1.The Report of the Ministry of Ecological Transition
In August 2022, the French Ministry of Ecological Transition provided a much-needed insight into the environmental impact of the cosmetics and fragrance industry through a detailed report that:
- Lists 11 recommendations to help all industry players go further in assessing and reducing the environmental impact of the products they make available to consumers.
- Establishes an inventory of the actions taken so far and the impact they have had.
- Paves the way for future regulatory updates aimed at better guiding the industry's players in their efforts to be more environmentally friendly.
List of the 11 recommendations
The 11 recommendations addressed to the profession in the report of the Ministry of Ecological Transition are the following:
- Recommendation n�1: Improve knowledge of the environmental impacts of cosmetic products (implementation of an ambitious program between 2020 & 2030 within the framework of the industry committee).
- Recommendation n�2: Implement French proposals to improve the link between the cosmetics, REACH and classification, labeling and packaging (CLP) regulations to better take into account the environmental impacts of cosmetic products.
- Recommendation n�3: Promote bulk sales within the framework of ADEME's recommendations and assess the results.
- Recommendation n�4: Continue actions to reduce the water content in cosmetic product formulas, without increasing other negative impacts on the environment.
- Recommendation n�5: Limit the use of palm oil or palm kernel oil to reduce deforestation.
- Recommendation n�6: Implement a plan to reduce greenhouse gas emissions related to the transportation of products throughout the value chain.
- Recommendation n�7: Accelerate the implementation of ecological transition actions at cosmetic product sales outlets.
- Recommendation n�8: Promote and develop the use of the European EcoLabel for cosmetic products.
- Recommendation n�9: Set up a governance structure to ensure the development of environmental labelling projects that can be used by the greatest number of companies, in conjunction with the international consortium and other emerging initiatives.
- Recommendation n�10: Set up a working group with ADEME to oversee work on environmental labelling and the creation of the necessary databases, in conjunction with industry initiatives.
- Recommendation n�11: Provide consumers with more information on the importance of moderation in the use of cosmetics and on practices to reduce their impact.
What you need to remember
Even if the cosmetics industry is on the right track when it comes to environmental impact, we must continue this extensive shift by accelerating its commitment. All industry stakeholders (suppliers, distributors, manufacturers...) must continue to protect consumers' health and contribute to their well-being, while intensifying their efforts to reduce the environmental impacts of their products at every stage of the life cycle.
Another step towards the revision of the European cosmetic regulation
The report points out that the regulatory framework is still too vague between the different regulations, which does not offer a clear guideline to serve as a guide for the industry's actors in terms of environmental impact. The European Commission has launched initiatives in this direction, in order to improve the consideration of the environment by cosmetic products and to strengthen the coherence of the European framework on chemicals: procedures for the revision of the regulation on cosmetic products, the REACH regulation and the CLP regulation, establishment of a working group "one substance one assessment".
2. The upcoming revision of the European cosmetic regulation
For several months, the European Commission has been working on a project to amend the cosmetics regulation for ever more environmentally friendly cosmetics. This revision project could alarm the methods of the industry players and lead to numerous regulatory updates.
A potential revision of the REACH, CLP and Cosmetic regulations
The European Chemical Strategy is moving towards the goal of a toxic substance-free environment. To achieve this goal, changes are needed in the REACH, CLP and cosmetic regulations. Marketers, suppliers of raw materials, testing laboratories, cosmetic brands... all actors will be concerned by this amendment.
The agenda of the European Commission's revision project
Here is a summary of the actions launched by the Commission, and those to come in the framework of the project to recast the cosmetics regulation.
Past actions:
- A first public consultation was conducted to assess the impacts of a revision of the Regulation (in October 2021).
- A second targeted public consultation was conducted to study the socio-economic impacts (open from March to June 2022).
- Targeted interviews with a representative panel of companies were conducted (June 2022).
- The Commission services worked on a list of options to be selected for the revision (July 2022).
Upcoming actions:
- Presentation of options and impact assessment to the Regulatory Review Committee (September 2022).
- Finalization and publication of the text proposal after inter-service consultation within the Commission (November).
The 5 key points targeted:
- 1. Automatic ban on the most dangerous substances (except for essential use).
- 2. Consideration of combined effects (related to exposure from different sources).
- 3. The modification of the governance of the CSAS.
- 4. Revision of the definition of nanomaterials (to ensure harmonization between the different regulations).
- 5. Improving consumer information (option of dematerialized labeling).
The impact on the entire industry
The impact on the cosmetics and fragrances industry could be significant: from the risk of losing raw materials to the disappearance of the Scientific Committee for Consumer Safety (SCCS) - highly appreciated by the industry for its expertise and its guiding role - the revision of the cosmetics regulation could upset the daily life of manufacturers and lead them to rethink their approach. And to consider new alternatives.
A greater impact on the perfume industry
A study on the consequences of the European Commission's proposed Chemicals Sustainability Strategy (CSS) for perfumery companies and the wider fragrance industry in Europe has been carried out by consultancy Ricardo Energy & Environment. According to the study, more than a quarter of the fragrance industry's turnover could be affected in some way by the proposed changes.
Estimated date of application of the new cosmetic regulation
In the fastest scenario, the Commission's proposal could be adopted by the Council within about a year, leading to the end of 2023 - early 2024 (if the text does not give rise to major controversies or discussions).
However, if there are objections to the text or difficult discussions between the Council and the Parliament, or between the member states and the Parliament, the process can take much longer, up to three or four years. In this extreme case, final adoption of the text will not take place before 2026.
How can EcoMundo help you anticipate these changes?
EcoMundo offers support methods via expert regulatory services to anticipate any changes in cosmetic and CLP regulations. EcoMundo accompanies many cosmetic brands in the compliance and regulatory monitoring of their products. As a Responsible Person for the Europe and UK market, EcoMundo has a rigorous knowledge of the regulations and their evolutions, in order to keep its customers informed of any change and to protect them from any risk of non-compliance.
EcoMundo has also developed COSMETIC Factory, an adapted PLM software solution that secures the global regulatory compliance of cosmetic and fragrance products on the long term. Our experts (regulatory affairs officers, toxicologists) provide the software with international regulatory databases and perform regular updates to secure the compliance of products with European and other international regulations (GHS, HAZCOM, WHMIS...). COSMETIC Factory users can thus control all aspects impacting the compliance of their cosmetic products (raw materials, formulas, packaging, labels), anticipate modifications and control the update or reformulation timeframes (thanks to the embedded databases and AI-assisted functionalities).
Want to know more?
1.The Report of the Ministry of Ecological Transition
In August 2022, the French Ministry of Ecological Transition provided a much-needed insight into the environmental impact of the cosmetics and fragrance industry through a detailed report that:
- Lists 11 recommendations to help all industry players go further in assessing and reducing the environmental impact of the products they make available to consumers.
- Establishes an inventory of the actions taken so far and the impact they have had.
- Paves the way for future regulatory updates aimed at better guiding the industry's players in their efforts to be more environmentally friendly.
List of the 11 recommendations
The 11 recommendations addressed to the profession in the report of the Ministry of Ecological Transition are the following:
- Recommendation n�1: Improve knowledge of the environmental impacts of cosmetic products (implementation of an ambitious program between 2020 & 2030 within the framework of the industry committee).
- Recommendation n�2: Implement French proposals to improve the link between the cosmetics, REACH and classification, labeling and packaging (CLP) regulations to better take into account the environmental impacts of cosmetic products.
- Recommendation n�3: Promote bulk sales within the framework of ADEME's recommendations and assess the results.
- Recommendation n�4: Continue actions to reduce the water content in cosmetic product formulas, without increasing other negative impacts on the environment.
- Recommendation n�5: Limit the use of palm oil or palm kernel oil to reduce deforestation.
- Recommendation n�6: Implement a plan to reduce greenhouse gas emissions related to the transportation of products throughout the value chain.
- Recommendation n�7: Accelerate the implementation of ecological transition actions at cosmetic product sales outlets.
- Recommendation n�8: Promote and develop the use of the European EcoLabel for cosmetic products.
- Recommendation n�9: Set up a governance structure to ensure the development of environmental labelling projects that can be used by the greatest number of companies, in conjunction with the international consortium and other emerging initiatives.
- Recommendation n�10: Set up a working group with ADEME to oversee work on environmental labelling and the creation of the necessary databases, in conjunction with industry initiatives.
- Recommendation n�11: Provide consumers with more information on the importance of moderation in the use of cosmetics and on practices to reduce their impact.
What you need to remember
Even if the cosmetics industry is on the right track when it comes to environmental impact, we must continue this extensive shift by accelerating its commitment. All industry stakeholders (suppliers, distributors, manufacturers...) must continue to protect consumers' health and contribute to their well-being, while intensifying their efforts to reduce the environmental impacts of their products at every stage of the life cycle.
Another step towards the revision of the European cosmetic regulation
The report points out that the regulatory framework is still too vague between the different regulations, which does not offer a clear guideline to serve as a guide for the industry's actors in terms of environmental impact. The European Commission has launched initiatives in this direction, in order to improve the consideration of the environment by cosmetic products and to strengthen the coherence of the European framework on chemicals: procedures for the revision of the regulation on cosmetic products, the REACH regulation and the CLP regulation, establishment of a working group "one substance one assessment".
2. The upcoming revision of the European cosmetic regulation
For several months, the European Commission has been working on a project to amend the cosmetics regulation for ever more environmentally friendly cosmetics. This revision project could alarm the methods of the industry players and lead to numerous regulatory updates.
A potential revision of the REACH, CLP and Cosmetic regulations
The European Chemical Strategy is moving towards the goal of a toxic substance-free environment. To achieve this goal, changes are needed in the REACH, CLP and cosmetic regulations. Marketers, suppliers of raw materials, testing laboratories, cosmetic brands... all actors will be concerned by this amendment.
The agenda of the European Commission's revision project
Here is a summary of the actions launched by the Commission, and those to come in the framework of the project to recast the cosmetics regulation.
Past actions:
- A first public consultation was conducted to assess the impacts of a revision of the Regulation (in October 2021).
- A second targeted public consultation was conducted to study the socio-economic impacts (open from March to June 2022).
- Targeted interviews with a representative panel of companies were conducted (June 2022).
- The Commission services worked on a list of options to be selected for the revision (July 2022).
Upcoming actions:
- Presentation of options and impact assessment to the Regulatory Review Committee (September 2022).
- Finalization and publication of the text proposal after inter-service consultation within the Commission (November).
The 5 key points targeted:
- 1. Automatic ban on the most dangerous substances (except for essential use).
- 2. Consideration of combined effects (related to exposure from different sources).
- 3. The modification of the governance of the CSAS.
- 4. Revision of the definition of nanomaterials (to ensure harmonization between the different regulations).
- 5. Improving consumer information (option of dematerialized labeling).
The impact on the entire industry
The impact on the cosmetics and fragrances industry could be significant: from the risk of losing raw materials to the disappearance of the Scientific Committee for Consumer Safety (SCCS) - highly appreciated by the industry for its expertise and its guiding role - the revision of the cosmetics regulation could upset the daily life of manufacturers and lead them to rethink their approach. And to consider new alternatives.
A greater impact on the perfume industry
A study on the consequences of the European Commission's proposed Chemicals Sustainability Strategy (CSS) for perfumery companies and the wider fragrance industry in Europe has been carried out by consultancy Ricardo Energy & Environment. According to the study, more than a quarter of the fragrance industry's turnover could be affected in some way by the proposed changes.
Estimated date of application of the new cosmetic regulation
In the fastest scenario, the Commission's proposal could be adopted by the Council within about a year, leading to the end of 2023 - early 2024 (if the text does not give rise to major controversies or discussions).
However, if there are objections to the text or difficult discussions between the Council and the Parliament, or between the member states and the Parliament, the process can take much longer, up to three or four years. In this extreme case, final adoption of the text will not take place before 2026.
How can EcoMundo help you anticipate these changes?
EcoMundo offers support methods via expert regulatory services to anticipate any changes in cosmetic and CLP regulations. EcoMundo accompanies many cosmetic brands in the compliance and regulatory monitoring of their products. As a Responsible Person for the Europe and UK market, EcoMundo has a rigorous knowledge of the regulations and their evolutions, in order to keep its customers informed of any change and to protect them from any risk of non-compliance.
EcoMundo has also developed COSMETIC Factory, an adapted PLM software solution that secures the global regulatory compliance of cosmetic and fragrance products on the long term. Our experts (regulatory affairs officers, toxicologists) provide the software with international regulatory databases and perform regular updates to secure the compliance of products with European and other international regulations (GHS, HAZCOM, WHMIS...). COSMETIC Factory users can thus control all aspects impacting the compliance of their cosmetic products (raw materials, formulas, packaging, labels), anticipate modifications and control the update or reformulation timeframes (thanks to the embedded databases and AI-assisted functionalities).
Want to know more?
