EuroCommerce Position on the Evaluation of the Cosmetic Products Regulation (CPR)

• Effectiveness

In general, the Cosmetics Products Regulation (CPR) provides a solid framework for ensuring consumer safety, which is of the utmost priority. Nonetheless, the absence of clearly defined safe threshold limits for such restricted substances may present challenges in ensuring safety and compliance. (For more details look at Section 5 on Enforcement: Thresholds).

• Efficiency

In the context of regulatory changes, short or lack of transition periods can present challenges for effective inventory management across complex supply chains, potentially resulting in avoidable product disposal and associated financial impacts. It may be helpful to consider sufficient transition periods for changes not directly related to safety, as frequent regulatory updates can entail significant operational and financial implications, due to reformulations, labelling adaptations, and packaging changes.

While the direct applicability of a Regulation is advantageous in terms of harmonisation across the EU, it remains important that implementation timelines are designed with operational realities in mind, while prioritising health and safety, to support a smooth and proportionate adjustment by all market actors. (For more details look at Section 2 on Labelling & Transition Periods).

• Relevance:

While the CPR provides a robust framework for cosmetic product safety and market access, several aspects need updating to better align with current industry needs. To remain relevant, the CPR needs to evolve to better support digital solutions, including digital labelling and documentation, and increase the role of digital labels, while also addressing environmental concerns and providing clearer pathways for sustainable innovation without compromising the high standards of consumer safety. (For more details look at Section 2 and Section 5 on Digital Labelling and Simplification).

• Coherence:

Some challenges have been observed with products that fall within borderline categories (e.g., cosmetics with biocidal claims or medical device properties). These cases can give rise to regulatory uncertainty, increased compliance efforts, and potential delays in market access. A more streamlined and harmonized approach across these regulations would reduce administrative burden while maintaining safety standards.

In addition, economic operators are often confused of the regulatory boundaries between CPR, REACH and CLP, particularly in the areas of hazard communication and notification systems. Additionally, the use of broad substance group definitions in REACH restrictions—without clear identifiers like CAS or INCI numbers—makes it difficult for stakeholders to determine whether cosmetic ingredients are in scope, highlighting the need for better alignment and cross-referencing between databases. (For more details look at Section 4 Interface with REACH, CLP).

• EU Added Value:

The Regulation plays an important role in ensuring the consistent implementation of EU legislation across Member States, thereby facilitating the smooth functioning of the internal market for cosmetic products. It helps reduce the risk of divergent interpretations by national authorities, supporting legal certainty and cross-border trade.

At the same time, the Regulation could benefit from further harmonisation of definitions, safety assessment methodologies, and coherence on expectations from market surveillance across Member States, where approaches might differ