Axis 1: the strategy for sustainability in the chemicals sector (CSS), or more broadly, the zero-pollution plan.
This axis aims to achieve a world free of substances that are toxic to human health or the environment. To this end, the EU wishes to regulate products from the design stage, rather than controlling them once they are on the market. Regulatory developments in line with the Green Deal include the following:
- Several one-off amendments to the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation on the manufacture, placing on the market and use of chemicals, to ban non-biodegradable microplastics and PFAs in cosmetics and other products.
- Amendments to the CPR (Cosmetics Product Regulation; EU Cosmetics Regulation 1223/2009), which specifies regulations to take account of the specific features of the cosmetics sector with the aim of guaranteeing optimum safety, are planned. The definition of microparticles has been revised to bring it into line with REACH.
- More far-reaching changes to REACH to enable simpler, more effective assessment of the risks associated with chemical substances. For example, the European Chemical Agency (ECHA) is working on a tool for assessing the effects of mixtures of chemicals (the “mixture assessment factor”) and on a system for grouping chemicals by family, to avoid regulating them one by one. However, it should be noted that the vote on these directives has been postponed several times by the European Commission.
- The obligation for pharmaceutical and cosmetics manufacturers to pay for the treatment of wastewater in which their products are found.
Axis 2: the sustainable industry plan, and more specifically the new circular economy action plan (CEAP)
After an initial eco-design directive adopted in 2019, the Green Deal has given birth to the CEAP and, within this framework, the proposal for a new Eco-design for Sustainable Products Regulation (ESPR) in March 2022. One of the European Commission’s objectives is to improve product traceability, giving consumers all the information they need to choose their product. To this end, the notion of a “product passport” has been introduced by a European directive. A packaging directive has also been adopted, encouraging manufacturers to produce reusable packaging. Finally, a directive aimed at protecting consumers from greenwashing (misleading environmental claims) was published in March 2024.
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Axis 3: Biodiversity strategy for 2030
The aim of this strategy is to create a long-term plan to protect nature and reverse the degradation of ecosystems in Europe and worldwide. Regulations on imported products derived from deforestation are part of this plan. The import of certain listed chemical products (e.g. palm oil) will be prohibited without sufficient traceability to exclude any link with deforestation.
Axis 4: the “Fit for 55” energy strategy
“Fit for 55” has been given a great deal of prominence, as it concerns all sectors of activity. The goal is to reduce greenhouse gas (GHG) emissions by 55% by 2055. It directly concerns the transport and construction sectors, as well as energy-intensive industries. However, as for all industrial sectors, the “Fit for 55” could have a financial impact on the transportation of cosmetic products or their raw materials, and should encourage cosmetics manufacturers to optimize the energy efficiency of their production sites.
In conclusion, cosmetics manufacturers need to improve their traceability processes, both in the supply chain and at product life-cycle level, by analyzing the fate of substances used to limit their appearance in wastewater and their environmental impact. On the other hand, they are also encouraged to communicate more transparently about their products, such as the origin of their raw materials or the details of their environmental claims.
It should be noted that cosmetics manufacturers are used to adapting to changing regulations on the use of chemical substances, and to finding more environmentally-friendly alternatives. However, with the Green Deal, regulatory changes are cross-cutting, and the EU is showing its willingness to change consumption patterns. So, although the implementation of the more global REACH changes has been postponed, it is in the interest of manufacturers to anticipate, and to sign up to an eco-design and carbon footprint reduction approach, if this is not already the case. With expertise in both strategy and innovation in the cosmetics and energy sectors, Alcimed’s teams help manufacturers investigate the solutions of the future. Don’t hesitate to contact us!
About the author,
Agathe, Consultant with Alcimed’s Cosmetics & Luxury team in France