CTPA launches manifesto to “secure the continued, sustainable growth” of the industry

The UK beauty and personal care industry trade body Cosmetics Toiletries and Perfumery Association (CTPA) is set to present its first-ever manifesto that will ask to work in partnership with the next UK government on a dedicated strategy to “secure the continued, sustainable growth” of the industry for the next five years.

The document contains 12 ‘key asks’ that the beauty and personal care industry has of the UK government, which is based around five main pillars: of Essentiality, Science, Regulation, Sustainability and Business.  

The CTPA said it has chosen to create and present a manifesto​ for the first time in 2024 due to the UK General Election taking place, which means it is set to be “a pivotal year” for industry.

CTPA director-general, Dr Emma Meredith, said that the manifesto is designed to “secure the continued sustainable growth of this essential sector,” and that it reflected CTPA’s critical workstreams “which cover the key issues that affect our industry.” 

The content itself was developed in collaboration with CTPA members to ensure it addressed their needs.

CTPA: 12 key ‘asks’ for the next government  ​

One of the first requests is that safety law the UK Cosmetics Regulation, is preserved, continues to be sector-specific and risk-based, and regulates the safe use of cosmetics ingredients and finished products.  

Meredith provided context and explained that between August and October last year, the OPSS (Office for Products Safety and Standards) – the UK regulator for cosmetics products – held a consultation called the Product Safety Review (PSR), which focussed on reshaping product safety legislation, including all sectors regulated under OPSS, to try and bring them into a common framework with cross-cutting requirements.

“The UK Cosmetics Regulation (UKCR) is included as one of the regulations that could be potentially removed in favour of this approach, she explained. “CTPA submitted robust responses to the consultation stating that the UKCR, and the high standards it demands, should be preserved and that CTPA does not support the inclusion of the UKCR within the proposed horizontal framework.” 

UK REACH regulation without ‘unnecessary burdens on business’​

Another of the key ‘asks’ is on the topic of UK REACH regulations.

Meredith shared that while CTPA strongly supported the need for a UK REACH system to protect the environment and human health, the industry would like to see a UK REACH that achieves these objectives while avoiding excessive costs, bureaucracy and unnecessary burdens on business, which could in turn lead to a reduced investment in the UK.

“Unfortunately, as there is currently no data sharing agreement between the UK and the EU, UK REACH requires companies placing chemicals on the UK market having to submit full data dossiers, which have already been submitted under EU REACH,” she explained.

“These data are owned by consortia, who are under no obligation to release their data for any purpose other than for EU REACH.  If companies wanting to place chemicals on the UK market cannot procure access to the data from the consortia, they will be forced either to stop using the chemicals in the UK or they will have to reproduce the data themselves at huge cost and resource.  This is disproportionate in terms of its costs and bureaucracy which could cause huge damage to UK businesses while having no additional benefit to human health or the environment,” she continued.

Meredith also explained that the CTPA has been working with Defra (Department for the Environment, Food and Rural Affairs), and other chemical industry representatives, over the past year on an alternative UK REACH model that removes some of these burdens. Therefore the manifesto includes an ask on UK REACH to ensure the positive engagement between industry and Defra continues, so “UK REACH maintains the availability of safe chemicals already on the UK market – thus sustaining the future of UK manufacturing – while ensuring future submissions for UK REACH are achievable for companies of all sizes in terms of cost and resource.”  

She added that “chemicals are the building blocks of not only life but also cosmetic products.”

A risk-based (not hazard-based) approach to chemicals legislation​

On the topic of chemicals, the CTPA manifesto has also asked that the next UK government does not move toward a hazard-based approach in terms of chemical regulation, and instead sticks with its current risk-based approach.

“CTPA has continuously supported the merits of the current risk-based regulatory framework that promotes robust safety principles and sound science,” Meredith explained.

“The UK cosmetics legislation, and the EU regulatory framework (which the UK has followed for over 40 years) are based on comprehensive risk-management tools.  Similarly, chemicals regulation should protect human health and the environment from harm whilst recognising and supporting the importance of chemicals for our everyday lives,” she continued.

“When considering product and/or chemical safety, policymakers must consider factors such as exposure to gain a better understanding of whether a chemical is safe in the way that it is used,” she said.

