As Gerald Renner reminded us in the preamble to his presentation, we’ve been playing the scare tactics with the possible implications of the CSS (European Strategy for Sustainability in the Chemicals Sector) for the foundations of the Cosmetics Regulation. The scarecrows of the GRA (Generic Risk Assessment), increased safety margins, a rather vague system for banning substances based on danger except in the case of essential use, the crushing of all regulations by a blind and overpowering CLP, the possible absorption of the SCCS into the meanders of ECHA, etc. have all been waved around.

A new political context

And then the European elections reshuffled the deck somewhat, leading some to believe that the Green Deal and its CSS were dead and buried, with the revision of the REACH and Cosmetics Regulations, in favour of a policy more in favour of industrial development than green campaigns… But beware, warned Gerald Renner: unless there is a shift in intentions, all the concepts and principles developed and discussed over the last four years will not simply disappear.
Because the CSS remains the pillar anchored in many fitness checks of European texts, assessments and consultations. Because the CLP Regulation has been revised, …