The European Union (EU) has published its Chemicals Strategy for Sustainability on 14 October 2020. The aim of the Strategy is to boost innovation for safe and sustainable chemicals and better protect citizens and the environment for the future. While CTPA welcomes strict requirements to ensure on-going chemical safety, we have some concerns that the Strategy proposals are not based on sound science.
The word ‘chemical’ should not cause alarm
As the Strategy says, chemicals are everywhere in our daily lives and they play a fundamental role in most of our activities. Therefore, we all want to know that makers of chemicals and products we use in our lives (including cosmetic products), the Government, law-makers and others are taking our health seriously and ensuring that we, and our environment, are not put at risk.
This is why the UK and EU already have one of the most comprehensive and protective regulatory frameworks for chemicals, supported by the most advanced knowledge base, globally. We can be confident in the safety of our cosmetics and personal care products thanks to the strict laws already in place governing chemicals and cosmetics.
Guided by science
While it is essential to maintain a robust, long-term process for managing the chemicals we use in everyday products, it is important that such a strategy is rooted in in-depth scientific knowledge and assesses the key risks to be addressed. We should be concerned if the basis for action is the political climate or hot topics raised by the media.
What does the Strategy mean?
In terms of the suggested approach to managing chemicals, the new EU Strategy proposes to ban chemicals based on their hazard properties rather than understanding how they are used in specific situations, and whether this use poses a risk.
Hazard and risk
The distinction between hazard and risk is essential. For example, caffeine in coffee has hazard properties because if it is consumed at high doses, it can cause harm. Similarly, the chemical acetic acid is very dangerous in its concentrated form, but perfectly safe when eaten in its much less concentrated form, which we know as vinegar. It wouldn’t make sense to ban caffeine or vinegar that we consume in daily life, based on the properties they might have in completely different situations. In the same way, it doesn’t make sense to ban chemicals, and the consumer products which contain them, based on their potentially dangerous properties under other conditions, which are completely different from how they are used in controlled and safe situations.
An approach based purely on hazard has the potential for chemicals and consumer products, which have important uses in our daily lives, to be unnecessarily lost.
The Strategy also intends to treat chemicals and products differently based on whether they are ‘essential’ for society or not. ‘Consumer products’ are not considered to be essential by the Strategy. This is extremely disappointing, as what is classed as essential is really personal. We all have things which we’re sure we just can’t live without, while of course others might disagree.
Cosmetic and personal care products play a huge variety of roles in our daily lives. Our shower gels remove daily grime and bacteria and deodorants keep us fresh, and sunscreen protects our skin from harmful UV rays. Toothpaste is vital for oral health, and some would suffer a constantly itchy and flaky scalp without anti-dandruff shampoo. Makeup can help us feel great on a night out or a big day at work, and it can even be an art form, showcased in global competitions. For people living with challenging skin conditions, camouflage makeup can have enormous psychological benefits.
If the basis on which chemicals are assessed for safety is changed from the strict requirements currently in place, we risk not being able to buy some of the cosmetic and personal care products we love and find essential to our daily hygiene routines, even though a strict process has already shown they are safe.
Wellbeing and self-esteem
Thinking about our self-esteem and wellbeing, a survey commissioned in 2017 by Cosmetics Europe, the European personal care association, found that 80% of us feel cosmetics and personal care products are important or very important in building up our self-esteem. 71% of us said that they are important or very important in our daily lives.
Amazing science, applied daily
Whole teams of scientists are involved in developing and bringing cosmetics and personal care products to market, because the laws governing cosmetic products and their ingredients are already so strict. Ingredients used in cosmetic products are regularly reviewed by a panel of independent expert scientists to ensure that they are safe, and every single cosmetic product must be safety assessed by a qualified safety assessor before being sold. The assessment takes into account how the chemicals are used, in which products, by whom, where on the body and how often they are applied.
The strict requirements for cosmetic products being placed on the UK market will not change after Brexit.