16 INTERVIEW Tim Probert – Editor, Personal Care Global
Editor Tim Probert talks to Olivia Santoni, chief executive and founder of London-based consultancy Bloom Regulatory. Olivia, originally from Paris, established Bloom Regulatory in 2019 to provide expert support to beauty and cosmetics companies worldwide
Tim Probert (TP): From a regulatory perspective, what is causing personal care ingredient suppliers to have sleepless nights at the moment? Olivia Santoni (OS): Ingredient suppliers have had to adapt to customer needs with changing trends. We are seeing ever more customers that want to go to green or clean, use botanical ingredients. Furthermore, many distributors have their own ‘ban list’ or a list of required clean ingredients. So, formulators have more
and more requirements in terms of which ingredients they can and cannot use. That’s not just the simple aspect of whether certain ingredients can be used to make efficacious cosmetics, or make green claims, it’s also about managing impurities. Some botanical ingredients
are highly seasonal and they can be sourced from Asia or South America. Supply can be switched depending on the season. So, more than ever, ingredient suppliers have to provide data and information to their customers on impurities.
TP: What other challenges are you seeing right now? OS: For smaller companies who want to go global, they need to make sure that their formulation is globally compliant. This is where it’s going to be quite difficult because there are a lot of ingredients used every day in Europe and in the US that are considered new elsewhere and therefore cannot enter easily, for example, into China. So, even if a supplier develops
a new ingredient that is very potent, or a breakthrough, the ability to sell it could be limited because customers may be focusing on the global market.
PERSONAL CARE February 2024
TP: How cosmetics regulation changing in terms of banned ingredients? OS: In the past, it used to be very simple: you knew something was banned and you could not use it. In the future in Europe, the European Commission is going to group substances to classify them under chemicals legislation. So, if one substance in one
family is seen as a bad apple, it’s going to ‘contaminate’ other substances that are closely related. I think that is going to cause a lot of problems to ingredient suppliers because that group suddenly may be not wanted either by their customers because it doesn’t look good for the consumer, or it simply may be banned. The European Commission is
reviewing the Cosmetic Products Regulation (CPR), and this will be mainly an issue for ingredient suppliers. In the future, we are expecting the CPR will be ever more in sync with the CLP (Classification, Labelling and Packaging) Regulation. As you will know, we
cannot put CMR (carcinogenic, mutagenic, or toxic for reproduction) substances in cosmetics unless there is a specific exemption. What the European Commission is going to look at in future is expanding that to other hazard categories. We are expecting that for endocrine disruptors; something that is classed as an endocrine disruptor will be automatically banned.
TP: When are we talking about that coming in? OS: Either this year or 2025. We are expecting the review of the CPR to see an automatic ban of endocrine disruptors. In the future, it could apply to respiratory sensitizers and other types of hazard category.
INTERVIEW
Regulation, regulation, regulation
I think it’s a big challenge
because, up until now, ingredient suppliers and the wider industry were looking at specific substances being banned. We are shifting from a substance-by-substance approach, which was very slow and time consuming to a group classification. This is the same as California. Now it’s more per group, so
we will have more difficulty. It’s no longer about one formulation with one substance, it may be that we are losing more than we were expecting. We already seeing it with regulations on microplastics and PFAS (per- and polyfluoroalkyl substances).
TP: Could silicones become part of this European regulatory change? OS: Not at the moment. For now they are focusing more on endocrine disruptor hazards, microplastics and PFAS.
TP: Is there anything else on the horizon in terms of cosmetics regulation in the EU? OS: Yes, as well as the CPR and CLP Regulation reviews, REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) will be reviewed as well. What is important to understand is that all of these reviews have been triggered by the Green Deal. The Green Deal is an EU political
initiative with 50 objectives. It’s not a law in itself, but to implement those objectives there needs to be a review of EU legislation across the board. For us, the most important are the Cosmetic Products Regulation, REACH and CLP. Another thing that is going
to impact the sector – maybe less for ingredient suppliers – is the European Packaging and Packaging Waste directive that will be changed into a regulation.
www.personalcaremagazine.com
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