CTPA Consultation Responses

In this section:

CTPA Responses to Consultations on Cosmetic Legislation
CTPA Responses to Consultations on Chemical Legislation
CTPA Responses to Consultations on Environmental Legislation
CTPA Responses to Consultations on Other Legislation
CTPA Responses to Consultations on Trade Negotiations with non-EU Countries

Consultations and impact assessments are used by Government and other key stakeholders to gather feedback from interested parties on intended policy changes or new proposals. CTPA responds to public consultations and impact assessments to explain how new initiatives will impact the UK cosmetics industry. CTPA provides constructive feedback on how to ensure the objectives of the initiatives are best met whilst maintaining an innovative and responsible UK cosmetics industry.

CTPA Responses to Consultations on Cosmetic Legislation

CTPA Response to EU’s WTO Notification G/TBT/N/EU/924 on New Fragrance Allergens - November 2022

CTPA has responded to the European Union notification of the draft legislation introducing declaration requirements for new fragrance allergens. This legislation, which will come into force in the European Union and Northern Ireland, provides a three-year transition period to comply with the new requirements, and imposes a limit of five years for products already on the market after which products should be withdrawn. CTPA has requested the five-year deadline to be removed allowing the sell-through of products avoiding unnecessary recalls. The CTPA response can be downloaded here.

CTPA Response to the Public Consultation on the EU Cosmetic Products Regulation - June 2022

The EU Cosmetic Products Regulation (EC) No 1223/2009 (EU CPR) is seen as a positive reference across the world, with numerous third countries, including the UK, having implemented, or planning to implement the same principles in their own regulatory framework. This is because the EU CPR requires that only safe cosmetic products can be placed on the EU market and maintains a very high standard of protection for human health. The EU CPR currently has a risk-based safety assessment approach to cosmetic ingredients management, which regulates ingredients based on their hazard and exposure. Products complying with the EU CPR are highly regarded outside of the EU, facilitating trade and opportunities for businesses. The CTPA response can be downloaded here.

CTPA Response to the Inception Impact Assessment of the Review of the EU Cosmetic Products Regulation - November 2021

CTPA supports the current robust process ensuring the safety of cosmetic ingredients and products, which is based on a risk-based safety assessment approach. CTPA also wholeheartedly supports the existing ban of animal testing across the EU and UK and the exemption for finished cosmetic products from the Classification, Labelling and Packaging (CLP) Regulation. In addition, CTPA promotes the digitalisation of consumer information (i.e. making more information available electronically), as well as the harmonisation of the definition of ‘nanomaterial’ across different industry sectors. The CTPA response can be downloaded here.

CTPA Responses to Consultations on Chemical Legislation

CTPA Response to the Consultation by the Department for the Environment, Food and Rural Affairs on the Alternative Transitional Registration model for UK REACH

CTPA has responded to the Department for the Environment, Food and Rural Affairs (Defra) consultation on the Alternative Transitional Registration model (ATRm) for the UK Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation. CTPA supports the principles of the proposed ATRm; however, there are practical challenges that need to be addressed to ensure that the ATRm can be complied with. CTPA also strongly supports that UK REACH is at the forefront of promoting the use of Non-Animal New Approach Methodologies (NAMs) for chemical safety assessment. The CTPA response can be downloaded here.

CTPA Response to the Consultation by the European Commission on a Nomination of D4, D5, and D6 for Inclusion in the Stockholm Convention as POPs Substances - August 2023

On the points of principle that the science is not universally aligned on the classification of D4, D5 and D6 as POPs and the precedent being set on regulating intermediates under the Stockholm Convention, CTPA does not support the EU Commission nomination of D4, D5 and D6 to the POP list under the Stockholm Convention. The CTPA response can be downloaded here.

CTPA Response to the Environmental Audit Committee Call for Evidence on the Progress of Implementing UK REACH - November 2022

CTPA has responded to the Environmental Audit Committee (EAC) call for evidence on the progress of implementing the UK Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation. CTPA has been working with the Department for the Environment, Food and Rural Affairs (Defra) and the Health and Safety Executive (HSE) on UK REACH since 2018, providing the relevant Government departments with evidence on the impact of the UK REACH provisions, particularly on downstream users of chemicals. CTPA and the UK cosmetics industry strongly support the need for a UK REACH system which protects the environment and human health. UK REACH should be a simple and proportionate framework that allows for information on chemicals to be collected efficiently, enabling effective chemical risk assessment based on the latest science. To ensure relevant and outcomes-focussed risk management, it is important that UK REACH takes into account GB-specific uses of, and exposures to, chemicals. The CTPA response can be downloaded here.

