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Kosmetiikka- ja hygieniateollisuus ry (The Finnish Cosmetic and Hygiene Industry Association)

KH

The Finnish Cosmetic and Hygiene Industry Association (Kosmetiikka- ja hygieniateollisuus ry) is a Finnish trade association representing the interests of companies manufacturing, importing and/or distributing perfumery, cosmetic and toiletry products, detergents and cleaning products for consumers and professionals, and for institutional & industrial use.

Lobbying Activity

Meeting with Jessika Roswall (Commissioner) and

27 Aug 2025 ยท Meeting to discuss EU chemicals policy

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

The Finnish Cosmetic and Hygiene industry Association is an industry association representing both domestic and multinational cosmetics companies of all sizes in Finland. The association is a member of Cosmetics Europe. European citizens including Finnish people use cosmetics, such as body lotions, make-up, shampoos, toothpastes, soaps and deodorants, every day. These products have a significant impact on citizens health and well-being. Cosmetics industry is both economically and socially significant sector in Europe, and it is important to ensure its competitiveness. The EU Cosmetics Regulation (EC) No 2009/1223 (CPR) is a key legislative instrument for maintaining competitiveness and it must be ensured that innovative, safe, and efficient products can be designed, manufactured and offered to European including Finnish consumers and professionals also in the future. European regulatory framework (CPR) is essential for the industry to ensure a functioning internal market. The current CPR is a workable package ensuring functioning of the internal market as well as safe products, and it has been well received by cosmetic companies. The key principles of the legislation science-based risk assessment approach for the safety assessment of cosmetic ingredients and products, rules on claims, comprehensive labelling requirements and a robust market control system have proven to work. However, the regulatory framework for cosmetics has evolved in the last years, and therefore the impact of other legislation needs also to be considered when assessing the CPR. In addition, for example, technological innovations and solutions, such as digital development, must be considered. For example, consumer information requirements are constantly increasing. Because of the limited space available for cosmetics labelling, the use of digital solutions would support both consumer information and sustainable development. However, possible adaptations to the CPR should not jeopardize these basic principles of the well-functioning current regulation as continuity is important for the industry. One of the key elements of the current regulation is a risk-based approach in the safety evaluation of cosmetic ingredients and products and, sectoral risk assessment should be maintained. Hazard-based approach would threaten the foundational principles of CPR. It is important that ingredients are not categorically banned without assessing their safety in cosmetics. However, some ingredient regulatory processes under the current CPR could be improved and made more effective. These processes should be such that they do not leave legal uncertainty for the companies which ingredients are allowed in cosmetics. Any regulatory development should also be accompanied by adequate transition periods to allow companies sufficient time to adapt to legislative changes. We are available for further exchange on the evaluation of the EU Cosmetics Regulation.
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Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

The Finnish Cosmetic and Hygiene Industry Association (Kosmetiikka- ja hygieniateollisuus ry) welcomes the idea of improving human health and environmental protection through the improvement of urban wastewater treatment. However, we would like to raise some observations regarding the proposed Extended Producer Responsibility (EPR) scheme for the pharmaceutical and cosmetics industry. Any addition of a quaternary wastewater treatment phase should be based on a scientific assessment of substances currently present in the wastewater effluent and which are hazardous to aquatic ecosystems or to human health via aquatic ecosystems. If the EPR system was established, it should cover all economic operators whose products release those harmful substances into wastewater. To ensure a harmonised implementation across the EU, we would like to see the future legislation being based on a clear definition of a micropollutant and a list of micropollutants in scope, instead of an open reference to CLP hazard classifications. The proposed upgrading of wastewater treatment processes will be costly. According to preliminary estimations, especially in small markets like Finland the setup costs for the upgrading could be very high compared to the actual market size. This may have an impact on the availability of products across the internal market. All in all, it will be important to have a fair and proportional allocation of the financial burden.
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