What is the impact of the EU chemicals strategy for sustainability on the Cosmetics Regulation?

October 29, 2021 – As part of the European Green Deal, with the ultimate goal of achieving toxic-free environment, the European Commission published the EU chemicals strategy for sustainability on October 14, 2020.

On this basis, the European Commission launched a consultation on the Roadmap on October 4, 2021, to address aspects related to cosmetics.

Let’s see how the implementation of the Strategy will affect the cosmetics regulatory framework as well!


Chemicals are present in most consumer goods – toys, cosmetics, and textile – but they might have hazardous properties and harm human and environment safety. Currently, the candidate list in REACH and in Annex VI to the CLP Regulation include the substances of concern.


The European Commission has called for a revision of the current EU’s chemicals policy to further protect both human health and the planet. This includes:

  • Reinforcement of REACH and CLP Regulation;
  • Ensuring a coherent approach in sectorial legislations, including the cosmetics one;
  • Creating tools that enable a prompt response to scientific findings.


Revision of the EU Cosmetics Regulation

The Regulation EC 1223/2009 on cosmetic products needs a revision to align with the EU chemicals strategy for sustainability. Among the proposed changes, there are the introduction of a new horizontal definition of nanomaterial and the development of digital labeling.

Authorities, industry representatives, citizens and researchers are all invited to give their feedback on how to improve the current cosmetics regulatory framework. The initiative will close on November 1, 2021.

Moreover, before the end of 2021, a public consultation on the topic will take place. Afterwards, the adoption of the new EU Cosmetics Regulation will likely be in the fourth quarter of 2022. You can find the roadmap here.

Generic approach to risk management vs specific risk assessment

One of the main points under discussion, is the introduction of the generic approach to risk management as the default method to evaluate chemicals. If the proposal will pass, the substances assessment will be by groups and no longer one by one.

In this scenario, after the evaluation, an automatic ban for use in consumer goods will apply to a category of substances that has hazardous properties. Exceptionally, the European Commission can permit their use with restrictions if the chemicals meet the essentiality criteria – which are not defined yet.

Conversely, the specific risk assessment method (currently, the most common) implies that substances of concern are evaluated and then ‘regulated on a case-by-case basis and for each specific use’ (EC, 2020).

According to the EU chemical strategy, the assessment procedure must be modified to make it simpler and more predictable. Therefore, the revision might introduce the principle ‘one substance, one assessment’. According to it, the evaluation of a substance must consider all the relevant sectors.

Hazardous chemicals in the EU Cosmetics Regulation

The EU Cosmetics Regulation specifically addresses CMR substances only. However, there are many more chemical categories that might present hazardous properties. At present, the Scientific Committee on Consumer Safety (SCCS) must assess substances of concern that are not CMR. Eventually, the European Commission includes restricted or banned substances in Annexes II or III of the EU Cosmetics Regulation.

The extension of the provisions restricting CMR in the EU Cosmetics Regulation to further hazard classes, as endocrine disruptors is also envisaged among the objectives of the EU chemicals strategy for sustainability.

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