Published: 21 May 2024  (Updated: 04 June 2024)

CTPA Manifesto series #4: protect science-led decision-making

By Dr. Emma Meredith, Director General, CTPA

The CTPA Manifesto, the first of its kind, has 12 asks of the next UK Government, the implementation of which would deliver a dedicated strategy for the cosmetics and personal care industry.  The strategic asks in the #CTPAManifesto2024 fall under five pillars of essentiality, regulation, science, sustainability and business.  I have already shared my views on how essential our products are to our everyday life, wellbeing and hygiene and on the importance on a strict regulatory framework.  Today I want to talk science!

I am extremely passionate about science.  Some of you may have heard me share my ‘lightbulb moment’ before.  I knew I wanted to be a scientist from around the age of seven years old, when one of my cousins made his own fireworks in the back yard (not that I am advocating DIY pyrotechnics, in the spirit of health and safety!).  Admittedly the fireworks set the bench on fire, but with a sense of wonderment of putting substances together to create an amazing, visible and pungent reaction, I was hooked!  My love of science, and fireworks for that matter, is still strong today.  I therefore count myself incredibly fortunate to work in an industry absolutely rooted in science.  Indeed, when CTPA was starting out on its communications strategy to promote the science behind our products we used the strapline “Amazing Science Applied Daily”.

My own pathway to working for CTPA was undoubtably aided by my pharmacy background, but also the subject of my PhD.  This involved recreating the skin pigment melanin in the laboratory and trying to investigate the pathway of malignant melanomas, caused by the damaging effects of the sun.  Sunscreens, classed as cosmetic products, are one part of a sun-safe regime.  I am sure we often use suncream without necessarily thinking about how it works, but to me it is fascinating that we have UV filters that work in different ways and are able to protect against all the individual wavelengths of the UVA and UVB spectrum because of their chemical structure. How amazing is that?!

Each and every step in developing a cosmetic product involves many different scientific disciplines – from biologists, chemists, microbiologists, physicists, to rheologists, environmental scientists, toxicologists.  A true A-Z of scientists have a place in our innovative industry.

Therefore, it was obvious to me that one of the pillars of the CTPA Manifesto had to be science.

A basic tenet of science is the concept of risk versus hazard, and the distinction between hazard and risk is essential.  As you know, hazard is an intrinsic property that any chemical, even water for example, has that could cause harm in high doses.  Risk is how we manage any possible issues of concern through controlled ways so that exposure to the substance is very low and/or it is used in a way that the hazardous property does not present itself. 

CTPA advocates for a proportionate, risk-based and science-led approach to chemicals, environmental and product safety management.  If regulation is overly focussed on eliminating hazards which pose limited real-world risks, the UK will undoubtedly miss leading innovative solutions to various challenges and forego access to chemical products which benefit society on a daily basis.

CTPA strongly supports regulatory action when there is sound scientific evidence of real harm to human health or the environment – but not where there are some suggestions of possible hazard that do not translate into real-world risks.

This is why the CTPA Manifesto is asking that any decisions being made on the safe use of cosmetic ingredients and finished cosmetics and personal care products follow a robust science-led and risk-based approach.  We are also calling for a long-term commitment to transparent, risk-based and independent scientific advice to inform the regulation of cosmetics under the UK Cosmetics Regulation (UKCR).

Risk is fundamental to our industry.  The safety of our cosmetic products is assured due to a robust risk assessment – the cosmetic safety assessment, a legal requirement under the UKCR. 

The UKCR also has strict bans on the testing of cosmetic products and their ingredients on animals, and the Manifesto asks that all future UK Governments must rigorously uphold these bans.

As an industry, the move away from animal data has made us a global pioneer in research into alternative methods that do not use animals.  The cosmetics industry has a long-standing commitment to the replacement of animal testing and plays a leading role in the development of alternatives by dedicating funding, time, resources and scientific expertise to this area of research. We should be proud of the investment made and the successes achieved in developing non-animal science, also known as Non-Animal New Approach Methodologies (NAMs), to ensure human safety. 

CTPA has an ongoing commitment to supporting the cosmetics and personal care industry in the development, promotion and regulatory acceptance of NAMs.  Examples of CTPA’s work include stakeholder workshops, practical training for safety assessors and collaboration with the global cosmetics industry and regulators, and CTPA is proud to be a member of the International Collaboration on Cosmetics Safety (ICCS).  CTPA is also increasing its collaboration with sister associations from the wider chemicals sector, to promote the use of NAMs beyond the cosmetics industry.

The CTPA Manifesto asks that Government publishes a strategy that establishes a commitment to integrate the use of animal-free methods into the safety assessment of chemicals.  We would like to see the Government prioritise collaboration to identify industry’s needs and challenges with the development and adoption of animal-free test methods for chemicals safety, and for occupational health and safety and environmental assessment.  Implementing a strategy to encourage the promotion, dissemination, education and implementation of non-animal NAMs in chemicals testing and safety assessment will prioritise this important work across all sectors and Government departments.

I was therefore delighted when Andrew Griffith MP, Minister of State for the Department for Science, Innovation and Technology, shared a video message at the recent CTPA dedicated UK NAMs strategy seminar, ‘For a Government Strategy on Non-Animal Methodologies’, where he conveyed the Government’s commitment to driving forward the development and use of non-animal scientific methods through publication of a plan, and that the Government is doubling its investment in non- animal methods.

Cosmetic products - Amazing Science Applied Daily.


Read the full CTPA Manifesto here.

Please share the Manifesto internally and with your key stakeholders!

Join me on the next stop of this journey through our five Manifesto pillars to hear CTPA’s key asks on the critical subject of sustainability.


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