alternatives, it should be considered to be in compliance for NCS. If individual criteria are established, economic factors should always be taken into account in order to accommodate SMEs. ICADA also advocates for binding guidelines for the application of Article 15 with an extended timeline, since the proportion of substances classified as CMR occurring in cosmetic products has increased dramatically in recent years. With regard to endocrine disruptors, ICADA e.V. is of the opinion that the presence of substances that cause an established endocrine disruption in humans (EDHH1) should be subject to a risk assessment by the SCCS in every case. This does not require an automatic ban as in Article 15 for CMR substances. ICADA member companies agree with a harmonized nano definition (Art.16), so that the definition of nanomaterials in the EU Cosmetics Regulation should be aligned with the Commission Recommendation of 2022. With regard to the labelling of cosmetic products (Art. 19) ICADA e.V. would like to point out that the warning for professional use only is ineffective. Rather, the imprint tends to tempt the normal consumer to buy the product on the assumption that professional products are of a better quality and more effective than normal consumer products. Therefore it would be more effective to add to the warning for professional use only a sentence like sales only to business customers allowed. ICADA is also in favour of standardizing internationally the disposal instructions on the packaging in the CPR so that the idea of harmonized labelling of cosmetic products is not undermined by other national regulations. Here, SMEs are also at a great disadvantage when it comes to gathering and obtaining the relevant information in the first place. The members of IDADA would like to see the common ingredient labelling move to a modern, future-proof platform and away from a glossary according to Article 33. The glossary is already outdated by the time of revision and publication. As an alternative to the glossary, the Cosing database should be used. The preamble to Annexes II to VI should define what is meant by a ready-to-use preparation. For example, bath salts should be mentioned here, which are only ready for use when diluted in bath water. The tables in the Annexes to the regulation should include the Annex number as a header, to make it easier to navigate through the regulation.
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Response to Initiative prohibiting and permitting under scrutiny certain hydroxyanthracene derivatives in food supplements

21 Apr 2020

ICADA, the international association for cosmetic products, cosmetic devices and food supplements, representing over 600 global small and medium size enterprises We are against a ban on aloe vera products on the European market. Products based on the inner aloe vera gel and products based on the whole leaf both decolorized contain aloin level ≤ 5 ppm. This value ensure that HAD exposure from aloe vera products it comparable to the natural exposure to HADs through consumption of common vegetables, but it is not technically possible to confirm the complete absence of these compounds as it is stated in the current draft. Therefore we recommend to change the current draft such a way that the aloe products are not included in Annex III part A but in Annex III part B of the regulation (EC) 1925/2006 with a maximum content of aloin and HAD (e.g. ≤5 ppm). In addition the AOAC method accepted in 2017 for determining the aloin and aloe- emodin should be included as technical basis for defining presence of HADs, as well as helping to ensure consistency in determining compliance.
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