The Polish Union of the Cosmetics Industry

The Polish Union of the Cosmetics Industry welcomes the Commissions efforts to harmonise producer registration and EPR reporting under the PPWR. At the same time, the draft raises a number of practical concerns regarding the proportionality, usability and administrative impact of the proposed reporting framework, especially for companies operating in several Member States and using complex distribution, logistics…

The Union supports the EU Commission ambition to accelerate the transition to a circular economy, while ensuring EU-wide harmonization and simplification. The Circular Economy Act is great opportunity to streamline and clarify the EU legislation through targeted revisions of EU rules and the introduction of new measures.

The Polish Union of the Cosmetics Industry welcomes the change of the legal act from a directive to a regulation, while maintaining the legal basis of the single market. The proposed amendment will make it possible to harmonize packaging rules in the Member States and avoid fragmentation of the single market, proliferation of systems and national rules.

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals.

The Polish Union of the Cosmetics Industry welcomes the European Commission's proposal for a Directive on the substantiation and communication of explicit environmental claims. The Union supports its overarching objective of tackling greenwashing and the need to develop a harmonised EU legal framework for environmental claims.

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals.

The Polish Union of the Cosmetics Industry supports the objectives of the Green Deal and the European Commission's proposal for a Regulation on Ecodesign for Sustainable Products (ESPR). Cosmetic products are outside the scope of the ESPR in the first step.

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals.

The Polish Union of the Cosmetics Industry supports the goals of the Green Deal. We welcome the opportunity to engage with the European Commission on the revision of the Regulation on the classification, labelling and packaging of substances and mixtures 1272/2008/EC (the CLP Regulation).

Addressing the CLP revision roadmap, the Polish Union of the Cosmetics Industry would like to highlight the following issues: New hazard classes The Union considers the CLP Regulation as an effective tool for harmonised hazard identification and classification at substance level. The regulatory consequences of CLP classifications, i.e.

The Polish Union of the Cosmetics Industry supports the European Unions objectives related to industrial decarbonisation, circular economy and the development of sustainable, bio-based value chains. Our sector has already invested significantly in sustainable packaging, circularity initiatives, reformulation efforts, responsible sourcing and innovation involving renewable and bio-based ingredients.

The Polish Union of the Cosmetics Industry, representing over 270 companies operating in Poland, welcomed with high expectations the announcement of the Environmental Omnibus VIII Unfortunately, the outcome of the Omnibus is deeply disappointing.

Addressing the REACH revision roadmap, the Polish Union of the Cosmetics Industry would like to highlight the following issues: Revision of the registration requirements The introduction of new information requirements (hazards of concern, documentation of safe use, registration of certain polymers, and information on the environmental footprint) should be consistent with the requirements of Article 13 of REACH and…

The Polish Union of the Cosmetics Industry welcomes the approach presented by the European Commission in the draft decision to set legal rules for the chemical recycling, to enable including the recyclates obtained from chemical recycling in the legally binding targets and set methodologies for counting the chemical recyclates.

We welcome the Commissions intention to establish sustainability criteria for plastic recycling technologies. These criteria must ensure access to high-quality recycled materials and allow chemical recycling to complement mechanical recycling, especially where mechanically recycled material of the required purity, consistency or technical performance is not sufficiently available.

The Polish Union of the Cosmetics Industry supports increasing the use of recycled plastics in packaging. However, the current PPWR component-by-component approach is not workable for many complex cosmetic packaging formats. Recycled-content requirements apply to individual plastic packaging parts, while compliance is calculated as an annual average for each packaging type and format per manufacturing plant.

On 26 October 2022, the European Commission presented, within the framework of the Zero Pollution Action Plan policy, being a part the European Green Deal, the proposal for a revised Urban Wastewater Treatment Directive (UWWTD). The scope of the Directive is wide and it covers a number of horizontal issues.

The CPR is one of the most important and comprehensive legal framework in the European, provides a high level of consumer protection, ensuring that cosmetics placed on the EU market are safe. Cosmetics are an essential products, providing a positive impact on health prevention (sun protection products, oral care products and many others).

The Polish Union of the Cosmetics Industry supports the main objectives of the Chemical Strategy for Sustainability (CSS) including OSOA approach - to improve the efficiency, effectiveness, coherence, and transparency of safety assessments of chemicals across different pieces of EU legislation.

The Polish Union of the Cosmetics Industry welcomes the Commission's proposal on better access to data on chemicals for the purposes of safety assessment. This initiative will help to improve the flow of data on chemicals. Better access to data on chemicals will allow the use of various sources, greater availability of information and a positive impact on the use of data.

The Polish Union of the Cosmetics Industry welcoming the possibility of cooperation with the Commission on General Product Directive (GPSD) recast from directive to regulation, which will improve the harmonised application of the law across the EU. The GPSD is an important regulatory tool to ensure consumer safety in the EU. It fundamental approach, scope and principles are still relevant and valid.

Filed in Polish · English published by the European Commission

The Polish Union od the Cosmetics Industry welcomes the opportunity to engage with the European Commission on the New Consumer Agenda and related files. In regard to the Commission’s roadmap on the review of the General Product Safety Directive (GPSD), the Union considers the following principles are critical elements for the upcoming European Commission policy discussion in this field: • The GPSD is an important…

The revision of Directive 2019/633 on unfair trading practices (UTPD) should take into account the changes that have occurred in the market in recent years. The ongoing consolidation of retail and the development of international buying alliances have significantly increased buyers bargaining power vis-à-vis suppliers, not only in the agri-food sector, but across the entire consumer goods segment.

The Polih Union of the Cosmetics Industry supports the objectives of the Chemical Strategy for Sustainability (CSS) to improve effectiveness, efficiency, and coherence of safety assessments across EU legislation. However, the Union would like to reiterate that the SCCS needs to continue being a stand-alone committee within ECHA.

The Polish Union of the Cosmetics Industry welcomes the opportunity to contribute to the ongoing evaluation of the Market Surveillance Regulation (EU) 2019/1020. We fully support the European Commissions efforts to strengthen the enforcement of product compliance across the Single Market, especially given the sharp increase in non-compliant and counterfeit products entering the EU market via online channels and…

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…

The Polish Union of Cosmetics Industry hereby presents comments to the Call for Evidence regarding a „Proposal for a basic regulation of the European Chemicals Agency” with a particular focus on the Scientific Committee on Consumer Safety (SCCS).

The Polish Union of the Cosmetics Industry strongly welcomes timely presentation of the draft regulation on the format of reporting of the discarded products according to the ESPR regulation. Also, we appreciate the simple format of reporting, and optimal granularity. Some of our postulates raised within the ingoing discussion were addressed.