International Fragrance Association

IFRA welcomes some improvements in the draft Delegated Act revising the ESRS. In particular: - The recognition of the risk of double counting contributes to more accurate disclosures. - The clarification of the application of the double materiality assessment helps ensure that reporting focuses on decision useful information. - Improvements in definitions, e.g.

Multi-constituent substances IFRA would like to reiterate our concern that Natural Complex Substances (NCSs) (multi-constituent substances according to the new definition 7a introduced in article 2),should be considered as single substances and not mixtures. By nature, and definition, NCSs are complex.

The International Fragrance Association welcomes the opportunity to comment on the European Commission Inception Impact Assessment on CLP. Full comments are available in the attachment. Inclusion of new hazard classes should first take place under the UN Globally Harmonized System of Classification and Labelling of Chemicals framework.

The International Fragrance Association welcomes the opportunity to comment on the EU Commission Inception Impact Assessment on REACH. Full comments are available in the attachment. The revision of the REACH regulation should be targeted and science based. The Commission should seek to build on the current solid and existing framework to make it more efficient, consistent and streamlined.

The International Fragrance Association (IFRA) supports the improvement of a European framework aiming at ensuring that consumers can actively contribute to the green transition, through the delivery of reliable information on consumer products, to make environmentally sustainable consumption choices and is actively participating in the meetings of the EU Ecolabelling Board.

Since its adoption over 15 years ago, the CPR has established itself as a gold standard in Europe, creating a unified legal framework to protect consumer health by ensuring that all cosmetics meet strict safety requirements before being placed on the market.

The International Fragrance Association (IFRA) would like to express its support to the main objective of the One Substance, One Assessment approach (OSOA) under the Chemicals Strategy for Sustainability (CSS) to improve the efficiency, effectiveness, coherence, and transparency of chemical safety assessments across different pieces of EU legislation.

The International Fragrance Association (IFRA) welcomes the opportunity to comment on the European Commission Call for evidence for an initiative on “Chemicals – making best use of EU agencies to streamline scientific assessments”.

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 International Fragrance Association (IFRA) welcomes the European Commissions proposal for a Regulation on the European Chemicals Agency (ECHA) and its objective to reinforce the Agencys governance and scientific structures.

IFRA supports the European Commission’s willingness to adjust the mandate and structure of ECHA to optimise and rationalise how its bodies operate and increase the sustainability of its financing model. IFRA believes that this Regulation could be an opportunity to enhance the transparency of ECHA, make the best use of the expertise of its different bodies and improve the organisation of scientific committees to…

The International Fragrance Association (IFRA) welcomes the European Commissions evaluation of Regulation (EU) No 511/2014 on Access and Benefit Sharing (ABS) and appreciates the opportunity to provide feedback to this important review.