INTERVIEW It could have a big impact because it will
go more into hazard substances that are in the packaging – that could enter the product - as well as more recycling requirements on top of plastic content. Outside of the Green Deal, we have a sort
of unseen mix between CLP, REACH and CPR because they want to harmonise the way things are regulated, instead of sector by sector.
TP: Where does the UK fit into this? Is the UK following what’s happening in Europe or will there be divergence? OS: We are seeing divergence with the EU. On cosmetics regulation, there is currently a consultation, not just for cosmetic ingredients but also product safety. Importantly for ingredient suppliers, we have
already received some different interpretations regarding hazardous substances due to the UK having its own scientific committee.
TP: What does this divergence mean for ingredient suppliers? OS: It means they will have to provide different data for the same hazardous substances. Sometimes this won’t be important; if the EU has the stricter regulations you just follow those rules. But sometimes it could be the other way round. We still think that if you follow the Europe
rules you should normally be OK but we see that the UK government wants to diverge a bit. Also, substances have to be registered with the UK authorities. If you don’t have this registration for the UK, you are unable to bring substances to the UK market. Many ingredient suppliers will have already been organised but this could be complicated for, say, some US suppliers who see the UK as part as Europe.
TP: Do you follow the developments in the US, such as MoCRA (Modernization of Cosmetics Regulation Act)? OS: In general, we leave America to the Americans but, from the perspective of a European consultancy working with European companies that do business in the US, MoCRA requires a few tweaks. There will be more regulation and companies
will have to register their products but, from what we can see, the additional work is not too onerous. Much of the MoCRA work, safety assessments and so on, has been in place under European regulations for many years. Putting aside the issue of registration, MoCRA is less of an issue for European companies than some other countries.
TP: Like China? OS: China is where the majority of our clients have been struggling due to the new CSAR (Cosmetic Supervision and Administration Regulation). This has totally changed the way China is monitoring cosmetics. It’s still in the implementation period and we’re still not exactly sure of all the requirements. There are some things that are very unclear. The CFDA (China Food and Drugs
Administration) requires a lot of testing for impurities, and there are a lot of new requirements
www.personalcaremagazine.com February 2024 PERSONAL CARE
“China is where the majority of our clients have been struggling due to the new CSAR (Cosmetic Supervision
and Administration Regulation)” Olivia Santoni, chief executive and founder of London-based consultancy Bloom Regulatory
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