Square one: the European Green Deal. Climate change and environmental degradation are an existential threat to Europe and the world. The EU is committed to becoming the first climate neutral bloc in the world by 2050. Changing consumption behaviours can be a significant driver, empowering consumers to play their part in achieving a more sustainable economy.

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Cosmetic standards are subject to the political framework

Launched by the European Commission (EC) in December 2019, the European Green Deal initiated a number of policy areas which can be seen to impact natural and organic cosmetics (NOCs) across the supply chain from sourcing to packaging including:

  • From farm to fork (agricultural products including organic)
  • Protecting nature (biodiversity protection, sourcing and environmental sustainability)
  • Mobilising industry for a clean and circular economy (raw materials, packaging)

Chemicals: Safe and Sustainable by design

In October 2020 the EC launched the Chemicals Strategy for Sustainability (CSS). This initiative represents a highly ambitious strategy for chemicals within the EU with two key objectives: (i) to better protect citizens and the environment; (ii) to boost innovation for safe and sustainable chemicals The CSS lays out a number of actions to achieve these objectives by focusing on, for example:

  • banning the most harmful chemicals in consumer products (except where essential);
  • assessing risk focus on aggregate exposure (‘cocktail effect’) to chemicals;
  • boosting investment and innovation for production of chemicals that are safe and sustainable by design;
  • establishing a simpler “one substance one assessment” process

The CSS overarches various horizontal policy areas related to chemicals, including downstream users of chemical substances like cosmetics, and integrates itself within the circular economy approach also at the heart of the European Green Deal.

It is important to mantain an upholding robust safety assessment for consumers and the environment

Upstream revisions, downstream impacts

As a first step towards alignment of the CSS both REACH and CLP are undergoing the process of revision. Currently both pieces of horizontal legislation can already impact cosmetics, and so it any potential changes to these regulations will have an impact too. Noted points for cosmetics under the CLP Regulation revision process have been a reference to the possibility to extend the scope to cosmetics, clarification of the classification rules for complex substances (e.g., natural complex mixtures – plant extracts, essential oils), and examining different measures and options to introduce new hazard classes (e.g., endocrine disruption, persistency, bioaccumulation and toxicity).

For the REACH revision, a noted element has been the proposed introduction of mixtures assessment factors (MAFs). In basic terms, this tool is proposed to act as an additional safety factor applied to single substances to account the effects of mixtures in a generic way. For instance, when the available data are insufficient to allow the assessment of real co-exposure the method would ensure a risk that is not higher than the risk represented by each substance. For natural complex mixtures (NCSs) there is an element of risk since data may not be available for all constituents and exposure may come from a wide variety of sources.

cosmetics rules
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Another noted element is the proposal to extend the generic approaches to risk management for all chemicals. The aim is to accelerate the REACH restriction process based on hazard classes. The approach can be thought of as the treatment of category 1 CMRs in cosmetics, which are automatically banned unless exempted. Under the REACH revision this exemption centres around essential use, which triggers a debate around what precisely is ‘essential use’; both in terms of chemical substances and for cosmetics i.e., are cosmetics considered essential to society enough to be granted an exemption?

Cosmetics: a targeted revision

In October 2021, the EC presentation its roadmap for targeted revision of the EU Cosmetics Regulation covering policies options link to:

  • extend the generic approach to risk management to cosmetics;
  • improving the effectiveness, efficiency and coherence of safety assessments in line with the “One Substance, One Assessment” approach;
  • reviewing the definition of nanomaterial;
  • on-pack and digital labelling and/or labelling simplification.

A targeted revision is relevant since the aim is to align to the approaches announced under the CSS, and in March 2022 an open publication was launched.

Another important element is the proposal to extend generic risk management approaches to all chemicals

Status quo and future

The EU Cosmetics Regulation provides an international point of reference when it comes to ensuring a high level of consumer safety. In terms of its revision, it is currently unknown what the outcome will be except that the current timeline for all actions to consolidate is Q4 2022. The importance of the Green Growth agenda and upholding robust safety assessment for consumers and the environment resonant strongly the natural sector and its consumers. However, the principal issue remains the degree to which these legislative revisions impact the entire cosmetics industry. To this end, the natural sector cannot consider itself shielded from the impact of this emerging and evolving legislation.

For the natural sector it is apparent that in order to maintain both the authenticity of claims like ‘natural’ or ‘organic’ for cosmetics, as well as the product diversity consumers have become accustomed to there is an essential need to maintain a diverse palette of ingredients, and in particular natural complex substances, in order to ensure consumers can continue to enjoy authentic natural and organic cosmetics meeting their expectations. It is for this reason that NATRUE has contributed, and continues to contribute, to these revision processes.

Author: Dr Mark Smith, NATRUE Director

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