In December 2019, the European Commission published its European Green Deal – a far-reaching plan that targeted climate-neutrality by 2050 and encouraged circular business models and clean tech uptake for sustainable change. Within the European Green Deal were a raft of strategies, notably the Chemicals Strategy for Sustainability which would be rolled out this year and had significant implications for the cosmetics industry.
European Green Deal a ‘major policy challenge’ for cosmetics
“A major preoccupation for Cosmetics Europe in 2021 is going to be the implications of the European Green Deal, particularly from a regulatory perspective on chemicals with the Chemicals Strategy for Sustainability,” said John Chave, director-general of European trade association Cosmetics Europe.
“…It’s a major policy challenge on a number of fronts and it will be the dominant concern of our association and the industry in Europe for 2021 and beyond,” Chave told CosmeticsDesign-Europe.
The European Green Deal, which he said contained the “very broad” strategy on chemicals outlining around 50 different regulatory proposals, created “completely new territory” for the regulation of chemicals in the EU, he said.
“One of the pillars under the Chemicals Strategy for Sustainability is essentiality, by which they mean that they will look at products which are essential in a different regulatory way.
“[The Commission] will give more regulatory scope for essential ingredients, for example, as opposed to non-essential where, if they consider there are hazards or risks posed to human or environmental health, they will be stricter in terms of their regulatory approach,” he said.
The issue facing the cosmetics industry, Chave said, was the Commission had taken a “very narrow view” on what essential was, and there were mixed views at EU-level on whether cosmetics were considered essential to everyday life, which had to change.
Cosmetic products must be considered ‘essential in a broader way’
“One of the perennial problems with the industry, is we tend to be associated with colour cosmetics and people don’t understand the range and depth of our industry,” Chave said.
One of the messages Cosmetics Europe and its members would be focused on in 2021 around ‘essentiality’, therefore, was how cosmetic and personal care products were “essential in a broader way”, he said.
“It’s not just about fighting infection, important as that is; it’s not just about hygiene, important as that is; it’s about some of the broader effects on wellbeing and quality of life, self-confidence and social interaction which we know from our own evidence that cosmetics can bring,” Chave said.
“…What we as an industry would like to draw more attention to is we are essential in this broader sense and we should be considered as having a societal importance. And I think, historically, we haven’t managed to get this message across. Now, we need to get this across because it’s true and relevant to the regulatory landscape we find ourselves in.”
Fighting against a ‘very narrow view’ on essentiality
The concept of essentiality – referenced as a pillar in the Commission’s European Green Deal – had drawn inspiration from the UN’s international treaty the Montreal Protocol that aimed to protect the ozone layer by regulating and phasing out numerous substances responsible for ozone depletion.
The problem with that, Chave said, was that ozone depletion remained a “very narrow way of looking at essentiality”.
“It’s a ground-breaking way of thinking about regulating chemicals, but still remains somewhat undefined. There’s still a need for deeper reflection on how we think about chemicals and cosmetics and other products in terms of the product’s essentiality.”
“…We would prefer to discuss essentiality in terms of whether our products, and by implication ingredients, bring something to improve people’s wellbeing and quality of life,” he said.
Industry needs to show consumer evidence of essentiality
Chave said Cosmetics Europe had been, and would continue to, work hard engaging with EU officials and wider stakeholders on the topic of essentiality. However, what was clear moving into 2021 was the need to bring forward the consumer point of view.
“I don’t think we have channelled quite as much as we could on the ordinary experiences of the hundreds of millions of cosmetic consumers across Europe and the world who value cosmetics. I think the challenge for Cosmetics Europe and other associations is to make sure that the consumer voice is heard.”
Positive experiences of ordinary consumers were traditionally far less prominent in European policy debates but extremely important if stakeholders were to truly understand what cosmetics meant to people.
“In the past, we’ve asked people whether they value cosmetics, and the evidence is fairly stark and clear – the vast majority of people say [cosmetics] improve their quality of life. We need to build this bridge between policy makers and the real needs and expectations of consumers, with regards to the products they enjoy,” Chave said.
Cosmetics Europe would continue looking into a variety of options it could take forward for arguments on essentiality in 2021, he said. It would also continue to spotlight what its members were achieving in terms of sustainability and environmental impact already because “many companies are setting a superb example”.