A potential review of the CPR was announced in 2020, as part of the EU’s Chemical’s Strategy for Sustainability, which aims to remove potentially harmful chemicals from consumer products.
Revising the CPR would allow the EC to ban persistent and bio-accumulative chemicals that are used in cosmetics, or ingredients that affect the reproductive or endocrine systems.
The revision of the REACH regulation – which co-exists alongside CPR and simultaneously impacts the cosmetics sector – was also due a review, but this was stopped in February 2024.
Revision of the CPR: “no consensus within the Commission”
At the Cosmetics Europe annual conference (CEAC) on 19th June in Brussels, the head of unit at the European Commission’s DG GROW, Hans Ingels, said that political discussions had been taking place on how to best proceed with the CPR revision.
He explained that an impact assessment had been undertaken that showed some options would be costly for the industry and that there was currently “no consensus within the Commission.”
Cosmetics Europe’s director-general John Chave compared the revision of the proposal to the Loch Ness Monster, stating that: “Some people claim to have seen it, but its existence has never been proven.”
“It’s interesting that we had a one and half hour session on a regulation that hasn’t actually been published yet,” Chave told CosmeticsDesign-Europe after the discussion panel.
He highlighted that Ingels had said that he’d never seen so many people happy about a regulation that hasn’t been published yet.
“I think that is indicative of issues that potentially could be involved in the revision going forward and how our industry really needs to reflect on what we need and what we want,” continued Chave.
Many people in the cosmetics industry have express concerns about the potential impact of a revision of the CPR, staying that it could negatively affect the sector’s competitiveness.
“The CPR stood the test of time in our point of view – it’s a gold-standard for the world – that’s not to say that some things can’t be improved.”
“We will have to see what happens going forward. For the industry it’s important that we don’t have a revision that makes things less easy for us,” he said.
“We think that we don’t need a full revision of the CPR. We think some of the concerns that have been expressed can be addressed, but without a revision of the CPR.”
The ‘essential uses’ concept is another key element of the Commission’s Chemical Strategy for Sustainability. This outlines situations where harmful substances can be allowed if their use is considered necessary for reasons of health or safety if there are no acceptable alternatives.
In April 2024, the EC adopted guiding criteria and principles to determine how the ‘essential uses’ concept would be used. As it stands, this is not set in stone, and it would only have legal effect if introduced into specific legislation. There are currently many doubts and questions about its application.
The implementation of the chemicals strategy is due to be discussed on 14 October 2024.
Cosmetics product labelling: problematic
At the CEAC conference, Chave also told CosmeticsDesign-Europe that the industry faces many labelling challenges. “Labelling for our industry is particularly problematic because of different packaging sizes for example and at the same time for good environmental reasons we are being asked to reduce packaging, so that is a bit of a dilemma,” he said.
“We think the way forward is to move to a system of digital labelling, that will be more ecological and allow us to provide information to consumers in a more digestible way, but as came out in the discussion, there are still some challenges with that and there is work to be done,” he continued.
“We think it is the most favourable option, although we don’t dismiss the concerns. The challenge for our industry is to work with all stakeholders to find a solution that enhances the information environment.”