Nederlandse Cosmetica Vereniging
NCV
De Nederlandse Cosmetica Vereniging is de brancheorganisatie van fabrikanten, importeurs en merkhouders van cosmetica.
ID: 519800633534-31
Lobbying Activity
Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation
29 Oct 2021
The NCV represents the interests of the Dutch cosmetic industry and provides a variety of services for its members. The turnover of the cosmetic industry in the Netherlands is 3 billion euros annually and provides direct and indirect employment for more than 100,000 people. The NCV shares the European Commission’s Chemicals Strategy for Sustainability (“CSS”) objective for a strong chemicals policy framework that protects consumers and the environment. That is why the NCV welcomes the opportunity to respond to the impact assessment on the revision of the Cosmetic Products Regulation EC 1223/2009 (CPR) which is known to ensure human safety by providing sophisticated risk management procedures guaranteeing a high-level of consumer protection.
Generic risk approach (GRA) in the CPR
The hazard of a chemical is independent of the real-life use of a chemical. These hazards can be identified in a horizontal, cross sector approach. The risk of a chemical, on the other hand, fully depends on the actual use of a chemical. If the use is well defined, the possible risk can be characterized and managed in a specific legislation that considers the real-life use scenario.
The main objective of chemical legislation is to ensure safe use of chemicals. Banning safe use by automatic GRA is, in our view, does not support this objective. When alternatives for chemicals are not available a regulation should contain measures which safeguard the use of these chemicals. If essentiality would become a criterion in the GRA, demonstrated safe use should always be the overriding principle.
Combination effects
The Commission’s Implementing Decision 2013/674/EU Guidelines prescribes assessment of combination effects, so potential combination effects of ingredients in finished cosmetic products are always assessed by the safety assessor.
One substance one assessment and future of SCCS
The NCV supports an approach of “One substance - One hazard assessment” where hazard characterization of chemicals is managed horizontally across sectors. Having access to a complete set of hazard data and a common ‘Point of Departure’ for sector specific risk assessment would be beneficial. For cosmetics, not all data may be usable in risk assessment due to the animal testing ban.
Over time, the SCCS has built up an unmatched science driven expertise in the constantly evolving cosmetics risk assessment. Also, the SCCS has long standing interactions with stakeholders, works efficient and is respected all over the world. The NCV and Dutch competent authorities discuss all SCCS opinions.
Nanomaterials definition
Variations between the nano definition in the CPR and the horizontal Commission Recommendation have led to different interpretations and practices between member state authorities, negatively impacting the functioning of the internal European market. Therefore the NCV supports a clear and cross sectoral nano definition that is workable for SMEs, through an update to Commission Recommendation 2011/696/EU. When a horizontal definition is used, it should be taken into account that not all substances falling under the definition need to be managed the same way. Aspects like loss of nano properties in the finished product should also be used to determine which sector-specific regulatory measures are required.
Digital Labelling is the future
The NCV welcomes the evolution of means by which information can be provided to consumers. The absence of specific provisions on consumer information for online sales in the Cosmetic Products Regulation (“CPR”) is not ‘future-proof’. There is a need for regulatory coherence between the upcoming significant increase in information requirements on one hand (transparency initiatives), and the challenges of packaging & packaging waste on the other hand. Providing information digitally is an opportunity to better communicate in a more comprehensive way with consumers, thus benefits the consumer.
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