We welcome the opportunity to provide input on the draft Implementing act on article 44 of PPWR. Please find enclosed COSMED contribution to reduce unnecessary administrative duplication and costs while maintaining the environmental objectives of the PPWR.
COS
COSMED
Industry association · France · EU Transparency Register 995341033700-55
12
positions filed
in the 665 files tracked
10
legislative files
of 665 tracked
11
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 410 trade unions and professional associations on this site, they rank #54 by legislative files engaged, a count of participation, not a measure of influence.
1.5
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2019
in the register since
Declares membership of
- Member of SMEunited : www.smeunited.eu
- SBS expert in the ISO TC 217 on Cosmetics : www.iso.org
- SBS expert in the CEN TC 392 on Cosmetics : www.cen.eu
- AFNOR representative in the CEN TC 352 on Nanomaterials : www.cen.eu
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade unions and professional associations
- Head office
- Aix-en-Provence, France
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
COSMED filed 12 positions between 1 Jun 2021 and 10 Sept 2026, across 10 of the 665 legislative files tracked here, attaching a full position paper 11 times.
2021 · 2 filed2022 · 1 filed2023 · 4 filed2024 · 1 filed2025 · 3 filed2026 · 1 filed
What they argued
COSMED fully supports the ambition of the Circular Economy Act to boost EU competitiveness while accelerating the shift to more sustainable production, circular models, and decarbonisation. However, we would like to stress that the transition towards a circular economy must be pursued without losing sight of the health and safety considerations specific to certain sectors.
COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the proposal for a regulation on packaging and packaging waste. First of all, COSMED support this proposal for a regulation on packaging and packaging waste to harmonize rules in European Union and to move towards a more circular economy.
First of all, COSMED supports overall objectives of the Green Claim Directive to protect consumers and companies against greenwashing. However, we alert on the need to maintain a rationale balance to avoid disproportionate burden on companies and especially on SMEs and to leave the possibility for SMEs to make voluntary environmental claims in an accessible way.
COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the revision of the CLP regulation. COSMED welcomes the initiative to simplify the legal framework of chemicals but warns the Commission of the counterproductive effects of certain measures leading to overcomplexity and administrative overload for the industry, impacting even more SMEs, without any benefit for the…
COSMED welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. Please find our full contribution in attachment. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 920 members, in France and Europe
COSMED welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. Please find our full contribution in attachment. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 920 members, in France and Europe.
COSMED INPUT on revision of the Urban Wastewater Treatment Directive First of all, COSMED support this initiative leading to the improvement of urban water quality and wastewater treatment. A quaternary treatment would indeed be necessary if some pollutants remain unremoved after the first three treatments.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Since its application in 2013, the CPR has continuously demonstrated its performance in achieving those 2 objectives and CPR is still considered as the global standard for international cosmetic regulations. We emphasize that CPR is the only regulation requiring a safety assessment of every product placed on the market.
COSMED, the French Cosmetic Association for SMEs, supports the main objective of the OSOA package. We however would like to draw attention on some key elements (definition, relevance of data, use of NAMs, study notification, confidentiality, access and use of data). Regarding the re-attribution of scientific and technical tasks to the ECHA, the best available expertise should be used.
COSMED welcomes the possibility to comment on the proposal which aims to strengthen the governance of ECHA. We fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is also essential to keep an efficient process ensuring a high level of protection of human health and a well-functioning internal market.
COSMED welcomes the possibility to comment on the proposal which aims to adjust the mandate and structure of ECHA. We embrace the objective of the CSS and fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is essential to keep an efficient process ensuring a high level of protection of human health and the environment and a well-functioning…
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