CTPA Position Papers

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

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.

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.

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

CTPA Position Paper on Microplastics

This document highlights CTPA’s position on the existing restriction proposal for microplastics, currently being developed under EU chemicals legislation ‘REACH’.  Under UK REACH, the UK Government will carry out an evidence project to review emissions of intentionally added microplastics and the risks they pose (both to human health and the environment). The results of this evidence project will be used to inform the Government’s approach to managing intentionally added microplastics, whether through UK REACH or an alternative route.

CTPA Position Paper on Siloxanes

This document highlights the CTPA position on the existing restriction proposal for siloxanes, currently being developed under EU chemicals legislation ‘REACH’.  Under UK REACH, the UK Government will assess further regulatory options for these substances in rinse-off products to move them under the UK REACH Authorisation List.

CTPA Position to Support the use of NAMs for Cosmetic Ingredients

CTPA published this blog “ Be brave to advance alternatives: UK Cosmetics industry shares its expertise in non-animal tests at pioneering CTPA workshop”.  The blog explains the existing strict animal testing ban on cosmetic products and their ingredients in the UK and EU, as well as promotes the use of New Approach Methodologies (NAMs) to generate toxicological and environmental data on cosmetic ingredients without the reliance on animal data.  The blog also gives an overview of the outcomes of a workshop on this topic convened by CTPA in collaboration with expert stakeholders on NAMs.

CTPA Position Paper of PFAS

This document highlights the CTPA position on PFAS (per- and polyfluoroalkyl substances), for which a number of EU REACH restrictions are currently under development.  As PFAS substances have a very limited use in cosmetic products and alternatives are available, CTPA on behalf of the UK cosmetics industry will not defend the use of individual PFAS substances in cosmetics.  Under UK REACH, PFAS are currently under assessment for Regulatory Management Option Analysis (RMOA).

CTPA works very closely with its EU counterpart Cosmetics Europe, the European personal care association.  Cosmetics Europe also issues recommendations to industry.

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: