On 7 October 2025, the European Commission published the Factual Summary Report of the public consultation conducted as part of the evaluation of Regulation (EC) No 1223/2009 on cosmetic products (the EU Cosmetics Regulation).
The report provides an overview of the feedback received from stakeholders and citizens and will contribute to the ongoing evaluation process.
Background: previous steps in the evaluation of the Cosmetics Regulation
In February 2025, the Commission launched a Call for Evidence. This was the first phase of the evaluation process, namely assessing the effectiveness of the EU Cosmetics Regulation. The feedback period ran from 21 February to 21 March 2025. The second phase began in May 2025 with a Targeted Consultation, which gathered detailed input from stakeholders.
The Factual Summary Report published in October 2025 summarises the contributions received through the public consultation. A total of 206 unique responses were analysed. Importantly, the report’s introduction clarifies that the document does not represent the official position of the European Commission.
Key findings by selected thematic area: does the Cosmetics Regulation work as intended?
Protection of human health
A large majority of respondents (84%) agreed that the Cosmetics Regulation effectively protects human health, and an even higher percentage (91%) considered this objective to remain relevant.
The Product Information File (PIF) was widely regarded as a useful and comprehensive tool but also seen as costly and burdensome for companies to compile.
Regarding labelling information, most stakeholders reported that consumers most often use details such as:
- product function (73%)
- particular precautions for use (63%)
- nominal content (60%)
- date of minimum durability (45%)
Experts largely agreed that most mandatory labelling elements contribute to consumer safety.
However, views were mostly mixed on the provisions on claims and advertising. While business associations, NGOs, and companies tended to find the provisions clear, consumer organisations, EU citizens, and public authorities generally disagreed. Overall, only 42% of expert stakeholders believed the rules are effective in ensuring reliable consumer information.
Functioning of the internal market
Most stakeholders (77%) agreed that the Regulation supports the free movement of cosmetic products within the EU. Similarly, 67% of stakeholders found it easy to buy or sell cosmetics across Member States, and 82% felt there is good product variety within the EU market.
Scope, coherence, and international alignment
A majority of respondents (72%) agreed that the Regulation adequately covers all relevant products, and 64% felt it appropriately excludes non-cosmetic items. The major classification challenge has been identified in distinguishing cosmetics from medical devices.
Stakeholders called for the Regulation to extend its scope to environmental hazards and the sustainability of ingredients, including their impact during product use and disposal.
Transparency and market surveillance
According to 60% of respondents, measures introduced under the Regulation have increased consumer confidence in cosmetics. In addition, 58% of companies reported that market surveillance activity has increased since the Regulation’s implementation.
Animal testing ban (Article 18)
Most respondents (71%) agreed that the animal testing ban effectively protects animal welfare. Only 52% agreed that the ban has helped promote alternative testing methods.
Efficiency and costs
An low percentage of experts, ranging from35% and 47%, felt that the Regulation’s Annexes are updated in a timely manner, though 71% agreed that stakeholders are adequately informed upon changes and updates.
More than half of the stakeholders defined transition periods for new bans or restrictions as too short, and 62% of respondents reported increased compliance costs, particularly due to:
- documentation and reporting (viewed as the largest contributor to cost increases)
- labelling obligations
- product reformulations
- safety assessments
Lastly, a large group of respondents argued that compliance obligations reduce the competitiveness of EU companies.
If you have any questions or need assistance to place your products on the EU, UK, US, and Canadian markets, contact COSlaw Team here or at coslaw@obelis.net.
References
European Commission. (2025). Factual Summary Report on the Public Consultation on the evaluation of Regulation (EC) No 1223/2009 – Cosmetic Products Regulation. Retrieved on 8 October 2025.
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