OpenLobby.EU
Explore

Polski Związek Przemysłu Kosmetycznego

Kosmetyczni.pl

Polski Związek Przemysłu Kosmetycznego is a leading association representing cosmetic producers and distributors in Poland.

Lobbying Activity

Meeting with Anna Zalewska (Member of the European Parliament)

28 Jan 2026 · Omnibus VI i Omnibus środowiskowy

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and Procter & Gamble and

27 Jan 2026 · Omnibus VI

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur)

5 Dec 2025 · Omnibus VI

Meeting with Joanna Scheuring-Wielgus (Member of the European Parliament)

4 Dec 2025 · Omnibus VI

Meeting with Marcin Sypniewski (Member of the European Parliament)

3 Dec 2025 · Deregulation in the cosmetics industry

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur)

20 Nov 2025 · Omnibus VI

Polish cosmetics industry urges harmonized EU recycling rules

6 Nov 2025
Topic — The Circular Economy Act aims to enhance sustainability and facilitate free movement of products.
Message — The union advocates for harmonized recycling schemes and uniform labelling to remove trade barriers. They request a temporary pause on wastewater rules to ensure a fairer distribution of costs. They also want legal recognition for chemical recycling to boost material supplies.123
Why — Uniform rules would lower compliance costs and eliminate fragmented national requirements.4
Impact — State-run recycling agencies would lose administrative control and funding to industry-led schemes.5
Read full response

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur)

6 Nov 2025 · Omnibus VI

Meeting with Piotr Müller (Member of the European Parliament)

9 Oct 2025 · Simplification of certain requirements and procedures for chemical products

Polish Cosmetics Industry Demands Wider Chemical Recycling Rules

13 Aug 2025
Topic — This initiative establishes rules for calculating recycled content in plastic beverage bottles.
Message — The organization requests that legal rules for chemical recycling apply horizontally to all industrial sectors. They argue these methodologies should be included in the wider Packaging and Packaging Waste Regulation.12
Why — This would allow cosmetic companies to meet mandatory recycling targets using high-quality materials.34
Read full response

Polish cosmetics industry seeks delay in product disposal reporting

10 Jul 2025
Topic — New EU rules require companies to disclose data on destroyed unsold consumer products.
Message — The Union calls for aligning reporting start dates with the finalization of the data format to ensure regulatory certainty. They also demand the removal of mandatory third-party verification and stronger protection for commercial secrecy.123
Why — This would reduce administrative expenses and prevent the leakage of sensitive commercial data.45
Read full response

Meeting with Tobiasz Bocheński (Member of the European Parliament)

7 Mar 2025 · Exchange of views on the legislation related to the cosmetics industry

Meeting with Elżbieta Katarzyna Łukacijewska (Member of the European Parliament)

5 Mar 2025 · International Women's Day with Polish cosmetics:

Meeting with Michał Kobosko (Member of the European Parliament)

5 Mar 2025 · Key regulatory challenges

Polish cosmetics industry seeks fairer wastewater treatment funding rules

4 Mar 2025
Topic — New EU strategy to manage water resources, tackle scarcity, and reduce pollution.
Message — The industry seeks a just and fair EPR scheme for wastewater treatment. They request financial support to ensure necessary investment, similar to decarbonization programs.12
Why — This would reduce compliance costs by spreading wastewater treatment fees across more sectors.3
Impact — Other polluting sectors would face new fees to fund urban wastewater upgrades.4
Read full response

Polish cosmetics industry urges end to national labelling barriers

29 Jan 2025
Topic — The consultation aims to strengthen the single market by removing cross-border regulatory obstacles.
Message — The union demands the immediate withdrawal of national labelling requirements and the transition from directives to regulations. They also call for a "simplification revolution" to reduce the burden of environmental overregulation.123
Why — Harmonized rules would reduce production expenses and eliminate redundant administrative tasks across different countries.45
Impact — National governments would lose the ability to mandate specific waste-sorting labels for their citizens.6
Read full response

Response to Commission Roadmap to phase out animal testing

15 Oct 2024

The European Commission's roadmap to phase out animal testing in chemical safety assessments - a call for evidence The Polish Union of the Cosmetics Industry welcomes the opportunity to contribute to the European Commission's roadmap to phase out animal testing in chemical safety assessments and underlines its full support for the phase-out of animal testing. We are convinced that current and future scientific advances will provide valuable tools to ensure an adequate level of protection for human health and the environment, with the goal of ending reliance on animal testing in chemical safety assessment. The Commission states that the development and implementation of the roadmap to phase out animal testing will need a coordinated effort, involving all stakeholders and taking into account scientific, regulatory and technical challenges. The cosmetics and personal care industry already routinely performs non-animal safety assessments under the Cosmetic Product regulation and can already provide examples of how non- animal methods (NAMs) and next-generation risk assessment (NGRA) frameworks can be applied. This is possible with the use of scientific exposure-led approaches such as NGRA which ensure a high level of protection while preventing unnecessary animal testing. Use of NGRA approaches for cosmetic safety assessment has been facilitated by the inclusion of NGRA frameworks for skin sensitisation and systemic safety assessment in recent editions of the Scientific Committee on Consumer Safety (SCCS) notes of guidance. The Union also supports the Commissions emphasis on collaboration, which should be across sectors and at a global level for an internationally harmonized approach to phasing out animal testing. Having a paradigm shift implemented in Europe without global alignment on the criteria and protection goals of new safety requirements would be counterproductive. The lack of alignment could result in companies being required to conduct animal testing for some regions, or to perform duplicative testing to meet different market standards, thereby undermining the objective of phasing out animal testing and causing a waste of resources. Even though non-animal approaches are already able to provide a high level of protection, the Union wants to stress that the current hazard classification system is not fit for NAMs, which eventually has an impact on the regulatory requirements in downstream regulations, e.g., REACH and CPR. This, ultimately, will impact industry innovation capacity and competitiveness, hence the need to ensure appropriate uptake into the regulatory framework. It should also be highlighted that validation is not the only component of international acceptance; while concurring with the need to modernize the existing validation process, such as by revising OECD GD 34, other obstacles also need to be tackled, e.g., different regulatory requirements in different geographies. The Polish Cosmetics Industry Association looks forward to building on the cosmetics industrys experience with NAM over several decades and continuing to work with European and international scientific and regulatory stakeholders on non-animal safety assessments. The Union kindly requests consultation on the next steps of the Commissions roadmap, including the targeted public consultation foreseen in the call for evidence.
Read full response

Meeting with Krzysztof Hetman (Member of the European Parliament)

10 Sept 2024 · Cosmetics industry in the EU

Polish cosmetics industry seeks clarity on chemical data platform

4 Apr 2024
Topic — EU initiative to create a common platform for sharing chemical safety data.
Message — The union requests clearer definitions for key terms and a precise scope for study notifications. They advocate for an exhaustive list of reportable studies and exemptions for research activities. Additionally, they stress that data sharing must respect the protection of proprietary information.123
Why — Specific exemptions and clearer rules would reduce compliance costs and protect trade secrets.45
Read full response

Polish cosmetics group urges independent scientific committee within ECHA

3 Apr 2024
Topic — EU proposal to centralize chemical safety assessments across various legislative frameworks.
Message — The Union requests that the Scientific Committee for Consumer Safety remains an independent body. They demand that sector-specific risk assessment be maintained to preserve non-animal testing expertise.1234
Why — This preserves regulatory pathways for ingredients that might otherwise face hazard-based bans.56
Impact — Health advocates lose if the transition to a stricter hazard-based approach is blocked.7
Read full response

Meeting with Elżbieta Katarzyna Łukacijewska (Member of the European Parliament)

5 Dec 2023 · Greenwashing directive

Polish Cosmetics Union Warns Green Claims Rules Risk Market Clog

21 Jul 2023
Topic — A proposal requiring companies to verify environmental claims using standardized footprint methodologies.
Message — The Union requests a 36-month implementation period and a clear definition of scientific evidence. They propose allowing partial self-verification to prevent administrative bottlenecks and high compliance costs.12
Why — This would reduce the financial burden and prevent delays in product launches.34
Impact — NGOs and rating apps would face stricter regulations if the Union's transparency demands are adopted.5
Read full response

