THE HELLENIC COSMETIC TOILETRY & PERFUMERY ASSOCIATION
PSVAK
PSVAK represents the Greek Cosmetic Industry and is a member of Cosmetics Europe
ID: 922699544549-07
Lobbying Activity
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
The Hellenic Cosmetic, Toiletry and Perfumery Association is the Greek Association for Cosmetics, founded in 1964, with 72 members cosmetic producers and distributors, mainly SMEs and member of the Cosmetics Europe Association. We welcome the European Commissions proposal on the Packaging and Packaging Waste Regulation (PPWR) and we fully support its overarching goals. The cosmetics industry is committed to improving the sustainability and circularity of its products. We would also like to thank the Commission for the opportunity to send our comments. PSVAK is fully aligned with the Cosmetics Europes Position Paper and we will present a summary of these comments in this paper. We would like to express our concern that many provisions in the proposal allow member states to introduce specific national requirements that would cause problems to the harmonization and the good functioning of the EU Single Market (e.g., Art. 4 (5) on labelling requirements). In this context, harmonized packaging and labelling rules across Member States are essential. We welcome the inclusion of cosmetics under the contact sensitive category as the packaging of cosmetic products requires high quality secondary materials to ensure consumer safety. We would like to point out that reaching the recycled content targets would not be feasible, considering the scarce availability of high quality secondary raw materials. Hence, it is essential to recognize advanced / chemical recycling as complementary to mechanical recycling. It is important that equal access to the high-quality recyclates is maintained for all sectors. Recyclability should be guaranteed regardless of size. The Design for Recyclability criteria to be established under the delegated act, shall consider the requirements for small packaging with due consideration to collection, sorting, and recycling processes. We support a target calculation for recycled plastic as an average of all plastic packaging placed on the EU market by an economic operator rather than per unit of packaging. We support the objective of packaging minimization measures but the related rules should not lead to packaging standardization and/or the limitation of companies flexibility in the design of packaging which would lead to a decreased global competitiveness for the European cosmetics industry. Manufacturers will need adequate transition time to comply in order to develop design alternatives, to change manufacturing lines and phase out the packaging types in scope. Regarding the obligation related to excessive packaging (article 21) and the empty space ratio for e-commerce, we would like to propose a different methodology for single products and group products. We fully support the harmonization of packaging-related labelling requirements and the replacement of national sorting instructions and other country-specific labelling of the material composition with harmonized labelling. We believe that the use of digital means should be fostered to strike a balance between the increased consumer information and labelling requirements and the obligations of packaging minimization. On-pack symbols should be used only when necessary and text that requires translations should be entirely avoided. Digital labelling should be allowed through a single data carrier to build towards the future digital product passport. Manufacturers should be given adequate time to comply with new labelling requirements. Additionally, full stock disposal and exhaustion of packaging manufactured or imported before the application of the different obligations should be allowed so as not to cause waste. Implementing acts should be published as soon as possible. It is necessary to allow for the exhaustion of stocks of packaging manufactured or imported before the application, so as to minimize waste and destruction of unsold goods. We attach the relevant Position Paper of Cosmetics Europe to further explain our position.
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
30 Mar 2023
The Hellenic Cosmetic, Toiletry and Perfumery Association (PSVAK), founded in 1964, is the Greek Association for Cosmetics and has 72 members (manufacturers, producers, and distributors). PSVAK is a member of Cosmetics Europe, the European trade association for the cosmetics and personal care industry. PSVAK fully supports the Cosmetics Europes position paper on the European Commissions Proposal for the Revision of CLP. We would like to thank the Commission for providing us with the opportunity to communicate our comments on this proposal. Our Association fully supports the European Green Deal and the Chemicals Strategy for Sustainability and is committed to working towards a pollution-free Europe and an environment free of toxic substances. In this context, we welcome the European Commissions Proposal for the Revision of CLP, and we support its general objectives. However, we would like to highlight some of our concerns regarding mainly the More than One Constituent Substances (MOCS). The proposed revision of CLP introduces a new definition for multi-constituent substance (MOCS) and specific classification rules described in Article 5. Article 5 states that MOCS should be classified as done with intentionally made mixtures. This rule has very low concentration limits for constituent substances that carry a classification and restricts the use of relevant, available toxicity data on the MOCS only to confirm the classification given by the mixture rule, or to give a more severe classification. Actual experimental test data would no longer be used even if it concludes on non-classification. Even if a multi-component substance, such as a natural extracts or essential oil, has been tested in an adequate test system and found not to have CMR properties, it would still have to be classified as CMR if a classified constituent is present above a certain threshold, despite the fact that classification of the single constituents is based on their behavior when used pure and undiluted. These classification thresholds are theoretical default values which are not determined based on scientific studies and they are given more weight in the classification than actual test data. This could lead to the unnecessary classification, and consequent loss, of numerous extracts that are safely used in cosmetics (citrus fruits are a prime example), just due to a constituent that may be considered "most harmful" at low concentrations. Formal classification of a substance as CMR or ED triggers automatic bans in consumer products, including cosmetics. As a consequence, under this new approach hundreds of ingredients, mainly from natural origin, could therefore be banned as CMR substances, although actual test data would show that they do not have CMR properties. Therefore, Cosmetics Europe and PSVAK ask that when reliable toxicity information is available for the complete natural substance, it should take priority over the rule of mixtures for classifying naturals in all hazard categories. There is no justified reason to selectively deviate from this principle for specific hazard categories.
Read full responseResponse to Proposal for a basic regulation of the European Chemicals Agency
10 Oct 2022
We would like to thank the Commission for providing us with the opportunity to communicate our views on this important subject.
Our Association fully supports the European Green Deal and the Chemicals Strategy for Sustainability and is committed to protect human health and the environment, supporting the transition towards the use of sustainable chemicals.
At PSVAK, we agree with Cosmetics Europe (CE) comments, and we support a stand-alone Scientific Committee on Consumer Safety (SCCS) within ECHA.
The SCCS has accumulated extensive and detailed data on how consumers are exposed to cosmetics and their ingredients, and this cosmetic specific knowledge is a key to the accurate safety assessment of the products and assurance of consumers safety. Its expertise on alternative methods to animal testing is essential for the Cosmetic Products Regulation concept of animal testing ban.
The SSCS Notes of Guidance, the Opinions on ingredients, the New Approach Methodologies (NAM)/ New Generation Risk Assessments (NGRA) for non-animal testing are sector specific scientific assessments and they are essential for the cosmetics safety as well as internationally recognized.
A commitment to enable and continuously grow the expertise of the SCCS would in turn allow continued development of new methods for the safety assessment of cosmetic ingredients and products, leading to increased consumer confidence, and thus facilitating trade and exports of EU cosmetic products.
The current mission and workload of the SCCS to RAC would lead to a discontinuity and a delay of the scientific and innovation development of european cosmetics. We fully support the CE call for a separate committee dedicated to work stemming from the CPR, within ECHA. We also support the concept of the industry paying fees per dossier, as proposed by CE.
Having such a committee only contributes to the CSS aim to improve the effectiveness, efficiency, and consistency of safety assessments while at the same time, ensuring the long -term competitiveness of the European cosmetics industry.
As a conclusion, PSVAK welcomes the implementation of OSOA as the basis for further assessment of the chemicals on a sector specific way. SCCS should maintain its independent role and continue its work as an expert committee within ECHA.
The Hellenic Cosmetic, Toiletry and Perfumery Association, founded in 1964, is the Greek Association for Cosmetics. Our Association is a member of Cosmetics Europe and has 70 members (manufacturers, producers, and distributors) that are mainly categorized as SMEs.
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