In May, the European Commission presented potential simplifications to the Cosmetics Regulation and the CLP Regulation. The initiative, discussed during a stakeholder workshop hosted by DG GROW on 16 May, has sparked controversy—particularly among public health and environmental organisations.

Cosmetics: Fewer Restrictions for CMR Substances?

Currently, substances classified as carcinogenic, mutagenic or toxic to reproduction (CMR) can only be used in cosmetics under very strict conditions. However, the industry argues that CMR classification under CLP automatically triggers a ban—often before companies can apply for an exemption.

As more cosmetic ingredients receive CMR classifications, the Commission is exploring several simplification scenarios:

• Removing the requirement for a separate exposure scenario description

• Allowing use of CMRs only where classification is relevant to the specific exposure route

• Exempting natural substances containing only trace levels of CMRs and not chemically modified (e.g., tea tree oil)

📌 What Does This Mean in Practice?

For cosmetic manufacturers, the changes could reduce regulatory hurdles and increase flexibility—provided the Scientific Committee on Consumer Safety (SCCS) gives a positive opinion. But the proposals are facing criticism. Health NGOs such as HEAL warn that these “simplifications” could lead to unnecessary consumer exposure, especially since the rules apply to products like toothpaste and mouthwash.

CLP: Labelling Simplifications Under Discussion

The same workshop also addressed industry concerns over new labelling rules under the revised CLP Regulation—particularly upcoming font size and line spacing requirements set to apply from mid-2026.

While no formal proposals were presented, the Commission acknowledged the challenges reported by stakeholders:

• Packaging adaptation costs may reach €60 million per year for large companies

• Larger fonts may require larger labels or even packaging redesigns—especially in multilingual markets

What’s Next?

These proposals are expected to be included in the so-called "omnibus package" for the chemicals sector, scheduled for release in summer 2025. For companies in the cosmetics and chemical sectors, this will be a critical moment. Simplifications could ease compliance—but may also introduce new regulatory and reputational risks.