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

Thank you for the opportunity to give feed back on the revision of the Cosmetic Products Regulation. We welcome the overall initiative to achieve the objectives of the CSS through the listed policy options. Generic approach to risk management We support the alignment of the CPR to a horizontal and generic, approach to risk management (GRA) for the most hazardous chemicals.

The Danish Association of Cosmetics and Detergents is the leading Danish industry association and represents more than 80 Danish and international companies, which predominantly consists of SMEs, although around 25% are large companies. We welcome the opportunity to comment on the Inception Impact Assessment on the revision of the Cosmetic Products Regulation (CPR).

PETA Science Consortium International e.V. is grateful for the opportunity to comment on the 'EU chemicals strategy for sustainability – Cosmetic Products Regulation (revision)'. Please see the attached document for our response to the aforementioned consultation.

UNITIS, the European organization of cosmetic ingredients industries and services, representing SMEs manufacturing natural cosmetic ingredients, supports the general objectives of Chemicals Strategy for Sustainability (CSS) and green growth agenda.

Commentary on the EU chemical strategy for sustainability - Cosmetic Products Regulation (CPR) (revision) The Cosmetic, Toiletry and Fragrance Association (CTFA) represents over 80% of cosmetic companies in South Africa. These range from small to medium enterprise local companies up to and including major multi-national cosmetic manufacturers. Some of the industry members import and export products internationally.

Plastic Soup Foundation welcomes the proposed Roadmap and supports the Commission’s ambitions for a toxic-free environment leading to zero pollution. A revision of the Cosmetic Products Regulation is needed to align with the aims and ambitions of the Chemical Strategy, and to ensure a high level of protection of human health and the environment against hazardous chemicals in cosmetics and encourage the development…

Introduction The Irish Cosmetics and Detergents Association (ICDA) welcomes the opportunity to respond to the Inception Impact Assessment on the Revision of the Cosmetic Products Regulation (“CPR”) and as a constructive stakeholder looks forward to contributing throughout the revision process.

Forbrugerrådet Tænk welcomes the EC’s inception impact assessment, which contains many points we agree with. We welcome a revision of the Cosmetics directive. We would like to emphasize the need to address combination effects. In line with the CSS new legal provisions which take into account consumers’ combined exposure to ingredients of concern from all sources needs to be introduced.

IKW represents the German cosmetics industry. The 450 members are small and medium-sized, but also international companies. IKW members cover approx. 90% of the German market. We welcome the steps taken by the EU Commission towards more sustainability.

Extending the generic approach to risk management to cosmetics. The safety of cosmetic formulations and the ingredients they contain is of paramount importance to industry. Before ingredients and finished cosmetic formulations are placed on the market, their safety and suitability for use must be assessed.

RUCODEM – Romanian Union of Cosmetics and Detergents Manufacturers was established in 1997 and in present has 25 members and 1 associate members, companies active in the area of cosmetics and detergents. We would like to share with the European Commission the point of view regarding the Inception Impact Assessment for the Cosmetics Regulation – please find attached.

The Finnish Cosmetic and Hygiene Industry Association supports the general objectives of the EU Chemicals Strategy for Sustainability (CSS), as safety is the basic value for cosmetics industry. The EU Cosmetic Products Regulation (EC/2009/1223) (CPR) sets strict rules for human safety and all products undergo a risk-based safety assessment before being placed on the European market.

The Finnish Ministry of Social Affairs and Health and the Finnish Safety and Chemicals Agency fully support the Commission’s high ambitions for a toxic-free environment leading to zero pollution. We want to thank the Commission for the possibility to provide feedback regarding the Commission’s Inception Impact Assessment (IIA) on the revision of the Cosmetic Products Regulation.

The German Environment Agency welcomes the initiative to improve the environmental protection from chemicals used in cosmetics under the Cosmetic Products Regulation (EC) 1223/2009. Preservatives used in cosmetics currently do not fall under any environmental risk assessment comparable to other preservatives used for the preservation of manufactured products.

Summary of the comments from PSVAK: The Hellenic Cosmetic, Toiletry and Perfumery Association: 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.

Japan Cosmetic Industry Association representing interest of more than 1000 Japanese cosmetic companies would like to express our sincere gratitude to your great efforts to protect citizens and environment and encourage innovation for safe and sustainable alternatives development.

