Japan Cosmetic Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to a proposal of Revision of Packaging and Packaging Waste Regulation (PPWR). JCIA supports the EU's efforts toward the circular economy society.
JCI
Japan Cosmetic Industry Association
Industry association · Japan
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
7
positions filed
in the 665 files tracked
7
legislative files
of 665 tracked
2
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.
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Their record over time
Japan Cosmetic Industry Association filed 7 positions between 30 Mar 2023 and 11 Sept 2026, across 7 of the 665 legislative files tracked here, attaching a full position paper 2 times.
2023 · 2 filed2024 · 1 filed2025 · 1 filed2026 · 3 filed
What they argued
Japan Cosmetic Industry Association, JCIA is representing interest of more than one thousand Japanese cosmetic companies. We would like to express our sincere gratitude to your significant efforts to protect human health and the environment from hazardous chemicals.
Japan Cosmetic Industry Association (JCIA) supports the development of a robust and practicable sustainability framework for plastic recycling technologies under Article 7(9). LCA-based greenhouse gas (GHG) emissions, expressed in CO2 equivalents, are an important and internationally comparable indicator for assessing recycling technologies. However, sustainability should not be assessed on GHG emissions alone.
Japan Cosmetic Industry Association (JCIA) recommends clear, practical and verifiable rules for calculating and verifying recycled content, taking into account the complexity of cosmetic packaging and global supply chains.
Japan Cosmetic Industry Association (JCIA) submits these comments from the perspective of cosmetic companies placing on the EU market finished products using packaging containing recycled materials recovered, sorted or recycled outside the EU, rather than from the perspective of companies importing recycled materials as such.
Since its full implementation in 2013, CPR has played a central role in consumer protection across the EU's internal market and has served as a reference for regulatory development in many countries worldwide. However, in recent years, various other EU regulations concerning chemical substances have increasingly impacted the regulatory framework applied to cosmetics, leading to a situation where it is difficult to…
The Japan Cosmetic Industry Association, JCIA, appreciates the opportunity to comment on this proposal. JCIA welcomes the operational proposal to accelerate hazard and risk assessment in the EU. At the same time, we would like to request that the system be designed to derive appropriate risk assessments, taking full account of the fact that products are used in different ways for different purposes including…
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