Five reasons for the UK cosmetics and personal care industry to be cheerful in 2022

By Dr Emma Meredith, Director-General, CTPA

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CTPA takes pride in tracking pressing issues across the year on behalf of our members, who span product development through to retail, and the industry as a whole. It’s critical that our thinking stays current as we represent their voice to Governments, Regulators and the scientific community.

So, what will 2022 hold for the UK cosmetics and personal care industry? We’ve all learned to expect a sizable serving of the unexpected in recent years, but what can companies plan for? And is the outlook optimistic?

Happily, there are a host of hot topics we can be certain will be a feature this year. The good news is that even those that could seem most challenging at face value, offer plenty of opportunities too, if we prepare for them. Opportunities to innovate. To reimagine how we trade. To build confidence in our claims – and more.

In this latest blog, I explore five of our favourite reasons to feel cheerful about the year ahead…

1. Responsible green claims will build trust. 

   The CMA’s (Competition and Markets Authority) Green Claims Code started to be enforced last month, which means we can expect to see positive changes in the way that companies of all kinds make environmental claims. In short, the Code supports a shift from the ambiguous to the accurate. 

   In the context of our industry, the call for claims to “be clear and unambiguous” may mean a crack-down on generalised marketing concepts like ‘clean’, ‘green’, ‘eco’ or ‘biodegradable’, which may be driven by short-term advantage, rather than science. Meanwhile, the call for claims to “consider the whole lifecycle of the product” could also mean greater scrutiny of broad-brush terms such as ‘sustainable’ or ‘sustainably sourced’, which can be applicable to just a small part of a product’s story, while appearing to mean the whole product’s green credentials.

   For the UK cosmetics and personal care industry, starting with a clean green slate in 2022 can only be a good thing. It creates a level (and truthful) playing field for companies of all sizes, while building consumer trust at a time when our customers demand, and deserve, more transparency than ever before. Let’s face it, nobody wants to find out they’re being greenwashed while they wash. 

   You can read more about this in my recent interview with Kacey Culliney from Cosmetics Design Europe.

2. More customers will help to create change. 

   In April, the introduction of the Plastic Packaging Tax will see every industry take on greater costs to conserve our environment. It will apply to plastic packaging that contains less than 30 per cent recycled plastic. However, there will also be more opportunities for consumers to create change if companies take steps to engage them. Towards the end of last year, the UK cosmetics and personal care industry announced it would be moving forward on take-back schemes for cosmetics packaging that are currently not recycled. This Spring we can expect to see a ramping up of efforts to engage more consumers with the excellent Recycling Locator Tool, in collaboration with the Recycle Now team at WRAP. It will be an exciting shift by our industry, and one welcomed by our customers who have had the motivation, but perhaps not the information, to play their part on our journey towards NET positive.

3. New trading terms will bring new opportunities. 

   While Brexit will continue to bring changes for companies to contend with, there will also be opportunities if companies know where to look - and how to harness them. Perhaps the best poster child for this is Free Trade Agreements, which will continue to be a hot topic this year. Free Trade Agreements offer opportunities to reduce bureaucracy, paperwork and costs. While the inclusion of dedicated Cosmetics Chapters within the Agreements - something CTPA is advocating for - creates chances to make regulatory frameworks more compatible across regions. A clear mutual benefit for any two countries wishing to trade. Our industry’s work with Australia has created a positive case study for this already, so while we cannot say whether the UK’s attempts to agree new deals with Canada, Mexico, India and the Gulf Cooperation Council (GCC) will be successful, if they are we will be encouraging both sides to include a Cosmetics Chapter.

4. Divergence can foster innovation. 

   As the UK develops its own chemical regulatory system post-Brexit it is bound to encounter risks and challenges, including potential extra costs for companies operating across Europe and internationally, and some monumental manufacturing headaches. It’s very likely that the EU and UK will take different paths on certain issues, but it’s also very likely to create opportunities too.  Active divergence could be a real positive for our industry, creating clear space for the UK to follow the science and innovate where it matters most. A great example of this is alternatives to animal testing. Make no mistake, the UK is not back-tracking on the strict animal testing bans that have been in place for many years.  Divergence could pave the way for the UK to design even more innovative alternatives to continue to support the safety of our ingredients and to integrate these into our regulatory system, creating value proofs of concept for the EU market, and beyond.

5. Opportunities for the UK to rally a risk-based approach. 

   Divergence or no divergence, companies selling to both the EU and UK will want to ensure that if their products comply with EU Regulation, they’ll be accepted in the UK too. What divergence might do, is offer companies keen to focus on the UK market a chance to draw on a greater palette of ingredients, all the while building a compelling safety profile to share with more hazard-driven EU Regulators. In this regard, 2022 could see divergence creating a very real opportunity to rally a risk-based and science-proven approach to ingredient safety. This would be the best outcome for companies and consumers, helping us to safeguard the future of products that play an essential part of our lives, from sun-safety through to our self-esteem.

For more information on the latest industry issues, get in touch with the CTPA team.