Natural and organic cosmetics are global megatrends evident in both the EU and the UK from increased emphasis on ethical and sustainable living. However, what now for the UK and EU cosmetic industry, their natural and organic sectors, and consumers in those regions?

Natural and organic cosmetics

Future regulatory divergence or alignment?

After nearly 44 years of cosmetics regulatory alignment the UK left the EU on 31 January 2020. Until the end of 2020, the status quo remains that products placed on the UK market must be compliant with established law. This means compliance to the EU Cosmetic Regulation, which includes provisions such as animal testing and mandatory safety assessment.

The UK is set to weigh the costs and benefits of regulatory divergence away from direct alignment and mutual recognition with the EU when negotiating a free trade agreement (FTA). Without a FTA, the UK would revert to World Trade Organisation (WTO) rules; effectively a ‘no deal’ scenario. If there is a FTA, then the details of such an agreement will ultimately dictate the precise impact on cosmetics; possibly at short notice.

Cosmetic implications

EU legislation is not changing but the UK’s relationship to this legislation is changing. Pragmatically it is anticipated that a future UK legislation would be similar to EU law with some ‘tweaks’. The biggest impact in the short-term remains the changes to allow a product to be placed on the market. As the EU and UK are independent territories, this means definitions, changes to legal responsibilities (importers, distributors, UK/EU responsible person(s)), as well as product notification (UK/EU CPNP), labelling and safety information can be affected.

The overriding issue that remains is duplication for businesses, both under the new UK system, as well as for those who operate both in the UK and EU. This can present difficulty for supply chains, and greater effort to develop structures that comply with emerging UK and established EU law.

In the longer term, the UK can introduce further changes to reflect the internal UK market’s focus and needs. Nevertheless, as the EU is the UK’s principle trading partner, and as a global hub for natural and organic cosmetics (NOCs), the principle outcome for the UK should be to maintain ease of trade and maintain consumer benefits, including robust safety laws for human health and the environment from existing EU legislation.

Opportunities for improvement?

Since neither ‘natural’ nor ‘organic’ claims are officially defined under the EU cosmetics law, the UK government has the ability to propose positive changes improving upon EU law, such as the reduction of the impact of cosmetics on the environment, a more sustainable production and the qualification of the characteristics of natural and organic cosmetics to facilitate greener innovation as a whole.

UK-EU Consumer perception

Germany remains the largest single EU market (and the second largest market globally) for NOCs with almost 20% market share, half of which is certified. France and Italy also represent key international markets for NOCs with a clear pattern of growth.

According to the Soil Association’s report “Organic Beauty and Wellbeing Market 2020”, the UK has increased their sales in NOCs by 23% between 2018 and 2019. The continuous growth of the NOC sector in the UK is influenced by the rising popularity of natural and organic products as part of a lifestyle choices of conscious consumers, but it’s still greatly determined by consumer concern against certain ingredients.

Key Drivers: Clean, Natural, Ethical

Many consumers of cosmetics in the UK base their purchase decisions on the avoidance of various fossil fuel-based ingredients in cosmetics upon their perceived hazard such as parabens, aluminium and refined petroleum. This trend, which has its base in the “free from” claims, has recently evolved into the “clean beauty” movement.

Apart from efficiency and high quality, consumers look more and more for products that provide them with a “feel good” experience. Due to their connection to nature through their active ingredients, natural and organic cosmetics are increasingly popular not only among consumers whose lifestyle and values are in line with a natural approach, but also among those looking to improve their wellbeing.

As in the EU, UK consumers want to buy ethically produced and sustainably sourced beauty products. This movement is called “conscious beauty” and it involves not just the quality of the formulation and the brand ethos, but also aspects like packaging.

Similarly, animal welfare and protection are also a great concern for EU and UK consumers. Along with the guarantee of plant-based ingredients, and the absence of non-natural ingredients based upon perceived hazard, NOC consumers increasingly look for vegan and cruelty-free cosmetics.

NATRUE in the UK market

Natural and organic cosmeticsThe NATRUE Label is a solid reference for natural and organic cosmetics in the UK market. Retailers and manufacturers alike know our label well, and many NATRUE certified products can be found in the UK both in specialised shops and through e-commerce. NATRUE actively contributes to supporting transparency and a better understanding of natural and organic cosmetics in the UK through our participation to key events (such as NOPE) which provide us with a platform to explain the guarantees of the NATRUE Label to producers, retailers and consumers. NATRUE promotes transparency against greenwashing, and will monitor the developing UK legislation to advocate for improvements in this regard.

Author: Mark Smith, NATRUE General Director.

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