Polish cosmetics industry seeks flexible design and digital labeling

24 Apr 2023
Topic — Reviewing EU rules for packaging design, waste reduction, and mandatory recycling targets.
Message — The Union wants to maintain the definition of contact-sensitive packaging for cosmetics. They request that recycled content targets apply to a company's total portfolio. The organization calls for digital labeling options and freedom in packaging shapes.12
Why — This allows brands to maintain unique packaging shapes while lowering compliance costs.3
Impact — National authorities would lose the power to implement specific domestic sorting instructions.4
Read full response

Polish cosmetics group warns EU classification rules threaten natural oils

30 Mar 2023
Topic — Revision of European rules for classifying and labeling hazardous chemical substances.
Message — The group demands that natural extracts be classified as single substances rather than mixtures. They argue that actual safety data must override automatic mathematical classification rules.12
Why — This allows manufacturers to keep using traditional natural ingredients without costly reformulations.3
Impact — European agricultural workers and distillers would lose their livelihoods from aromatic crops.4
Read full response

Polish cosmetics industry urges fair polluter pays wastewater rules

14 Mar 2023
Topic — The European Commission is revising rules on treating urban wastewater and micro-pollutants.
Message — The association argues all polluting industries, not just cosmetics and pharmaceuticals, should fund the system. They request a narrower definition of micro-pollutants based on whether substances survive current treatments. They also seek clearer rules to prevent paying fees multiple times within the supply chain.123
Why — Narrowing the pollutant list would exempt many ingredients, reducing the industry's total compliance costs.45
Impact — Other industrial sectors currently excluded would be forced to pay for wastewater treatment upgrades.6
Read full response

Meeting with Marek Paweł Balt (Member of the European Parliament, Shadow rapporteur)

11 Mar 2023 · Urban water treatment

Polish cosmetics industry seeks independent safety committee within ECHA

10 Oct 2022
Topic — New rules to modernize governance and update the European Chemicals Agency's mandate.
Message — The Union requests keeping the Scientific Committee for Consumer Safety as an independent body. They argue sector-specific expertise is essential for reliable risk assessments of cosmetic ingredients.12
Why — Retaining a dedicated committee prevents slow review processes that hinder market access.3
Impact — Consumers may face safety risks if specialized expertise in cosmetic exposure is lost.4
Read full response

Polish cosmetics industry backs chemical data sharing initiative

16 Aug 2022
Topic — Improving chemical data access and reuse for more effective safety assessments.
Message — The organization supports the proposal to facilitate data flow across different stakeholder groups. They emphasize that transparency rules must respect data ownership and trade secrecy to avoid increasing administrative burdens.12
Why — The industry would benefit from reduced administrative burdens and simplified chemical reporting procedures.3
Read full response

Response to Sustainable Products Initiative

22 Jun 2022

The Polish Union of the Cosmetics Industry supports the objectives of the Green Deal and the European Commission's proposal for a Regulation on Ecodesign for Sustainable Products (ESPR). Cosmetic products are outside the scope of the ESPR in the first step. However, the European Commission is considering the extensive application of ecodesign requirements in the future and the application of the general regulatory framework to many product categories through delegated acts. Therefore, the Union presents some observations from the point of view of the cosmetics industry in the attached position paper. These comments may be useful in adapting the future regulatory framework to a wide range of products. • The Union supports the proposal to adopt EU ecodesign requirements as a regulation. Harmonization of the regulatory framework in the EU could be important factor accelerating the implementation of circular economy, both at the EU level and in individual Member States. Harmonizing ecodesign rules at EU level is vital to protect the integrity and smooth functioning of the Community market. • However, supporting instruments should be provided to promote a level playing field for SMEs and for enterprises from countries less advanced in the field of environmental regulations and technologies, such as Poland. • In addition, during the preparation of the draft regulation, the Commission declared that, for many products, third party certification by accredited bodies would be required to demonstrate that the product complies with the ecodesign requirements. The possible costs of such third-party certification and the impact on the SME sector must be carefully assessed. It is likely that the cost of externally certifying each product will be difficult or impossible for most SMEs. Moreover, in some countries necessary expertise in the field of environmental assessment of products is hardly available. • The rules on destroying unsold consumer goods also raise some regulatory uncertainty. The ban on the destruction of unsold consumer products exposes economic operators to additional costs associated with the indefinite storage of products that cannot be sold or destroyed. In addition, the regulation should provide for legal solutions for contract manufacturing. Detailed comments are presented in the attached position paper.
Read full response

Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

29 Oct 2021

The Polish Union of the Cosmetics Industry supports the goals of the Green Deal and the Chemicals Strategy for Sustainability. Safety is highest priority of the cosmetics industry. The revision of the regulation 1223/2009/EC should ensure, that this regulation would continue to be the consumer-oriented, strongest cosmetics sector regulatory system for cosmetics in the world, based on science-based sectoral risk assessment and ensuring highest level of cosmetics products safety for consumers. Moreover, the revision should recognize the long history of safe use and high level of cosmetics product safety in the EU and essential value of cosmetics to consumers and society. Any new approach to safety assessment of substances under regulation 1223/2009/EC should take scientific state-of-the-art in toxicology and risk assessment. It should also consider and respecting the sectoral ban of animal testing in place in the cosmetics regulation 1223/2009/EC. Safety should be the first and overriding rule in the application of Generic Approach to Risk Assessment (GRA). GRA approach should be applied only in case there is unacceptable risk AND when safety assessment (risk assessment) can not be performed, or safety can not be proven in such risk assessment. No substances should be subject to ban with regards to the classification only, without appropriate risk assessment. GRA mechanism existing in the regulation 1223/2009/EC could be adapted to most harmful substances according to Chemicals Strategy for Sustainability. Essentiality criteria should be considered with regards to the substance (not the product) and should be based on the availability of alternatives – for specific substance in specific applications. Such assessment should be done by the appropriate organ (i.e., SCCS), according to transparent and well-established rules. Potential combination effects (with regards to Mixture Assessment Factor) are already subject to legal provisions under the regulation 1223/2009/EC and Commission’s Implementing Decision 2013/647/EC and are taken into account in safety assessment of each cosmetic product. One Substance – One Assessment approach (OSOA) could be very useful concept, to facilitate the effectiveness of safety assessment process for chemicals in the EU, provided it is understood and applied as one substance – one hazard assessment approach – OSO(H)A. All sectors using the substance could take advantage from as access to one, full dataset regarding the hazard information. This hazard data set be a starting point for risk based, sector-specific risk assessment. Risk assessment of cosmetics ingredients should be still performed by the dedicated, qualified group of experts, such as Scientific Committee on Consumer Safety. Regardless the location of SCCS according to the EC decision, maintaining the role and composition of the Committee as well as maintaining the methodological approach to the risk assessment for cosmetics ingredients – is key. SCCS is a highly specialized, experienced, and independent committee of experts, specialists in various toxicological sciences and represents unique scientific knowledge in risk assessment of cosmetics ingredients. It is unique and the most specialised committee of experts in risk assessment of chemicals using data from alternatives to animal tests. The Union supports the revision of the nanomaterial definition. Aligning current definition of nanomaterial adopted in the CPR with a horizontal definition included in Commission Recommendation 2011/696/EU would increase coherence between legislation on the EU level. The Union welcomes the proposal of implementing the digital labelling to the CPR. It can simplify the consumer information and significantly increase cost-effectiveness for industry, especially if it allows quick adaptation of information. Full version of Union’s comments to the IIA document on the revision of regulation 1223/2009/EC is attached.
Read full response

