Cosmetics Europe’s John Chave on ‘Chemophobia’ and the State of EU Cosmetics Regulation

Critical negotiations lie ahead on the EU’s planned revision of the Cosmetic Products Regulation. Cosmetics Europe Director-General John Chave outlines the stakes, the unresolved tensions around hazard vs. risk-based approaches, and what global brands should be watching as the process enters a decisive phase.

The future of the EU’s Cosmetics Products Regulation (CPR) – and the competitiveness of Europe’s beauty and personal-care sector – is entering a pivotal phase. Brussels is reevaluating the CPR and, in parallel, exploring the regulation’s simplification via the Chemicals Omnibus. The outcome will shape not only the EU market but also regulatory expectations in the United States, where state-level policy often follows Europe’s lead.

John Chave, Director-General of Cosmetics Europe, says he’s encouraged by the shift in tone coming from the European Commission under President Ursula von der Leyen’s second term, which began in December 2024.

“I’d like to think that some of the – how shall I say – pro-competitive, pro-industrial spirit that is so alive and well in the U.S. is coming, in its own way, to the European Union,” Chave told IBA.

It marks a notable shift after several years in which the CPR revision appeared destined to embed the most precautionary elements of the European Green Deal’s Chemicals Strategy for Sustainability (CSS).

Rather than an overhaul rooted in hazard avoidance, the EU now is undertaking a more measured assessment of the existing CPR. Crucially, the Chemicals Omnibus introduces the possibility of a changed approach to automatic ingredient bans under the CPR based on hazard classifications, a growing issue in recent years that poses an existential threat to the cosmetics and personal care industry.

At the same time, Member States are resisting many of the key aspects of the proposed changes, setting the stage for vigorous debates in the coming months. 

What follows is a look at how the CPR revision reached this inflection point and what brands on both sides of the Atlantic should expect next.

October 2021: The ‘Generic Approach’ Takes Center Stage

In its 2021 Inception Impact Assessment, the European Commission announced plans to revise the CPR, the Classification, Labeling and Packaging (CLP) Regulation, and REACH to align with the CSS and broader Green Deal. Central to that agenda was the generic approach to risk management (GRA), i.e., automatic restrictions or bans based solely on the hazardous properties of a substance and broad exposure assumptions.

Described in the CSS as “an automatic trigger of pre-determined risk management measures,” the GRA in practice means default restrictions on substances linked to cancer, genetic mutations, reproductive or endocrine disruption, or environmental persistence, with case-specific, exposure-based risk assessments largely sidelined.

Endocrine-disrupting chemicals, in particular, were singled out as requiring specific GRA attention. Under the CSS, such substances of concern were to be minimized and ultimately phased out unless deemed “essential,” though the essentiality criteria themselves remained undefined.

Despite a stated commitment to present a revised CPR in 2022, the Commission’s proposal never materialized, and momentum stalled.

July 2025: A Change of Course and the Rise of Omnibus VI

Following the June 2024 European Parliament elections, the Commission adopted a lighter-touch approach, launching a 2025 call for evidence to evaluate whether the CPR remains effective and fit for purpose.

In parallel, the Commission introduced Omnibus VI, a chemicals simplification package intended to reduce administrative burden by at least 25% for all businesses – and 35% for SMEs – while preserving high levels of protection. The package acknowledges the chemical sector’s strategic importance and the regulatory obstacles weighing on investment, with more than 60% of EU companies citing overregulation as a barrier.

For cosmetics, Omnibus VI proposes several targeted refinements:

• Extending submission deadlines and clarifying the periods for defending a CMR derogation and, if necessary, removing products from the market;
• Removing the requirement that Category 1A/1B CMR substances meet food-safety requirements, noting that food and cosmetics are fundamentally distinct exposure routes;
• Clarifying procedures for adding colorants, preservatives, and UV filters to Annexes IV–VI to speed up ingredient availability; and
• Eliminating redundant nanomaterial reporting requirements.

In September 2025, the Council approved a related “stop-the-clock” mechanism delaying application of several new CLP obligations to January 1, 2028, giving industry additional time to adapt. This measure was explicitly presented as part of Omnibus VI and framed as necessary to provide legal certainty. While of more direct relevance to suppliers than manufacturers, this measure is indicative of more flexibility at the Commission level.

Industry Relief and the Ethanol Flashpoint

Industry welcomed the Commission’s streamlining proposals. “The existing interaction between the hazard-based CLP and risk-based CPR is a continuous challenge,” Cosmetics Europe said. “CLP classification can result in automatic bans of substances that are completely safe for use in cosmetics.”

Chave provided additional perspective: “It’s very, very difficult to get the derogations to stick. It was just about manageable when you didn’t have many substances. What’s happened now is there’s been a huge increase in the number of substances coming along the [CMR] pipeline.”

He points to ethanol as the emblematic case. Greek authorities have proposed classifying ethanol as a Category 2 reproductive toxicant under the CLP, which the Biocides Products Committee is expected to turn into Category 1, which would trigger its automatic ban in cosmetics absent a successful derogation.

