Laurence Mulon
Premium Beauty News - First of all, what is Reach?
Laurence Mulon - REACH, stands for Registration Evaluation Authorization, of Chemicals. The regulation came into force on 1 June 2007 with the aim to assess the risk of chemicals with regard to human health and the environment. Its scope covers all chemicals placed on the European market in quantities exceeding one 1000kg per year.
REACH stands on a basic principle: “No Data, No Market”.
Furthermore, REACH also includes compulsory data sharing provisions within the frame of the evaluation procedure, with the aim to reduce tests performed on vertebrates.
Premium Beauty News - What is the outline of the registration procedure?
Laurence Mulon - Registration became compulsory on June 1, 2007. However, the substances that were already sold in Europe and were duly pre-registered before this date benefit from extended registration deadlines. The deadline depends on the tonnage band and the hazardous properties of the substance. The staggered deadlines are: 30 November 2010, 31 May 2013 or 31 May 2018
Registration is costly and it is likely that some substances that suppliers will deem unprofitable as such will be withdrawn from the market. Another consequence should be the increased cost of registered substances.
Premium Beauty News - How can REACH be accommodated with the other regulatory requirements already applicable to cosmetics?
Laurence Mulon - The legislation governing cosmetic products in Europe is constantly evolving. Tests on animals have been banned for both finished products and the ingredients (within a detailed schedule), the labelling of fragrance allergens is now compulsory and the use of substances classified as CMR 1 and 2 has been prohibited, such as the use of some glycol ethers.
As far as cosmetic ingredients are concerned, REACH adds another regulatory layer to the rules applicable to cosmetics.
However, the two sets of regulations may be divergent and sometimes contradictory, in particular regarding the toxicological evaluation of substances used as cosmetic ingredients. with testing on animals is allowed contrary to the directive. While tests on animals are forbidden by the regulations applicable to cosmetics products, there are compulsory under REACH. The European Commission subsequently had to clarify this point ad has indicated that the toxicologic evaluation could be performed using animals for any use but cosmetic.
Premium Beauty News - In such circumstances how is it possible to combine regulatory compliance and innovation?
Laurence Mulon - There are plenty sources of inspiration and innovation available to cosmetics and perfumes manufacturers, whether they choose to use determined chemicals or natural substances. The first ones are covered by REACH but for the latter ones the situation is more difficult. Indeed, REACH is not the best tool for natural substances as it is not adapted to the specificity and complexity of botanicals.
That is the reason why concerned trade bodies have issued a common position regarding the use of natural substances. They submitted this position to the European Commission on November 2007 and to ECHA at the end of 2008.
Premium Beauty News - In your opinion, what is the best way to behave under REACH ?
Laurence Mulon - I have the conviction that the constraints that REACH imposes should stimulate the emergence of innovations.
The sourcing of new raw materials being simultaneously environment-friendly and ethical and « natural », may be a solution.
Another way is to innovate through greener manufacturing processes and through the development of new formulations.
Eventually, organisational innovations are also required, based on the concepts of substance (instead of raw material) and of sustainable development at every step of the supply chain.
Premium Beauty News - What about innovation in the future?
Laurence Mulon - In the past, the beauty industry and beauty products have already been submitted to this kind of innovation-stimulating regulatory constraints. In the future, regulatory requirements should continue to complexify themselves. NGO should also increase their pressure through the media. These new requirements are becoming strategic trigger to innovation.
