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The International Natural and Organic Cosmetic Association

NATRUE

• NATRUE is an international non-profit association representing authentic natural and organic sector of the cosmetic industry.

Lobbying Activity

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

NATRUE, the International Natural and Organic Cosmetic Association, is an international non-profit association representing pioneering producers from global natural and organic cosmetics sector globally and welcomes the opportunity to provide input to the call for evidence and public consultation on the upcoming EU Bioeconomy Strategy. For decades our members have contributed to the bioeconomic output globally and demonstrated their commitment towards biobased products that offer both a strong science-based, risk assessment approach to consumer safety as cosmetics, whilst also supporting consumer informed decision-making, harnessing sustainable innovation using renewables resources that align with recent climate and circularity goals in the EU. Highly resonant with consumers, natural (biobased) products face challenges associated with market scalability where enhancing the capabilities of the European bioeconomy could foster the supply, innovation and scale necessary to achieve its full potential. Whilst natural cosmetics have a long and pioneering history in Europe, to meet the wide diversity of product categories and future scope for innovation and competitiveness expected by modern consumers, manufacturers require access to resilient, renewable and sustainable raw materials, greater investment in new (bio)technologies and biomanufacturing, and ultimately lower costs through market scalability. All aspects are essential to support the growth of the natural cosmetics sector. To this extent, financing for research and innovation to realise and accelerate the potential of the EU bioeconomy should facilitate both the necessary innovation in biobased materials, as well as expanding their availability and affordability particularly for SMEs - whilst ensuring that the necessary sustainability, traceability, and sectoral qualities necessary for downstream regulatory compliance are met. Awareness and differentiation between conventional and biobased products remain underlying issue. Consequently, fostering increased transparency through clear, non-discriminatory means to distinguish and compare fossil fuel and biobased products can offer enhance clarity, particularly amongst consumers, and provide a level playing field for economic operators. A new EU bioeconomy strategy must invest in long-term growth, resilience and competitiveness in balance with the clear needs to reduce the EU's dependency on fossil fuel feedstock. Increasing resource efficiency, access to agricultural feedstock for greater biomaterial production at scale, harnessing the circular bioeconomy (including upcycling and use of waste streams), and addressing fundamental macro (particularly energy) and sector-specific needs are essential. To successfully valorise and capitalise the bioeconomy, the strategy should include a package of realistic, specific and measurable actions whilst removing regulatory inconsistencies that may hamper market access or limit biobased innovation at scale, and risk regression to conventional (fossil) products. The strategy must not ignore the essential role of primary agricultural producers, nor the beneficial role biodiversity plays in provision and protection of renewable raw materials as part of a rounded sustainable and nature-based solution towards supporting bioeconomic growth.
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Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

NATRUE, the International Natural and Organic Cosmetic Association, represents pioneering producers from natural and organic cosmetics sector globally and welcomes the opportunity to provide input to the evaluation of the EU Cosmetic Products Regulation (CPR). Upholding a strong science-based, risk assessment approach to consumer protection and safety must be maintained as per the CPR's primary objective. Looking forward, the scope to support the needs of natural cosmetics sector, enhance the capabilities of the European bioeconomy, foster sustainable innovation, and accommodate digitalisation will remain essential to deliver on future consumer expectations. Please find the attached file for further details on NATRUE's position.
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Response to Legislation for plants produced by certain new genomic techniques

5 Nov 2023

NATRUE aisbl is an international non-profit association representing pioneering producers from across the global natural and organic cosmetics (NOCs) sector, and welcomes this opportunity to provide feedback to the EU Commissions legislative proposal for plants produced by certain new genomic techniques (NGTs). To-date whilst there is no official EU regulatory definition for the cosmetic product claims natural or organic, third-party certification to verifiable criteria from private, voluntary standards, such as NATRUE, has been well-established over the past 15-20 years. European markets including Germany, which is the largest market for certification worldwide followed by France and Italy, remain hubs for innovation using non-GMO natural and organic raw materials in-line with European consumer expectations. Furthermore, the predicted compound annual growth rate of NOCs from 2023-2027 are two to three-fold higher (Bloomberg) than for the cosmetic industry in-general, as trends to substitute fossil fuels and improve sustainability increase. Currently the most well-adopted private standards cover more than 40,000 products from brands associated with sectoral pioneers to multinational manufacturers; from retailers to startups. Certified products currently cover sustainable innovations across all cosmetic categories including body, oral, hair and sun care. Whether certified as either natural or organic cosmetic, a fundamental criterion for certification is that the raw material is neither made from nor by a GMO. Even as non-foods, when considering certified cosmetics, the claim non-GMO must uphold its integrity and consistency with consumer expectations from foodstuffs. For example, an organic shampoo might not always contain only organic ingredients; so, where natural substances (surfactants, emulsifiers) are used these must equally be non-GMO (i.e., origin and manufacture). This ensures non-GMO claims integrity, validity for certification compliance, and ability to meet consumer expectations. Consumers rightly demand transparent information. For NOCs this trust is reflected in the on-pack labelling associated with third-party certification to private standards. Just as in foods, the freedom to choose to buy or not buy products that contain NGTs is an important right for citizens. Furthermore, manufacturers and wholesalers, as well as independent and chain retailers, commonly review the criteria of certification seals for NOC. So, where non-GMO compliances cannot be supported, consumer trust in well-established seals, and the NOC sector at large, will be impacted. To-date the legal references in established private standards, which are applied in a harmonised manner internationally within and outside the EU, stem from existing EU law (e.g,. Reg. (EC) No. 1829/2003 and 1830/2003; Directive 2001/18/EC). Therefore, EU law has formed a basis to ensure non-GMO compliance for these schemes. Certification requires confirmation of the presence or absence of defined characteristics throughout the supply chain. The dilution or lack of adequate traceability would amount to the risk of imposing the entry of NGTs into the production stream to all food production systems, which forms the basis of raw materials for downstream operators in the NOC sector. Supply chain uncertainty would impact certification compliance and consumer trust. As such the same traceability requirements that apply to Category 2 NGTs should also apply to Category 1 NGTs. This includes the systematic identification of NGT-derived products and compulsory labelling throughout the production chain. The NOC sector has long been aligned with the overarching objectives of the European Green Deal. NATRUE urges policymakers to consider not only the impact on agricultural practices, particularly organic farming, but freedom of choice for downstream economic operators whose businesses are established to exclude GMOs through traceability and ensure consumer transparency.
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Response to Environmental claims based on environmental footprint methods