“No one seriously thinks that ethanol is unsafe when used in cosmetics,” Chave said. “But because of short deadlines and the inflexibility of the derogations in the CPR, we could be faced with the nightmare scenario of removing safe ingredients and safe products from the market simply because we didn’t have the opportunity to demonstrate their safety. That cannot be consistent with the EU’s ambition to relieve the regulatory burden.”

He recalled being dismissed years earlier when he warned industry stakeholders that such an outcome was possible.

“I said imagine coming to Paris for a romantic dinner and having a glass of wine, but you can’t spice up the evening by spraying on bit of perfume because the perfume has not been formulated, because ethanol had been banned. They said, ‘You’re being ridiculous, that’s typical industry exaggeration – ethanol will never be banned.’ A few years later, the process has begun.”

Chave says it’s difficult to account for  the surge in hazard-based classifications, but it’s clear there is complacency about their knock-on effects, encapsulated in two attitudes:

1. That cosmetics are seen as not “essential,” so their regulation matters less; and
2. That industry will not innovate unless regulation forces it to.

Both views, he argues, are misguided. “One of the problems of banning ingredients that are safe is that you divert investment in genuine innovation into reformulation,” he said. “Innovation is driven by companies striving to make the best products possible. The idea that we wouldn’t innovate without regulation is just wrong.”

New Territory: Environmental Hazard Classes

As the CPR Evaluation unfolds, the cosmetics sector also expects increased pressure from the CLP’s new environmental hazard classes. Since April 2023, the CLP includes:

• Endocrine disruptors (human health and environmental);
• Persistent, bioaccumulative and toxic (PBT);
• Very persistent and very bioaccumulative (vPvB);
• Persistent, mobile and toxic (PMT); and
• Very persistent and very mobile (vPvM).

Chave says industry is particularly concerned about environmental persistence classifications. The sector’s traditional model focuses on human-health toxicology and conservatively assessing safe exposure levels. But for persistent substances – as shown in the EU microplastics restriction adopted in September 2023 – authorities may consider no safe level acceptable because of long-term accumulation.

“For environmental hazard classes, we’re in new territory,” Chave said. “This is potentially going to be very impactful going forward.”

UV filters, preservatives, and colorants may be particularly vulnerable. “We don’t have a great deal of UV filters to use anyway,” he noted. “The public-health case for UV protection is very clear, and, to an extent, UV filters are designed to be persistent in order to withstand the damaging force of UV radiation. Certain categories of our ingredients are exposed from the environmental perspective.”

Member State Pushback: The Council’s More Protective Stance

On November 5, 2025, the Council of the European Union adopted its negotiating mandate on Omnibus VI. While the package streamlines several CLP labelling and formatting requirements, the Council took a more protective stance than the Commission on cosmetics-specific elements.

Notably:

• It deleted the Commission’s proposal to exempt CMR substances based on oral or inhalation route of exposure (which still would require an SCCS opinion where such exposure routes may be relevant);
• It shortened transition periods for phasing out CMR substances in cosmetics compared with the Commission’s proposal (though they still would be longer than under the current CPR); and
• It reinstated the requirement that companies notify the Commission six months prior to placing nanomaterial-containing cosmetic products on the market.

Industry groups, including Cosmetics Europe, the International Fragrance Association (IFRA), and the European Federation for Cosmetic Ingredients (EFfCI) responded quickly and forcefully.

“The Council’s position reinstates unnecessary red tape,” Chave said in a November 6 statement. “There is a lack of coherence between the EU’s ambitions to increase competitiveness and the Council’s hesitance to support effective simplification. We regret this lost opportunity to better ensure safe ingredients and products stay on the market.”

The Road Ahead – Buckle Up

The months ahead will be turbulent. As John Chave notes, even modest pro-industry improvements are already meeting resistance within the EU’s “sausage machine.” Member states remain highly cautious, and this conservatism is colliding with the Commission’s attempt to restore balance between scientific risk-assessment principles and political pressure.

“Chemophobia is a real thing in the European Union, across a wide swathe of the member states and a wide swathe of NGOs. I don’t think it’s truly consumers, but it’s become sort of the conventional wisdom in the European Union that chemicals are dangerous and therefore banning them is good and it’s as simple as that. And that hasn’t gone away and won’t go away just because the European Commission has finally woken up to the fact that Europe needs to have an industrial policy and be more competitive.”

Chave expects significant discussions ahead in Brussels and a CPR proposal from the Commission in the first quarter of 2026.

In Chave’s estimation, the so-called “Brussels Effect” has weakened after years of increasingly radical and disproportionate measures. “Jurisdictions around the world are a little bit more circumspect about assuming the EU has always gotten it right,” he said.

Yet the influence remains. From animal-testing bans to microplastic restrictions to fragrance-allergen disclosure, the U.S. has a long tradition of importing EU policy concepts. What begins as a technical debate in Europe about CMR classification, endocrine-disruptor criteria, or digital labeling possibilities can quickly become a frontline issue for U.S. brands.

Companies that stay ahead will be those that track the EU closely, understand the science-policy dynamics, and anticipate how today’s European debates can become tomorrow’s compliance realities – even for brands that don’t sell a single product in the EU.