EDC-Free Europe is a coalition of public interest groups representing more than 70 environmental, health, women's and consumer groups across Europe who share a concern about hormone disrupting chemicals and their impact on our health and wildlife.

We would like to thank the Commission for organising this consultation on the revision of Regulation (EC) No 1223/2009 on cosmetic products, and also welcome the consultation on the revision of the Regulation in the context of the chemicals strategy for sustainable development (CSS) in the same timetable, which provides an opportunity to put forward proposals to ensure that these laws are complementary.

Filed in French · English published by the European Commission

Revision of the cosmetic product regulation is welcome, with the aim to increase protection of human health and the environment. Attribution to ECHA of the SCCS tasks can lead to a more efficient management of the cosmetic product control. However, this should not fade the principle from which no new animal tests should be performed for safety assessment of both cosmetic products and ingredients.

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.

The following is the feedback on the EC’s consultation on the inception impact assessment for the revision of the Cosmetics Product Regulation from the Scientific Committee for Health, Environmental and Emerging Risks (SCHEER).

Women Engage for a Common Future, France (WECF France) welcomes the European Commission’s plan to revise the EU Cosmetics Regulation. As the French office of the international ecofeminist network WECF, which brings together 150 women and non-governmental civil organisations involved in building a healthy and active environment at EU level with a view to a noxious future, WECF France calls on the European authorities…

Filed in French · English published by the European Commission

HELPAC, established in 1988, specialises in the production and sourcing of raw materials of plant origin (essential oil, hydroates, vegetable oils, glycerinated mother macerates, oily macerates, etc.). ). We are one of the few independent players in managing the production chain from plant processing to final packaging on a wide range of references.

Filed in French · English published by the European Commission

The European Industrial Minerals Association (IMA-Europe) represents the industrial minerals producers in Europe. Being at the top of the supply chain, minerals are used in a variety of applications going from the production of construction materials to food and feed additives or fertilisers. Annually, over hundred thousand tons of minerals are used as raw material to produce cosmetic products in the EU.

FEBEA is a french cosmetic association with more than 350 members representing 95 % of the companies manufacturing cosmetic products in France. We would like to share with the Commission our position regarding the objectives published in the Inception Impact Assessment and highlight the long history of a high level of safety of European cosmetic products based on specific risk assessment.

Filed in French · English published by the European Commission

The revision of the CPR provides an opportunity to ensure that cosmetics and their ingredients are not tested on animals. Cruelty Free Europe is disappointed to see that the initiative does not aim to protect and strengthen the animal testing bans, for which there is overwhelming public and political support.

L’Oréal, the worldwide leader in the beauty market, was founded in France in 1909 and has been growing in Europe and beyond ever since. Thanks to continued investment into Research & Innovation (964 million euros invested in 2020) and a stable regulatory framework, the company has been able to provide consumers with a wide range of safe and increasingly performing products which meet their beauty needs and…

STANPA is the Spanish cosmetic association with more than 400 members representing the 95% of the Spanish cosmetic companies. Currently Spain is the 5th market within the EU, with a consumption close to € 7,700 million, occupying 15th place in the world ranking.

Eurogroup for Animals welcomes this impact assessment with the purpose of reviewing some of the provisions of the Cosmetic Products Regulation in light of the objectives of the Chemicals Strategy for Sustainability.

The Blue Everything as an importer of cosmetics agrees and, as an associate, strengthens the position of AIC — Association of Cosmetic, Perfumery and Personal Hygiene Industrialists in the framework of the Initial Impact Assessment on the Revision of the Cosmetics Regulation. Please find attached the position of the AIC on the subject we subscribe to.

Filed in Portuguese · English published by the European Commission

NAOS welcomes the opportunity to provide feedback on the Inception Impact Assessment on the revision of the Cosmetic Products Regulation (CPR) as a key stakeholder. Present in more than 100 countries with 3100 employees, NAOS is a leading independent dermo-cosmetic company.

The EU’s bans on cosmetics tests on animals and the sale of animal-tested cosmetics arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

Henkel welcomes the opportunity to comment on the initial IIA for a revision of the Cosmetics Regulation. Our beauty care division with iconic brands such as Schwarzkopf Professional, Syoss or Fa represents over 100 years of experience in product innovation and safe use of cosmetics by consumers and hair care professionals.

