While the European Commission’s legislative proposal for the revision of Cosmetics Regulation 1223/2009 is expected in the first quarter of 2023, many questions regarding its practical implications are still pending. And according to Cosmetics Europe, the worst may come out of it, as an “acceptable” development for the industry. This is what John Chave, its General Manager, developed during the Perfumes & Cosmetics 2022 Congress.
The purpose of this presentation was not to make predictions about the consequences of the revision of the Cosmetics Regulation but rather to outline the prophecies of Gerald Renners, the Director of Technical Regulatory Affairs at Cosmetics Europe. And John Chave began with a point of vocabulary:
• A prediction is intended to give a precise vision of what will happen in the future, based on known data and information
• A prophecy describes the possible future if certain decisions are taken, and Cosmetics Europe’s prophecy was deliberately geared towards the “worst case”, where things would go wrong for the industry
Underlying this is the idea that a prophecy imposes a duty to act to prevent it from coming true and to influence the present to limit the less favourable eventualities.
For if today, “DG Grow seems receptive to the positions of the industry, there are many other interlocutors in the legislative process that will follow the revision of the Regulation who may be much less so, such as other Commission services, Member State governments or Members of the European Parliament, who take these issues very seriously and do not fully understand the complexities of our regulation and our industry,” …