Response to Sustainable Products Initiative

16 Nov 2020

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals. The Union would like to raise the following elements to be considered by the European Commission policy in shaping the Sustainable Products Policy Framework: • Overarching product sustainability principles should be clear and objective; these should be provided as a harmonised framework that is adaptable to the wide variety of product categories. This set of principles need to ensure the nature of the products is taken into consideration. The new requirements should not infringe existing sectoral legal requirements, including those regarding safety of the product to the final consumer. • The cosmetics industry is investing increasingly in the development of more sustainable products and it it is innovation-based. The new sustainability framework should be flexible and would be essential for maintaining the incentive to innovate, both at the product and at the methodology level. Flexible framework would allow companies and SMEs to voluntarily implement and communicate those improvements to consumers and value chain with the necessary agility. • Regarding the objective to increase recycling and recycled content, before setting any threshold the availability of recycled content supply of sufficient quality and quantity must be secured and specificities of the different product categories must be considered. Availability of the recycled materials on the market should be considered. Recyclability of the new product containing recycled material should also be taken into account (an example: rPET is more available than rPP or rPE, but PET is less preferable as non-food packaging by the recyclers, at least in some countries). • With regard to mandatory product-related sustainability information, a tailored approach is needed for the various sectors, based on the relevant environmental characteristics of their products, to provide meaningful information to consumers – and support their informed choice - as well as to relevant actors along value chains. o The use of digital information channels should be encouraged. Digital provision of information has the potential to communicate more efficiently, and in an adapted way, information to consumers. It can also, for example, contribute to reducing packaging waste. o In our view it is unlikely that one method alone (such as the Product Environmental Footprint – PEF) could be used for all the sectors concerned to reduce the environmental impacts of goods and services taking into account supply chain activities. Rather than a mandatory implementation of the PEF tool across all products and sectors, alternative and complementary sectorial approaches based on various robust and science-based methodologies should be allowed in order to accurately address the diversity of environmental features that could be communicated to consumers. • The management of unsold stocks is an important concern of the cosmetics sector. The companies in their daily business try to minimize as much as possible the destruction of products that are suitable for consumption and its potential negative impact on the environment, while preserving competitiveness. o There are already many industry-led initiatives conducted to improve recycling, reuse and donation of cosmetics and personal care products. These industry initiatives should be promoted and supported. o The reuse (donation) of cosmetic products is mainly carried out through donations in partnerships with charitable organizations but also through ad hoc outlets. Flexibility should be kept and given to industry on how to conduct these donations. o Donations may present the risk of supplying parallel markets for products operating through selective distribution channels.
Read full response

Response to Review of the general product safety directive

1 Sept 2020

The Polish Union od the Cosmetics Industry welcomes the opportunity to engage with the European Commission on the New Consumer Agenda and related files. In regard to the Commission’s roadmap on the review of the General Product Safety Directive (GPSD), the Union considers the following principles are critical elements for the upcoming European Commission policy discussion in this field: • The GPSD is an important regulatory tool for safeguarding consumers’ safety in the EU. Its fundamental approach, scope and principles are still very much up to date and valid. • The Union agrees with the EC that the GPSD may not sufficiently address some new technologies and online distribution channels which can impact product safety. Due to their horizontal nature, these aspects are better regulated at horizontal level than in sector-specific legislation. Effective instruments for enforcement of existing requirements on national level should be developed via horizontal regulations mentioned before. • The Union would like to notify the EC that more clarity is needed on the functioning of the GPSD provisions on the Safety Gate: Rapid Alert System for dangerous non-food products (formerly RAPEX). We observe is a growing tendency of notifications of products that are simply ‘non compliant’ but do not pose a serious risk. Moreover, there were cases in the past that compliant products were notified in the system. • The Union does not take definite position on the preferred regulatory option but taking the above critical points into account, options 1 or 2 could be considered. The Polish Union of the Cosmetics Industry looks forward to contributing actively to the future policy discussions on the review of the General Product Safety Directive.
Read full response

