CTPA Position Papers

CTPA develops position papers, in collaboration with its membership, to indicate the views of the UK cosmetics industry on relevant matters.


Cosmetics Industry Position on Implementing an Extended Producer Responsibility Framework for Micropollutants in Wastewater -           January 2026

In its 2025 report, the Independent Water Commission recommended exploring whether an Extended Producer Responsibility (EPR) scheme could provide an effective approach to managing micropollutants in wastewater in England and Wales. This document presents the cosmetics industry’s perspective on the potential implementation of an EPR framework for addressing micropollutants in wastewater.

CTPA and Chemicals Industries Position Paper on EU/UK Regulatory Cooperation on Chemicals - December 2025

In a challenging geopolitical and economic environment, it is critical to make full use of the trade agreements in place between the EU and UK.  In the field of chemicals and cosmetics, the EU/UK Trade and Cooperation Agreement (TCA) provides for such an opportunity through the Chemicals Annex.   Therefore, the UK and EU chemicals and cosmetics industries strongly support structured regulatory cooperation on chemicals between the UK and EU, with key policy asks outlined in this position paper.

CTPA Budget Submission - October 2025

On 15 October CTPA made a submission to HM Treasury ahead of the Budget taking place on 26 November 2025.  The submission outlines key recommendations on growth, better regulation, reducing barriers to growth, highly specific for our industry which are targeted, prioritised and actionable.  The submission can be downloaded here.

Joint Position Paper on the Overarching Principles for Moving Towards Animal-Free Safety Assessment for Chemicals - March 2025

CTPA is publishing this position paper ‘Moving Towards Animal-free Chemical Safety Assessment – Overarching Principles’, on the overarching principles for moving towards animal-free safety assessment for chemicals.  This paper was developed jointly with the Chemical Industries Association (CIA).  The International Fragrance Association (IFRA UK), the British Coatings Federation (BCF) and the Chemical Businesses Association (BCA) are also co-signatories to this paper.

The document sets out the overarching principles shared by the chemical manufacturers and downstream users, in their shared ambition to move away from animal testing when scientifically possible.  This position paper would sit on top of the position papers by the individual organisations, supporting the common themes – the CTPA position paper on this topic can be downloaded here.  Both documents are publicly available and can be used for advocacy activities in this area.

CTPA Position on the Promotion and Uptake of Non-Animal New Approach Methodologies (NAMs) for Chemical Risk Assessment in the UK - December 2024

CTPA's Position Paper sets out how CTPA fully supports efforts to accelerate the development, validation and uptake of technologies to reduce the use of animals in science in the UK and this Position Paper outlines practical steps which can help to achieve this important objective.  CTPA looks forward to continuing to work with key parties with a shared interest in progress, with the aim of expediting the UK’s strategy for moving to animal-free safety science.

CTPA Position Paper on Take-back Schemes for Small Cosmetic Product Packaging - February 2023

This document highlights CTPA support for the provision of Take-back Schemes to collect otherwise unrecycled small cosmetic packaging.

CTPA strongly believes that all items of packaging for cosmetic products placed on the market must be ultimately recyclable, either via kerbside collections or through the provision of Take-back Schemes.

While the ultimate aim of CTPA is the harmonisation of schemes, amalgamation of waste and its meaningful reprocessing, these goals are intrinsically linked with the UK Government’s plans for Extended Producer Responsibility, key aspects of which are currently undetermined. In the meantime, CTPA has committed to work with companies to maximise collection through Take-Back Schemes that are already in place and encourage other schemes to be set up.  In addition, working with the Recycle Now team at WRAP, CTPA will aim to increase the number of cosmetics brands that are listed on the Recycling Locator tool and highlighting Take-back Schemes to their consumers and so encouraging this form of recycling for currently unrecycled cosmetic packaging.

For further information including definitions, legal requirements and guidance on sustainability and environment, please visit the Sustainability Hub.

CTPA Position Paper on the use of ’Free From’ Claims

This document highlights CTPA’s position on the use of ‘Free from’ claims, including claims with a similar meaning, for cosmetic and personal care products.  CTPA believes companies should only use ‘Free from’ claims when they are intended to inform consumer choice.  Consumers should not be led to believe that a cosmetic product with a ‘Free from’ claim is safer, which legally cannot be true.

CTPA Position on Third-Party Certifications

CTPA is the trade association representing the UK cosmetics industry.  CTPA is not affiliated with any commercial organisations.  CTPA cannot endorse nor comment on the adherence or use of third-party certifications, commercial symbols, private logos, or schemes, irrespective of their philosophy and placement on marketing materials. 

CTPA advises on the strict legal requirements for cosmetics and personal care products, including compliance with the claims requirements.  Whilst certifications are voluntary, compliance with both the UK and EU Cosmetics Regulations (depending on the market where the product is sold) is a legal obligation. The use of symbols associated to commercial certifications can be considered as an advertising claim, and cosmetic claims are regulated under Article 20 of both the UK Cosmetics Regulation (for the GB market) and the EU Cosmetic Products Regulation (for the EU and NI markets).  Furthermore, cosmetic claims must comply with EU Regulation 655/2013 providing the Common Criteria for Cosmetic Claims, which remain applicable for both GB and NI.  For further information on compliance of cosmetic claims, please visit the CTPA Claims Reference Zone.

CTPA Position on the Essential Use Concept

This document outlines how CTPA supports a risk-based UK chemicals management framework where success can be measured by tangible, real-world benefits to the environment and to society, rather than a broad, hazard-based approach which unnecessarily forfeits safe and useful chemicals now and in the future.  CTPA does not support inclusion of an essential use concept into UK chemicals legislation and considers the concept to be fundamentally flawed.

CTPA Position Papers on the UK/EU Negotiations – February 2019

These documents summarise the CTPA position and the industry key asks to the UK Government on the UK/EU Brexit negotiations, in particular in regard to the Cosmetics Regulation, REACH Regulation and Trade: