As every year, at the end of the Cosmetic Valley Perfumes & Cosmetics Congress held in Chartres on November 6 and 7, 2019, the entire FEBEA team answered the questions prepared by the delegates during the two days of the conference. A session punctuated by numerous questions about claims (“Free-from…” and “With…”, in particular) and the subtleties of the labelling, and also some questions on the ISO 16128 standard on natural and organic cosmetics.
They answered questions from delegates on November 7, 2019:
• Anne Dux, Director of Scientific and Regulatory Affairs, in charge of European relations
• Hélène Orliac, Director of Economic, Environmental and International Affairs
• Xavier Gueant, Director of Legal Affairs
• Laure Menanteau, Scientific and Regulatory Advisor
• Catherine Bramaud, Scientific and Regulatory Advisor
• Françoise Audebert, Scientific and Regulatory Advisor
• Claire Ducatillon, Head of Mutualised Audits Department - CVL Quality Assurance Manager
• Carlota Vicente, Environmental Affairs Officer
Allegations
Question Opposability of the Technical Document
The ARPP Recommendation and the Technical Document on Claims are not legally binding according to the ANSM and the DGCCRF. However, during the inspections, these two texts are systematically cited. What to do?
Xavier Gueant’s answer
The crux of this question is the term “legally binding”. The DGCCRF explained that it based its controls on the Consumer Code, which includes the Unfair Commercial Practices Directive (2005/29), which refers to the rules of professional diligence in assessing consumer deception and behaviour that could affect consumer judgment. It therefore seems to me that the DGCCRF is consistent with its approach, citing the ARPP Recommendation as part of the rules of professional diligence.
Question “Fragrance-free”
If …