Response to Environmental claims based on environmental footprint methods

31 Aug 2020

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals. The Polish Union of the Cosmetics Industry considers the following elements are critical for successful and reliable substantiation of environmental claims: • The definitions and scope of applicability of methodology proposed must be clearly defined and assessed. • There is a crucial need to define a clear and objective set of criteria and approach to assess products’ environmental impact. However, these should be provided as a harmonised framework (approach, common criteria) rather, than as specific legal requirements including detailed methodology. • The producer should be free to choose the specific method for substantiation claims being subject to the proposal. It is difficult to find one reliable method that is adequate for all types of products. • The PEF methodology isn’t still wildly known and applied in Poland. Our members and we as an organisation do not know that method yet in details and cannot provide details comments on its applicability to specific cosmetic product category. We haven’t seen any companies refer to it in their publications yet. We need adequate time to understand and test such a method. • Mandatory and a clear regulatory framework for claims made with regards cosmetic and personal care products already exist. It included mandatory substantiation of claims by evidence, the problems connected with environmental claims could be (at least partially) addressed by better enforcement of the existing requirements. It could be strengthened through the development of guidelines, in particular regarding relevant environmental impact characteristics for cosmetics. • Any new approaches for green claims substantiations should protect the integrity of Internal Market. Differentiations of obligatory national approaches and methods should be avoided as it would lead to the fragmentation of internal market, being detrimental for both – consumers and industries. We have reservations with regards to the Likely economic impacts presented in the Inception Impact Assessment. It is hard to believe that introduction of PEF methodology will reduce overall costs. It is rare situation companies have to apply several various methods for PEF at the same time. For the same reason – impact for SME could be significant as those companies has usually less resources, than the big ones. It could be expected the new methodology may have impact on products prices. The Polish Union of the Cosmetics Industry looks forward to contributing actively to the future discussions on the environmental claims substantiation.
Read full response

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

6 Aug 2020

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals. The Union considers the following elements are critical for successful and sustainable implementation of essential requirements including improvement of packaging recyclability: • The European Single Market: The gradual fragmentation of the Single Market must be prevented, and its smooth functioning and the free movement of goods, so vital to competitiveness and growth, must be assured by removing barriers. • State of play in various MS: While it is legitimate for striving for full harmonisation of rules on packaging cross the internal market, it is necessary to take into consideration state of play in the area if the waste management systems in various Member States. Appropriate transitional measures/ transitional time should be granted to allow less advances countries to adapt to the new requirements. • Education: Systematic education should be part of any system improving recyclability of the packaging. • Safety: Any requirements with regards to the circular packaging, such as re-use, recycled content etc., must not compromise stringent EU regulatory regimes for human safety. Cosmetics industry specificities and regulatory regime including product safety should be taken into account in the context of packaging’s functionality. • Re-use: Promotion of the re-use packaging systems should take into account the existing safety, quality and good manufacturing practice requirements for particular categories of pre-packed goods. • Recyclability: Recyclability should be precisely defined and harmonized at EU level. Harmonized EU methodology to assess recyclability should be set, such as e.g. International (ISO) or European (CEN) standards. This methodology should be accepted and applied by all EU Member States. As a result, recyclability tested in one Member State should be accepted by all other EU Members States. • Mapping of packaging recyclability across EU should be done as important starting point for implementing requirements for full recyclability of packaging. • Recycled content: Targets for recycled content, if set, should take into consideration safety requirements in particular category of consumer goods (e.g. cosmetics products) as well as availability of secondary materials. Recyclers and recycling infrastructure need investments to make recycling of non-food post-consumer plastics packaging cost-effective. • Bio-plastics: Clear rules and recommendation of sorting and recycling for each types of bio-plastics are necessary to make proper communication to the consumer. • Overall environmental performance: A holistic assessment of the environmental impact of packaging should be applied. • COVID-19 pandemic impact on economic condition of sectors should be taken into account. Please find attached more detailed position.
Read full response

Response to Chemicals strategy for sustainability

19 Jun 2020

The Polish Union of the Cosmetics Industry fully supports the European Green Deal goals and its initiatives, including Chemicals – strategy for sustainability (CSS). Protecting citizens and the environment while at the same time encouraging innovation through safety and sustainability is the best way for European growth. Addressing the CSS, the Union would like to highlight the following issues: • The CSS should recognize the existing regulatory frameworks that already provide robust tools, such as Cosmetic Products Regulation EC 1223/2009 • Science and innovation must be at the heart of the CSS. • The CSS should strengthen the enforcement of applicable regulations and eliminate differences between national regulations of individual EU members and EU regulations. • The Union is calling upon a coherent, integrated and scientifically based approach of eliminating all unnecessary animal testing in implementation of CSS. • The Union welcomes the fact that CSS will support the digital transition. • CSS should include an educational campaign informing about the risks and benefits of using chemicals. CSS should clearly indicate the differences between risk and hazard. • The Union supports an approach of “One substance - One Hazard Assessment” where hazard characterisation of chemicals is managed horizontally across sectors. Sectoral regulations should, however, be still based on risk management. Sector-specific scientific risk assessment-bodies (such as ECHA, SCCS, EFSA, EMA) should all have full access to the hazard data and use similar methodologies to quantify the real-life risk for their specific use scenarios. Detailed position of the Polish Union of the Cosmetics Industry is attached.
Read full response

