NATRUE

NATRUE, together with other European with other European fragrance, cosmetics, and essential oils industry representatives, has cosigned a Questions & Answers (Q&A) Document addressing the European Commission’s Omnibus VI on Chemicals, which introduces targeted adjustments to the Cosmetic Products Regulation (CPR).

Science-based clarity for a workable and protective system
Omnibus VI reaffirms that consumer safety remains the cornerstone of the CPR, while introducing focused clarifications to ensure the Regulation is both operational and effective. The document, jointly prepared by European fragrance, cosmetics, and essential oils associations, provides answers to key questions on:

  • the scope and intent of the Omnibus proposal,
  • how the updated procedures address experiences with the Article 15 derogation process
  • the continued central role of the Scientific Committee on Consumer Safety (SCCS),
  • the reasons for urgent action rather than waiting for the full CPR revision,

Why these adjustments matter
For over a decade, the Article 15 derogation procedure (use of substances classified as CMR — Carcinogenic, Mutagenic or Reprotoxic) has proven unworkable, with no derogations ever granted – even when scientific evidence confirmed safe use. The Omnibus VI proposal provides a clear, enforceable, and science-based framework that balances precaution with practical implementation.

The changes clarify how hazard-based classifications should be interpreted in the context of exposure scenarios associated with actual cosmetic use, ensuring that decisions reflect realistic use conditions. This makes the system more consistent, predictable, and aligned with public health protection.

Safeguarding the use of natural ingredients
Of particular importance to natural cosmetics, Omnibus VI is particularly important to safeguarding Natural Complex Substances (NCS), such as essential oils and other botanical extracts. Under the existing rules, the regulatory approach for these natural ingredients creates severe legal uncertainty, which could severely affect the use of natural ingredients despite extensive evidence of safe use at cosmetic level.

This uncertainty particularly impacts ingredients where a constituent has been classified as a CMR, even if present at low or very low or very low concentrations and without actual risk under cosmetic use.

The Omnibus provides:

  • A clearer route for NCS constituents under the CPR (via Article 31).
  • A reaffirmation that the safety of the constituent must be evaluated case-by-case by the SCCS.
  • Recognition of the impracticality of substituting a constituent within a range of natural complex substances.

Read the full document here.

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