The Association of Synthetic Amorphous Silica Producers (ASASP) recognises the European Commission’s efforts to further improve the protection of human health and the environment and to ensure that regulations become more efficient and predictable and supports the Chemical Strategy for Sustainability (CSS) objective of improving effectiveness, efficiency, and coherence of safety assessments across EU legislation.

Paper labelling requirements should be simplified and all EU countries should be as vigilant as the French or Belgian authorities with regard to checks on labelling. We are an importer of international (EU and non-EU) brands in these markets and it is very difficult to convince manufacturers of a lax non-EU or EU product of the need to provide all information in EU languages when they have experience of “lax”…

Filed in French · English published by the European Commission

The Polish Association of Cosmetic and Detergent Industry (PACDI) represents the manufacturers of cosmetic and personal care products as well as broadly defined cleaning products in Poland. PACDI members - apart from large international companies - are mainly local SMEs for which the scope of changes provided by the revision of cosmetic regulation will have a significant impact on their smooth functioning and…

AIC is the association representing companies that manufacture, import and/or distribute cosmetics products in Portugal. AIC is member of Cosmetics Europe Regarding the initial impact assessment of the revision of Cosmetics Regulation, - AIC re-states the fully commitment with EU Green Deal and Chemical Sustainability Strategy.

Unilever is committed to making sustainable living commonplace and welcomes the Commission’s initiative to review the Cosmetic Product Regulation (CPR). The CPR has been effective in safeguarding human safety, with well-established pre-market risk-based assessments of ingredients and products by company safety assessors and Scientific Committee on Consumer Safety (SCCS) providing independent assessment on high…

• Generic Risk Approach (GRA) should be implemented and used appropriately, in a way which is specific for cosmetic products. CTPA supports the objective of the CSS, to ensure a high level of safety for human health and the environment, and achieving this objective does not require automatically banning substances with demonstrably safe use within cosmetic products.

Cosmetica Italia (CI) (www.cosmeticaitalia.it) is the Italian Cosmetic Industry Association representing more than 600 companies: from multinational companies to SMEs, providing 33.000 direct jobs (400.000 considering the whole value chain). CI represents 90% of the sector turnover, amounting to 10.6 billion euro in 2020.

Cosmetics Europe, representing the cosmetics and personal care industry in Europe, welcomes the opportunity to respond to the Inception Impact Assessment on the Revision of the Cosmetic Products Regulation (“CPR”) and looks forward to contributing throughout the revision process.

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…

We support the overall objectives of the Chemical Strategy for Sustainability but want to stress the following points related to revision of the Cosmetic Product Regulation: - It is essential to distinguish between Hazard and Risk. Once the hazardness of a substance has been determined, the risk assessment should be sector specific.

On behalf of the Association Perfumery and Cosmetics of Ukraine (”APCU”) we would like to express our sincere appreciation to the European Commission for its continued support and assistance in the Ukrainian Cosmetics Regulation implementation process. Ukraine has approved the Regulation on Cosmetic Products based on the European Cosmetics Regulation 1223/2009.

The Austrian Association of Chemical Industrie – FCIO supports the goal of a predictable framework that protects consumers and the environment, as described in the Chemicals Strategy for Sustainability (CSS). The development of safe and sustainable cosmetic products is closely linked to the innovative capacity and global competitiveness of the cosmetics industry.

Following the publication of the inception impact assessment for the targeted revision of the cosmetic products regulation, the European cosmetics Responsible Person Association, ERPA, would like to share with the Commission its stand in regards to the points raised in this impact assessment.

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.

We consider it important, and fully agree with the extension of the scope of the Regulation to the types of harmful substances listed in the Roadmap in addition to CMR and endocrine disruptors. In our point of view, the independent Scientific Committee on Consumer Safety (SCCS) should continue to provide the final safety assessment for the cosmetic use of hazardous substances.

Kom op tegen Kanker, a Belgian NGO active in the field of cancer prevention, treatment and care, welcomes the initiative of the European Commission to improve the efficiency and effectiveness of the current rules on cosmetic products.

The L'OCCITANE Group is a global manufacturer and retailer of natural cosmetics and well-being products. We are committed to developing high quality products and demonstrate respect for the environment throughout each step of the process.

Animal testing for cosmetic products is still required in some cases by ECHA. According to a recent study, 63 ingredients used solely in cosmetic products have been tested on animals after the Cosmetic Regulation ban on in vivo testing. As the intention of legislators and of EU citizens aimed to ensure that animal testing for cosmetic products is banned completely, this review should close the gaps (i.p.

