Cosmetics Europe “urges” European Commission: Ensure green and digital transition
23 Jun 2022 --- Cosmetics Europe has set out recommendations for the European Commission to revise the Cosmetic Products Regulation (CPR) to ensure a smoother green and digital transition for the industry. It states that any revisions to the CPR should be collaborative, holistic and factor in the European Green Deal for coherency and consistency across legislations.
In its contribution to public consultation, Cosmetics Europe outlines the negative consequences of the Generic Risk Management Approach (GRA) and the Mixture Assessment Factor (MAF) on the cosmetic sector. This includes an unnecessary widespread invalidation and illegality of the majority of cosmetic products containing ingredients such as ethanol, certain UV filters and preservatives.
To avoid the unnecessary negative impacts of cosmetics that are already regulated and recognized as safe by the current CPR ingredient management, Cosmetics Europe outlines six main factors the European Commission should take into account when revising the CPR.
Six factors to keep in mind
Its propositions include the promotion of a globally sustainable competitive cosmetics sector, entrepreneurship and innovation capacity and strengthening its effective, efficient and science-based approach to addressing human and environmental safety for consumers, industry and authorities.
Additionally, emphasis is placed on acknowledging the history of a high level of safety of European cosmetic products and keeping scientific safety-based risk assessment at the core. Cosmetics Europe focuses on maintaining the “Gold Standard” of the CPR as an international reference.
It also wishes to ensure that regulatory burdens are manageable and achievable by small and medium-sized enterprises (SMEs) and be future-proofed by introducing digital labeling provisions. 
Cosmetics Europe flags the negative consequences of the GRA and the MAF on the cosmetic sector.
Cosmetics Europe presents itself as a representative of the cosmetics and personal care industry in Europe. The Cosmetic Products Regulation has also been the central legislation for the industry for over 40 years.
“The CPR should not be revised in isolation”
Cosmetics Europe underscores that the CPR should not be revised without collaboration, as the revision comes during a time of many changes in legislative and policy initiatives that will impact the industry, which is making a green and digital transition under the European Green Deal.
This includes the CSS and its revisions of Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and Classification, Labelling and Packaging (CLP), which has caused the CPR to be revised. Including advances in eco-designs for sustainable products, packaging waste, and the restriction of intentionally added microplastics to products. These changes are expected to have a “cumulative impact” on the cosmetics sector.
“Companies will not have the capacity to work in parallel on all these changes which will be particularly impactful for SMEs,” flags the association.
The main concern raised by Cosmetics Europe is that the European Commission should factor in other regulatory initiatives for consistency and provide adequate transition measures.
Following Chemicals Strategy for Sustainability
Cosmetics Europe states that it fully supports the objectives of the Chemicals Strategy for Sustainability (CSS), increasing the protection of health and the environment and boosting EU competitiveness. And so it recommends that the European Commission consider the objectives of CSS during the revision.
The responsibility for human and environmental safety is split between the CPR and REACH, shares the association. It also wants the European Commission to acknowledge the ingredient safety currently under CPR. This will ensure consumers have a variety of safe choices in the future. 
Cosmetics Europe asserts that CPR revisions should be collaborative, holistic and factor in the European Green Deal for coherency and consistency across legislations.
To further cosmetics safety, Cosmetics Europe suggests maintaining an independent scientific committee to assess and guarantee the safety assessment of cosmetics ingredients and chemicals.
“Cosmetics Europe welcomes the introduction of a horizontal definition for nanomaterials
and asks the Commission to ensure enough time for the industry to transition,” adds the personal care association.
The current method of ensuring the safety of cosmetic ingredients is assessed by considering consumer exposure. It is unambiguously demonstrated as safe once the European Commission’s Scientific Committee for Consumer Safety (SCCS) considers it and has a positive opinion on its use.
Regulatory changes
Emphasizing the importance of cosmetic products to the European public, Cosmetics Europe recently found that 72% of European consumers consider cosmetics and personal care products to be “very important” in daily life. The main reasons were that cosmetic products improve quality of life, boost self-esteem and help social interactions.
Moreover, the progress on banning animal testing in Europe for good has been stalling, warned Unilever. It underscored that REACH still requires animal testing despite the EU’s cosmetics ban implemented in 2013. This mismatch is an example of conflict between legislations.
New York, however, is set to ban cosmetics tested on animals as the NY Senate and Assembly pass a ban, awaiting the Governor’s signature.
By Venya Patel