Response to Labelling fragrance allergens

2 Jan 2019

The Polish Union of Cosmetics Industry would like to thank the European Commission for making the Impact Assessment “Labelling fragrance allergens” available for public consultations. In general, the Union supports the initiative of the European Commission. Consumers’ safety is of highest priority to regulators and cosmetics industry in the EU. However, we believe the European Commission, taking final decision on the fragrance allergens regulatory proposal, would take into account its technical feasibility and its real impact on the safety of European Consumers. As the Union already expressed in 2014, information on the potential fragrance allergens on the packaging has little or no value for consumers who are not allergic to these substances. The Commission on the Inception Impact Assessment states that overall the frequency of contact allergy to fragrance ingredients in the general population in Europe is 1-3%. Therefore, labelling of 87 fragrance allergens is addressed to 1-3% of people using cosmetic products. The average patient has no possibility today to confirm sensitivity to most of 87 fragrance ingredients. The availability of diagnostic tests did not changed from 2014 and tests for most of 87 are still lacking, beside the 14 used in Fragrance Mix I and II. Patients and dermatologists would not be able to benefit from the proposed labelling until all 87 fragrance ingredients would be included in the standard patch tests. Another problem is a general lack of willingness of patients to be a subject of detailed, substance-by-substances diagnostic allergy tests. Only small proportion of patients suffering from dermatitis resulting use of cosmetic products decide to be subject of detailed diagnostics. Even when diagnostic tests for all 87 fragrance ingredients would become available, it could be expected that a percentage of patients subject to such tests would be low. Regardless which option will be chosen as a tool to inform the consumers, any regulatory proposal should take into account technical feasibility and real impact on the safety of European Consumers. Finally, the Commission is aware that most of the products on the market would require re-labelling to include information on additional fragrance ingredients, whatever form of information would be finally agreed. It means great costs for the overall industry. Appropriate transitional periods should be envisaged accompanying any regulatory proposal with regards to the labelling of fragrance ingredients. The Polish Union of Cosmetics Industry appreciates to be considered a stakeholder by the European Commission in the area of fragrance allergens labelling and is willing to contribute to the future consultations and activities.
Read full response

Response to Amendments following Article 15 of the cosmetic Regulation 1223/2009

24 Jul 2017

The Polish Union of Cosmetics Industry welcomes the listing in Annex II of CMR substances that were classified after 2010 and are not subject to an exemption procedure. The inclusion of CMR substances in the list of prohibited substances in Annex II to Regulation (EC) No 1223/2009 is necessary in order to ensure legal certainty, in particular for economic operators and national competent authorities, and to ensure consistency throughout the different industrial sectors. However, the Polish Union of Cosmetics Industry would like to raise several issues concerning the individual substances covered by the draft of Commission Regulation. In the position presented in attachment, the Union is addressing four issues: 1. The transition period for regulatory changes with regards to the following substances: Trimethylbenzoyl Diphenylphosphine Oxide (TPO); Furfural, Polyhexamethylene Biguanide Hydrochloride (PHMB),. 2. The ban of Formaldehyde in nail hardeners although the exemption procedure is ongoing. 3. The ban of Hydroquinone without the exemption for artificial nail products. 4. The ban of Paraformaldehyde and Methylene Glycol.
Read full response

Response to Structures of excise duties on alcohol and alcoholic beverages

28 Mar 2017

The Polish Union of Cosmetics Industry strongly welcomes the EC initiative of the directive 92/83/EEC REFIT and possible revision. The current regulatory systems enabling very restrictive approach in the area of partial denaturation of alcohol discriminates the business operators of the cosmetics industry in some of the EU Member States. Please find attached the detailed Union's comments on the Roadmap presented. Blanka Chmurzyńska-Brown General Director Polish Union of Cosmetics Industry
Read full response