16 Jul 2023

NATRUE AISBL is an international non-profit association representing pioneering producers from global natural and organic cosmetics sector, and welcomes the opportunity to provide input to the publication of the EU Commissions proposal of a Green Claims Directive (GCD). The objectives to tackle greenwashing, ensure consumer trust for green claims and labels, and support the green transition are also reflected in the work of the association. Our attached contribution addresses some of the specific observations and considerations from the perspective of cosmetic manufacturers who already voluntarily certify natural and organic cosmetic products via private labelling schemes obligating third-party vertification. NATRUE remains at your disposal for any clarification you may have to discuss these questions and concerns.
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Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

31 Oct 2021

NATRUE represents pioneering producers from global natural and organic cosmetics sector, and welcomes the opportunity to provide input to the Inception Impact Assessment of the EU Cosmetic Products Regulation (CPR). The importance of the Green Growth agenda and upholding robust safety assessment for consumers and the environment resonant strongly the natural sector. To this end, NATRUE recognises that the CPR provides an international point of reference when it comes to ensuring a high level of consumer safety. Additionally, NATRUE wish to strongly emphasize the essential need to maintain a diverse palette of “Natural Complex Substances” (NCSs) (e.g., plant extracts, essential oils) in order to ensure consumers can continue to enjoy authentic natural and organic cosmetics meeting their expectations for these product claims. Generic Risk Management Approach – NATRUE notes that provisions to address combination effects are already accounted for within the CPR cf. Annex I. NATRUE remains extremely concerned that the long-term safe use of NCSs could be under threat through any potential substance ban regardless of the assessed exposure or individual risk to the consumer using the cosmetic. To this end, NATRUE would like to highlight that an existing mechanism of the CPR obligates assessment and regulation of CMRs; so, extension to hazard classes is not necessary. Demonstration of safe use must not be overwritten, even if the current CPR mechanism has potential to evolve in light of any first priority substances identified under the CSS. Essential Use – Natural cosmetics consumers are increasingly focused not only on what is in the product (i.e., natural or organic substances) but also the sustainability of the product as a whole. For natural cosmetics the essentiality of a substance(s) also goes hand-in-hand with the product claim(s) since consumers do not expect non-natural substances to be present in natural cosmetics. The risk to blanketly eliminate NCSs demonstrating safe use by considering them non-essential for product function, especially in cases when there may be no suitable natural alternative, would limit the palette of naturals and concomitantly reduce the ability of producers to meet consumers’ needs for natural and sustainable products. Overall, the foremost principle of demonstrated safe use must apply based on a scientific risk-based approach to avoid unjustified and disproportionate impact for natural cosmetic producers. Natural and organic cosmetics align well with the developing Green Growth agenda, and NATRUE offers to work with the Commission on this topic. One Substance, One Assessment (OSOA) – any application of OSOA should only apply to hazard assessment as a common starting point with the primary focus being robust sectorial legislation based upon risk. NATRUE would like to underline that given the pioneering non-animal testing provisions in the CPR not every toxicology endpoint has an accepted alternative method, so full data sets may remain unavailable for cosmetic product safety assessment. To this end, NATRUE would like to emphasise that it remains important to preserve a dedicated independent body with cosmetic expertise and experience, as is the case with the SCCS, who are equally familiar with safety assessment using alternatives methods to animal testing. Nanomaterial definition – NATRUE supports reducing divergency and ensuring a harmonised, clear, coherent definition of a nanomaterial. Digital labelling - NATRUE very much welcomes measures to simplify and digitalise labelling requirements. Consumers of natural cosmetics increasing demand greater transparency, and with consumers becoming more accustomed to digitalisation providing viable alternatives for natural cosmetics producers allowing labelling information off-pack would provide a clear opportunity to consumers and market surveillance authorities alike to access more information without undermining consumer protection or safety.
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Response to Labelling fragrance allergens

21 Dec 2018

NATRUE AISBL, the International Natural and Organic Cosmetic Association, supports the Commission's efforts to improve consumer health, transparency and informed decision-making, and would like to provide its feedback to the Inception Impact Assessment initiative from the European Commission in relation to labelling fragrance allergens. Overall, we find this document to cover many of the principle options related to consumer notification, and provides clear descriptions of the options and their impacts. For consideration we noted that intention to label further allergens should be equalled by consideration to ensure a viable connection between analytical methods for qualifying and quantifying these new substances including patch tests. NATRUE would see that e-labelling (Option 3) is preferable. Nevertheless, any approach to declare allergens on-pack or e-labelling should be consistent to avoid risk to the consumer and confusion. Therefore, a consistent approach would best reflect either Option 2 or Option 3; not Option 2 and Option 3. NATRUE welcomes this work by the Commission and appreciates the possibility to be considered as a stakeholder. To that end, NATRUE welcomes the ability to contribute further as part of the targeted and public consultation processes starting from April 2019. We remain readily available to provide any further information that may be required by the Commission.
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