The impact of REACH on cosmetic manufacturers
Cosmetic product manufacturers are defined in the REACH system mainly as “downstream users” because they use substances and preparations to formulate their products.In addition, many cosmetics manufacturers are “importers” because they bring substances and preparations into Europe from outside the EU.
Obligations under the REACH system are determined by the company’s role (downstream user, importer, or even manufacturer) with regard to the individual ingredients.
The cosmetics industry and individual Member States have carried out studies into the impact of REACH. These cannot predict the precise effect on costs, the availability of substances, personnel and jobs but they do provide useful insights.
Non-availability of certain ingredients for cosmetics products is likely to be the highest impact on the cosmetics industry. Suppliers might decide to discontinue some chemicals if they consider the costs of registration to be too high.
Suppliers are expected to pass on the costs associated with REACH to users. The number of suppliers is likely reduce, and reclassification, or even bans on some substances, will result in product reformulations.