She also believed that the potential benefits of chemicals should be taken into account, as much as any potential concerns. “Basing regulation on intrinsic hazard properties runs the risk of removing safe and beneficial chemicals from the market,” she said and noted that ‘hazard’ and ‘risk’ are terms often incorrectly used interchangeably or in a way that could lead to misunderstanding of how they might be operating at a regulatory level.

Meredith also highlighted that the UK Cosmetics Regulation includes risk-management tools that “effectively ensure the specific hazards that cosmetic ingredients and products may have do not pose a risk to our safety in the way that these ingredients and products are used,” and that this “allows companies to examine the safety of cosmetic products in their correct context and to ensure that a safety decision is made based on robust exposure-led approaches, taking all these factors into account.”

All UK nations acting as ‘one’​

Following the devolution of Northern Ireland, Scotland and Wales, some powers that were previously held at Westminster are now devolved to each of the home nations and this includes some environmental laws. 

According to Meredith, the CTPA has seen several consultations from each of the devolved nations focussing on similar issues but with different proposals for possible action.

“If slightly different laws were to be introduced in Northern Ireland, Scotland and Wales that affect specific ingredients or products it would be completely unfeasible for a company to produce products specific to each devolved nation,” she said.  

“This is why the CTPA Manifesto is requesting that business regulation affecting the UK’s internal market is introduced at the same time and in the same way across the whole of the UK and that differences between the four home nations are avoided and minimised as far as is possible.”  

Removing barriers to global trade​

In the aftermath of Brexit, a focus on faster ratification of free trade agreements (FTA) has also made the list of requests.

“Free trade agreements have to be signed into law by Parliament to take effect, and this process can delay the real implementation of the provisions, explained Meredith.

“One of the more recent examples we have of this process is the UK-Australia free trade agreement, which took almost a year and a half to be signed into law after the negotiations had concluded,” Meredith continued.

“CTPA advocated for sector-specific provisions, and these have been included in the final agreement. Since then, CTPA has highlighted some technical challenges in achieving compliance with Australian regulations for UK companies which could impact our export capability. A perfect opportunity to use the FTA for the benefit of businesses,” she said.  

Participation in the EPR consultation process​

Sustainability will be increasingly integral to the cosmetics industry going forward, therefore the CTPA is also asking to be more involved in the Extended Producer Responsibility (EPR) scheme.

It had already been engaging with Defra on key aspects of EPR and contributed to the recent consultation on its implementation and is also part of the INCPEN (Industry Council for Packaging and the Environment) Working Group on Scheme Administrator, but feels that even more involvement is necessary.  

“It is important that producers are central to the operation and design of the scheme in order to achieve efficiency and deliver the desired environmental outcomes,” said Meredith.

“In addition, for the decision that are still outstanding, including EPR labelling requirements, it is important for the regulators to understand that companies need three years’ notice of the details to implement any changes.” 

Cosmetics can be “essential to people’s lives”​

Overall, the manifesto is seeking to demonstrate to the future UK government that the cosmetics, personal care and beauty sectors form an essential industry.

“The industry produces products that are critical to everyday life, including sun protection, oral care (including toothpaste), soap, antiperspirants and deodorants, shampoos and conditioners, hand washes and skin care as well as colour cosmetics, hair styling and grooming products for both women and men, said Meredith.  

She also highlighted research​ conducted in 2022 for the CTPA by Opinium[1]​ showed that 85% of UK adults class cosmetics and personal care products as essential to their lives; the figure is even higher among women, at 94%. 

“We look forward to working with the UK Government after the General Election on a strategy recognising the essentiality of the industry’s products and services by maintaining the strict risk-based safety legislation, protecting science-led decision-making whilst providing a framework for growth with sustainability at its core,” she concluded.

“The strategy should also enhance the competitiveness of the UK industry for both import and export and champion the UK industry as a leader in product manufacture, design and innovation.”

To find out more about the other key asks, read the full CTPA Manifesto​.

[1] Opinium polled 2,000 UK adults between 25 February and 1 March 2022.  See more information about this research in CTPA’s Annual Report 2021, ‘More Than a Feeling​’.