From an industry perspective, longer transition periods can reduce the risk of sudden product withdrawals, especially for smaller manufacturers managing reformulation and supply chain change. However, critics argue the same flexibility could translate into extended consumer exposure after risks are formally recognised.
HEAL pointed to the scale of routine exposure, citing figures from a related briefing that women use an average of 16 cosmetic products daily, pregnant women 18, and children under three around six. The briefing warns that extended transition periods, combined with restrictive definitions of “suitable alternatives”, could leave carcinogenic, mutagenic and reprotoxic (CMR) substances on the market for years after classification is initiated.
Scope and Exemptions Are Also Under Scrutiny
Beyond timelines, HEAL argued the draft report would narrow restrictions to certain products even where exposure routes such as inhalation or ingestion may be relevant, for example in powders or creams and particularly for children.
The proposal also raises questions about exemptions. HEAL highlighted concerns about broad carve-outs for carcinogens present as constituents of plant-based complex substances, such as essential oils, warning that “natural” origin does not remove hazard.
Compliance Implications for Brands and Suppliers
If Parliament moves towards longer transition periods, cosmetics firms may need to manage a more complex compliance picture, balancing extended sell-through windows with consumer expectations and reputational risk. Ingredient monitoring and supplier assurance processes become more consequential when classification triggers, derogations and product-scope rules may change.
Summary
The cosmetics elements of the Chemicals Omnibus debate are becoming a focal point for how the EU weighs administrative simplification against health protection. For manufacturers and retailers, the outcome will influence reformulation planning, ingredient governance and the pace at which products must align with new hazard classifications.