Pharma & Beauty Group is an international radiation company specialising in the design and production of cosmetics and pharmaceuticals. As a maker, Pharma & Beauty Group accompanies the marks in all life stages of the product. In the context of the evaluation of substances, it seems to me essential to differentiate between risk and hazard.

Filed in French · English published by the European Commission

We are a french company which develops, manufactures and sales ingredients for cosmetic products. First of all, we think that the objectives of the European Chemical strategy meets the need of our market, costumers and consumers. Nevertheless, we would like to pointed out some importants points that must be taking into account : 1) Necessity to differentiate the Hazard assessment and the Risk assessment.

The International Fragrance Association (IFRA) welcomes the opportunity to comment on the first step of the revision of the Cosmetic Products regulation (CPR). IFRA considers it is key to consider that: • Extend the generic approach to risk management (GRA) should be based on risk not on hazard.

The Cosmetic Products Regulation (CPR) plays a vital role in protecting consumers against chemical risks; still, the CPR suffers from major shortcomings, as correctly outlined in the Inception Impact Assessment (IIA). Thus, BEUC welcomes the Commission’s intention to revise the CPR to achieve the goals of the Chemicals Strategy for Sustainability (CSS).

Dear Sir or Madam, We are a French company specialised in making essential oils based cosmetic product. We support the overall objectives of the Chemical strategy but we want to stress the following points: - This is essential to distinguish between Hazard and Risk. Once the hazardness of a substance has been determined, risk assessment should be sector specific.

1/Les methods of measurement need to be harmonised between Member States so that there can be no distortion of competition between Member States. In particular, the method (s) chosen must be able to measure all the particles of a formula. There shall be no loss of material during the sample preparation process.

Filed in French · English published by the European Commission

Laboratoire Gravier is a French company which develops, manufactures and distributes cosmetic products. We support the overall objectives of the Chemical strategy but we want to stress the following points: - This is a key point to distinguish between Hazard and Risk. Once the hazardness of a substance has been determined, risk assessment should be specific for each use and product category.

Update on nanomaterials 1/Les methods of measurement need to be harmonised between Member States so that there can be no distortion of competition between Member States. In particular, the method (s) chosen shall be capable of measuring all the particles of a formule.There shall be no loss of matter depending on the process of preparation of the sample.

Filed in French · English published by the European Commission

1/Les methods of measurement need to be harmonised between Member States so that there can be no distortion of competition between Member States. In particular, the method (s) chosen shall be capable of measuring all the particles of a formule.There shall be no loss of matter depending on the process of preparation of the sample.

Filed in French · English published by the European Commission

The EU’s bans on cosmetics tests on animals and the sale of animal-tested cosmetics arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

The EU’s bans on cosmetics tests on animals, and the sale of animal-tested cosmetics, arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

The German Animal Welfare Federation welcomes the EU chemicals strategy for sustainability and the revision of the Cosmetic Products Regulation in this light. It has been an essential step towards a progressive and reliable safety assessment when the EU Cosmetics Regulation banned animal testing for cosmetic products and ingredients as well as the marketing of cosmetic products and ingredients that have been tested…

The Revision of the Cosmetic Products Regulation (Regulation (EC) No 1223/2009) is crucial for the successful implementation of the CSS and we thank the European Commission for the opportunity to provide inputs to the roadmap consultation. Harmful chemicals We welcome the European Commission’s intention to address the problems with the current CPR.

Generations Futures welcomes the opportunity to participate in the public consultation launched by the European Commission on the roadmap for the revision of the Cosmetics Regulation. Generations Futures recalls the urgent need to take the necessary measures to protect populations and in particular vulnerable groups from chemicals (children, pregnant and breastfeeding women) as advocated in the Sustainable Chemicals…

Filed in French · English published by the European Commission

The EU’s bans on cosmetics tests on animals, and the sale of animal-tested cosmetics, arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

Update on nanomaterials 1/Les methods of measurement need to be harmonised between Member States so that there can be no distortion of competition between Member States. In particular, the method (s) chosen shall be capable of measuring all the particles of a formule.There shall be no loss of matter depending on the process of preparation of the sample.

