COSMED

COSMED – Les Ocres de l’Arbois – Bâtiment B - 495 rue René Descartes – 13100 AIX EN PROVENCE – Tél. 04 42 22 30 40 - Fax : 04 42 22 36 06 Association Loi 1901 – SIRET 434 068 441 00048– TVA FR 26 434 068 441 – [email protected] – www.cosmed.fr COSMED INPUT on the proposal for a regulation on packaging and packaging waste First of all, COSMED support this proposal for a regulation on packaging and packaging waste to harmonize rules in European Union and to move towards a more circular economy. Cosmetic SMEs are strongly committed to reduce packaging and packaging waste and share the ambition of the circular economy action plan.

…strongly committed to reduce packaging and packaging waste and share the ambition of the circular economy action plan. However, COSMED highlight that obstacles prevent the achievement of some objectives and stress that consideration on feasibility, operational reality, maturity of the market and technologies, and impact shall be taken into account to adapt some targets especially considering SMEs situation.  Regarding recycling ambition The proposal set that from 1 January 2030, all packaging comply with design for recycling criteria, prohibiting performance grade E. Calculation rules would be harmonized in a second step by a delegated act, but we already want to stress that this target remains very challenging in the timeline defined.

…by a delegated act, but we already want to stress that this target remains very challenging in the timeline defined. More time is given for “innovative packaging” but better clarification on related definition of what may be considered as a “new material”, “new production process”, or “significant improvement in the functions of packaging” would be needed.  Regarding recycled content targets COSMED alerts that there is no sufficient quality and quantity of recycled materials available to achieve the objectives in the timeframe defined for the different sectors. Especially for cosmetic sector subject to strict safety and traceability requirements regarding packaging material content and limiting even more the sources opportunities. Indeed, cosmetic industries need to source specific food contact quality materials for their packaging.

…opportunities. Indeed, cosmetic industries need to source specific food contact quality materials for their packaging. Overall shortage, increase of costs and market disruption can already be expected and this will impact SMEs even more. Feasible targets and realistic deadlines must be defined, according to the maturity of recycled market to avoid any market fragmentation. Such targets should not jeopardize safety and traceability to fulfill cosmetic requirements. In addition, we highlight the need to explicitly recognize chemical and enzymatic recycling as complementary means of achieving the overall targets.  Regarding harmonization of sorting information COSMED strongly supports the harmonization of EU rules to ensure right consumer sorting of packaging. Several unharmonized measure have been implemented in some Member States. Some requiring the labelling on pack.

Several unharmonized measure have been implemented in some Member States. Some requiring the labelling on pack. We stress that: Ref. Ares(2023)2836985 - 21/04/2023 COSMED – Les Ocres de l’Arbois – Bâtiment B - 495 rue René Descartes – 13100 AIX EN PROVENCE – Tél. 04 42 22 30 40 - Fax : 04 42 22 36 06 Association Loi 1901 – SIRET 434 068 441 00048– TVA FR 26 434 068 441 – [email protected] – www.cosmed.fr - alignment is essential to ensure a common market and free circulation of goods - dematerialization of sorting information should be given as an option, which would support the necessary translations and would be in line with the overall ambition to reduce the size of packaging. - Timeframe of 42 months is realistic for placing on the market products meeting new requirements, provided that products already placed on the market can be disposed of without delay.

…meeting new requirements, provided that products already placed on the market can be disposed of without delay. In addition, we are concerned with the way the mandatory requirement has been set, indeed labelling the material composition would not give relevant information to the consumer at sorting time when he needs to decide in which waste bin he should put its packaging. So, in the end counterproductive towards the sorting objective as without proper consumer sorting recycling cannot happen. Existing national requirements may be considered and sorting information pictograms already in place in France, introduced by AGEC lawi may serve as an example of a practical and relevant information to ensure proper consumer sorting gesture.  To define feasible, harmonized and coherent objectives in EU On a general matter, we support harmonized targets across EU.

…define feasible, harmonized and coherent objectives in EU On a general matter, we support harmonized targets across EU. Some Member states have already implemented national goals, that may be stricter than those defined in the EU draft regulation, and for some, already anticipated as unachievable. To avoid any competitive distortion, harmonization is required with realistic ambition considering all sectorial constraints and specificities.  Regarding recycling targets of packaging waste We express concerned on the targets defined for paper and carboard which are unrealistic respectively by 2030 and 2040. Achieving the objectives would imply increasing the thickness of the material which would be contrary to the initial goal of the circular economy and in the end counterproductive.

…of the material which would be contrary to the initial goal of the circular economy and in the end counterproductive. Thus, COSMED stress that Cosmetic SMEs remain engaged to move towards a more circular economy but alert on the main obstacles in the achievement and feasibility of the proposed objectives: -Overall harmonized measures towards EU members states to avoid competitive distortion and ensure EU free circulation of goods - Accessibility of recycled material considering cosmetic requirements in terms of quality, safety and traceability of packaging (material with food contact quality) - Increased costs, amplified by expected supply tension. Consideration that SMEs will be the most impacted by supply tension and increased costs, specific support should be provided to SMEs. - Incorporation of recycled content, reuse, refill should not be made by jeopardizing consumer safety.

…to SMEs. - Incorporation of recycled content, reuse, refill should not be made by jeopardizing consumer safety. Targets defined must remain compatible with high standards of hygiene, traceability and safety required for cosmetics. We ask for the possibility to review targets and timeline, especially considering those already defined in article 7 considering the above-mentioned elements. COSMED – Les Ocres de l’Arbois – Bâtiment B - 495 rue René Descartes – 13100 AIX EN PROVENCE – Tél. 04 42 22 30 40 - Fax : 04 42 22 36 06 Association Loi 1901 – SIRET 434 068 441 00048– TVA FR 26 434 068 441 – [email protected] – www.cosmed.fr About COSMED COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 1000 members, in France and Europe. Cosmed sit at the European Commission as the voice of cosmetic SMEs.

…with more than 1000 members, in France and Europe. Cosmed sit at the European Commission as the voice of cosmetic SMEs. COSMED is involved in the development of cosmetic regulations, as well as in national and international standardisation bodies. In this way, COSMED contributes to the development of a regulatory framework for the marketing of safe and effective cosmetic products. Aix en Provence, 21 April 2023 i Loi n°2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et l’économie circulaire.

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