The European Commission Inception Impact Assessment on Labelling Fragrance Ingredients aims at inviting citizens and stakeholders to provide feedback by the 11th February 2020 and participate effectively in future consultation activities.
Background and issues
Essentially, the Commission asks for feedback on its proposed initiative to label 62 additional fragrance allergens in cosmetic products. Currently, there are 25 allergens that need to appear on the label if present in the cosmetic product in a certain percentage The proposal aims at addressing the SCCS Opinion from 2012, which recommended consumers be informed about additional fragrance allergens. Not doing so can potentially cause harm to human health and deprive consumers of their right to information.
There are several issues related to the labelling of such large number of additional allergens. The manufacturers may have difficulties adding more allergens to their list of ingredients due to size constraints. Leaflets or bigger packaging in turn will incur additional costs for the industry and may have a negative environmental impact. If instead the list of ingredients is printed with smaller font, this will create reading difficulties for the consumer. E-labelling could be an answer, however making sure that all consumers read the online label is still a challenge.
The Commission has provided three possible solutions:
- No changes to the current rules;
- Requiring current and new allergens (87 in total) to be added to the physical label;
- Requiring current allergens to be added on the physical label and new ones to be e-labelled, either through a website address, QR code or barcode.
Feedback from the industry and consumers can be consulted here. A decision is expected to be adopted in the fourth quarter of 2021.
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