Filed in French · English published by the European Commission

Adopt ready-to-read and understandable information for the consumer: Accept legal statements via a QR code with zoomable texts, visuals and explanations. This is more efficient than incomprehensible pictos or texts that are illegible (size) or even hidden (peel off) and in a language which is not always their own.

Filed in French · English published by the European Commission

Fecc acknowledges the consultation for the upcoming initiative on revising the Cosmetics Products Regulation under the Chemical Strategy for Sustainability. At the same time we would like to raise the following points in this consultation: 1.

First of all we would like to assure you about our support for goals of Chemicals Strategy for Sustainability in accordance to fact that safety of consumers is the top priority of our industry. We are concened about few thing we would like to share. First is about "One substance - One assessment" point of action.

We agree with the objectives of thestrategy but we want to insist on the following points: - SCCS is an independent expert committee to assess the use of substances in cosmetic, and we would like to rely on them, taking into account their knowledge and experience on the use of alternative methods. The SCCS should not be integrated to ECHA to keep its independancy from a political and industrial standpoint.

Dear Madam, and Sirs, We are a small cosmetics subcontractor and manufacturer located in France nearby Lyon, specialized in formulation and sales of solar protection products. We support the overall objectives of the Chemical strategy but we want to stress the following points: - This is essential to distinguish between Hazard and Risk.

Dear Madam, and Sirs, We are a small cosmetics subcontractor and manufacturer located in France nearby Lyon, specialized in formulation of solar and technical products. We support the overall objectives of the Chemical strategy but we want to stress the following points: - This is essential to distinguish between Hazard and Risk.

For more than 12 years IDM has been a major player in the development of brand names in Droguerie Parfumerie and Hygiène for French distribution. IDM aerosol expert is one of the MDD leaders in the household and cosmetic product market through his creativity. responsiveness and regulatory monitoring by offering turnkey or customised products.

Filed in French · English published by the European Commission

We agree with the objectives of the strategy but wish to highlight some points: 1. There must be a clear separation of hazards and risks. Once the hazard of a substance has been established, the risk should be assessed sector by sector and not globally. 2. The safety and durability of a product should be more important than the notion of materiality. 3.

Filed in French · English published by the European Commission

Dear all, We are a mauritian company with expertise in aromatherapy. Among our range, we offer cosmetic products. We are present on the French market with products developped in Mauritius but manufactured in France with only European suppliers.

The EU’s bans on cosmetics tests on animals, and the sale of animal-tested cosmetics, arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

1) Strengthened ingredients requirements: Cosmetic ingredients must be evaluated and regulated in accordance with the precautionary principle before they are used in cosmetic products. — The toxicological assessment of ingredients must be publicly available. — There must be strict quality requirements for cosmetic ingredients with regard to contaminants that are harmful to health and the environment.

Filed in German · English published by the European Commission

The EU’s bans on cosmetics tests on animals and the sale of animal-tested cosmetics arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

There is an urgent need for more simplification for artisanal cosmetics. For example, by exempting from toxicological assessment cosmetic products formulated exclusively with vegetable oils and cold process soaps without perfume. I would also like to see better information on the various EU rules that apply and instructions on how to implement them. Thank you

Filed in French · English published by the European Commission

The EU’s bans on cosmetics tests on animals and the sale of animal-tested cosmetics arose from strong and unequivocal public and political support for the idea that animals should not suffer and die in laboratories for the sake of cosmetics.

This initiative is timely. As a cosmetic claims specialist I welcome the stance on ensuring transparency as regards to the sustainability claims of cosmetic ingredients and brands. The EU should also, simultaneously, take into account the ISO 1420 and its revisions through this roadmap/process.

Please could you consider also to cover vaginal products in the cosmetics regulation. At present the only legal affiliation for a vaginal product is as a medicine or as a medical device. As many vaginal products are mainly intended to improve sensation, smell or feeling a registration to cosmetic products would be much more appropriate.

Summary of the comments from the Belgian Federal Public Service for Health, Food Chain Safety and Environment, Service Foodstuffs, Animal Feeding Stuffs and Other Consumption Products: We do support the application to other health hazard classes of restrictions inspired from the current CMRs provisions.

We welcome the revision of the Cosmetic Products Regulation and the proposed way forward presented in the roadmap. In our view the roadmap cover all necessary issues to be revised to make sure the Cosmetics regulation is in line with the aims and ambitions of the Chemical Strategy.