Impact assessment on fragrance allergens labelling has been published by the European Commission.
The Impact Assessment study on fragrance labelling on cosmetic products (575/PP/2016/FC) has been commissioned by the European Commission in 2019 with the objective to address the SCCS Opinion from 2012, which recommended consumers to be informed about 62 additional fragrance allergens in addition to the 26 allergens already labelled.
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.
POLICY OPTION ALTERNATIVES FOR FURTHER ASSESSMENT :
The European Commission has identified the following policy option alternatives for further assessment within the context of the study:
- Option 1. No changes to the current rules (on-pack labelling of 26 fragrance allergens);
- Option 2. On-pack labelling of current and new allergens (in total up to 88 allergens);
- Option 3. On-pack labelling of current 26 allergens and e-labelling of 62 new allergens, which could be either e-labelled with a website address, a QR code or barcode.
The objective of the study is to assess above labelling options and provide an informative and appropriate labelling solution whilst ensuring consumer safety, product information transparency in Europe and maintaining the competitiveness of the relevant industrial sectors.
Consequently, the study has involved a wide-ranging consultation process including: telephone interviews with consumers, public consultation for all stakeholders and citizens in Europe, and round-table meeting with stakeholders.
STUDY FINDINGS AND RECOMMENDATIONS :
Based on an analysis of relevant literature and extensive stakeholder consultation, the European Commission recommended that :
- Additional fragrance allergens should be labelled without undue delay.
- Consultations should be held with stakeholders on legibility criteria for labels and on the possibility of e-labelling in cases where these criteria cannot be met without increasing the size of the package.
- Flexibility should be ensured as to the form of providing information for consumers with no internet access. If the option of print-outs with labelling information is chosen, it is recommended that environmental footprint is minimised.
- If e-labelling is introduced, access via a website address is recommended, with QR or bar codes as possible additional ways of accessing information. Ensuring technological neutrality is recommended and minimum technical requirements to ensure easy access should be set. Consumers should be made aware that the information is available off-pack.
- Sufficiently long transitional periods to minimise impact on SMEs and environmental costs of withdrawal of packages
IFRA expressed its support for the use of e-labelling. Consultations with Cosmetics Europe will be stepped up. According IFRA, a regulatory framework is not expected before 2022.
In order to consult the results of the public consultation, please find the following link :