CTPA Response to Defra's Consultation on the Deadline Extension for UK REACH Registrations - August 2022

CTPA is supportive of Option 1 presented in the Defra consultation, which is an additional three years on each current deadline for registration. CTPA considers that this proposal will be the most beneficial for the future of the UK cosmetics and personal care industry. Longer deadlines will: allow industry to produce as high quality dossiers as possible, according to the requirements that will be implemented under the new registration model for UK REACH; harmonise the development of the new UK REACH model with other ongoing UK Government chemicals management initiatives, such as the UK Chemicals Strategy; allow industry to spread the costs over a longer time period, increasing the opportunity to invest in other areas such as research, innovation and sustainability initiatives; extending the deadlines by three years will not decrease the protection offered to health and the environment. The CTPA response can be downloaded here. Defra published a response to this consultation on 29 November 2022, favouring the longest extension by 3 years. Legislation will be issued to give effect to these changes.

CTPA Responses to Consultations on Environmental Legislation

In the last few years, different departments of the UK Government issued a number of calls for evidence and public consultations to gain feedback on legislative proposals and initiatives concerning environmental matters. Most of these initiatives fall under the UK Resources and Waste Strategy which seeks to minimise the impact of waste on the environment and promote the drive to a more circular economy in the UK. CTPA responses to these consultations are listed below

2024

2023

2022

2021

2020

2019

2018

HM Treasury call for Evidence on Single-use Plastics

CTPA Responses to Consultations on Other Legislation

CTPA Response to the UK Smarter Regulation Call for Evidence - January 2024

CTPA has found UK regulators open to engagement and collaboration with industry and have built close relationships with key authorities for the cosmetics sector. However, some key challenges appear in the form of absence of transparency; unclear UK Government organisational structures; low understanding of how to support efficient business decisions; and a slow pace of implementing legislation following policy announcements on business easements. CTPA’s response can be downloaded here.

CTPA Response to the UK Product Safety Regulation Consultation - October 2023

CTPA considers the UK Cosmetics Regulation (UKCR) to meet the objectives of ensuring consumer safety, supporting businesses though compliance, fostering innovation and promoting growth through domestic and international trade. CTPA’s response to the Product Safety Regulation (PSR) consultation requests preserving the UKCR, and the high standards reflected therein and does not support the inclusion of the UKCR within the proposed horizontal framework. CTPA’s response can be downloaded here.

CTPA Response to UK Government Review of Choice on Units of Measurement - August 2022

CTPA has responded to the proposal with the implications that a choice of using imperial measurements and not stating metric measurements for net quantity labelling on cosmetic products would have on the industry. The implications would mainly be confusion for consumers, and consistency across product within a company and the overall cosmetics sector. The financial implications of making the decision to remove metric system declarations on behalf of imperial units would likely render the choice invalid, as there would be substantial costs to relabel or repackage products, with little apparent benefit for the consumer. CTPA’s response can be downloaded here.

CTPA Response to the Consultation on Reforming the Framework for Better Regulation - October 2021

CTPA is in favour of taking proportionality into account when considering the need for new chemicals legislation. CTPA fully supports regulation which focusses on managing real and identified risks in a cost-effective manner, to ensure tangible improvements to health or the environment. The CTPA response can be downloaded here.

The UK Government report following responses to this consultation can be found here.

CTPA Response to the Competition and Markets Authority (CMA) Draft Guidance on Environmental Claims - July 2021

CTPA welcomes and supports the publication of the CMA guidance on environmental claims, outlining key principles with which environmental claims must comply. The guidance aims to protect consumers from misleading claims and to protect businesses from unfair. The CTPA response can be downloaded here.

From this consultation, the CMA published its Green Claims Code.

CTPA Response to the UK Product Safety Legislation Review - May 2021

CTPA supports the current rigorous process ensuring the safety of cosmetic ingredients and products, which is based on a risk-based safety assessment approach. CTPA identified opportunities to further strengthen the UK Cosmetics Regulation in relation to control of counterfeit products and certain online-retailed products, greater digitalisation of labelling information (i.e. making more information available electronically) and opportunities for reliable consumer education. The CTPA response can be downloaded here.

The UK Government report following responses to this consultation can be found here.

CTPA Responses to Consultations on Trade Negotiations with non-EU Countries

UK - Australia Free Trade Agreement (FTA)

With the support of its International Regulatory and Trade Committee (IRTC), CTPA contributed to the discussions around trade negotiations between the UK and Australia for the cosmetics sector, with the objective of securing a dedicated chapter. One year and a half after the negotiations started, the UK-Australia FTA was signed, including a Cosmetics Annex which will make easier for businesses to understand what rules need to be followed, including on products that are classified as cosmetics in one market but not the other, and secure the commitment to collaborate in the development of the regulatory framework in each territory.

UK - New Zealand Free Trade Agreement (FTA)

The UK-New Zealand FTA was signed on 28 February 2022 after nearly two years of negotiations, and CTPA contributed to the discussions on behalf of the cosmetics industry, resulting in the inclusion of sector-specific provisions on ongoing collaboration and on upholding the ban on animal testing, supporting alternative methodologies for cosmetics.