Cross-industry associations urge EC to boost transparency via e-labeling requirements

03 Apr 2023 --- An alliance of 16 organizations representing consumer-facing economic operators, such as The International Natural and Organic Cosmetics Association (NATRUE), the European Cosmetics Responsible Person Association (ERPA) and The French Cosmetics Association for SMEs (COSMED), is urging the European Commission (EC) for digital solutions for product information.

In the joint letter, the undersigned associations invited the EC to explore a general coordinated approach to e-labeling to avoid market fragmentation, address the challenges and opportunities for consumers and economic operators, including innovating solutions that are easy, cost-effective and practical to implement.

The associations believe e-labeling can help to expand a consumer’s awareness and further promote transparency about the product, its ingredients and its packaging.

“Digital solutions for labeling and product information at EU level can indeed help to reduce packaging waste, offer the possibility to provide more detailed and tailored information to consumers and decrease production costs and incentivize innovation,” the letter reads.

“We encourage the EC to explore, together with stakeholders, a coherent and systematic way forward to allow digital labeling solutions in EU legislation across all product sectors.”

Associations invited the EC to explore e-labeling to avoid market fragmentation.Digitalization of on-pack information
NATRUE presented a consumer survey last July investigating digital labeling of natural and organic cosmetic products that found that 37% of French shoppers would prefer to have the information on-pack but with additional information available online or in an app (57%).

In the letter, the associations detail that as consumers are increasingly adept at using digital tools, there is an opportunity to discuss the dematerialization of relevant mandatory information. They ascertain an integrated system like the Digital Product Passport could be explored for relevant compulsory details.

However, the alliance clarifies that the EC must involve all the relevant stakeholders throughout the supply and value chain regarding the responsibilities of each business operator to ensure legal certainty and avoid duplication.

Standardization across EU
According to the associations, the Digital Product Passport should be developed in a “harmonized way,” allowing the integration of different information into a single data carrier.

“Digital product information can raise challenges for consumers and business operators alike, which should be discussed with all parties involved,” the associations write.

“It is essential to maintain the roles and responsibilities of all business operators concerned – from manufacturing to the point of sale – to ensure proper and well-functioning digital solutions for labeling. There must be clarity throughout the supply and value chain regarding the responsibilities of each business operator to ensure legal certainty and avoid duplication.”

Associations check EC regulations
Recently, a coalition of European industry representatives – not limited to personal care and cosmetics – warned that online sellers might escape the EU’s new product sustainability and health requirements using e-market loopholes. The letter called for stricter regulations targeting online cosmetics sales and any other products covered by the Eco-design for Sustainable Product Regulation.

“If Europe is serious about its commitment to making sustainable products the norm, it must catch up with the reality that many major players in e-commerce depend on a business model based on avoiding legislation to sell cheap and unsustainable products to European consumers,” stressed Jean-Pierre Schweitzer, Deputy Policy Manager for Circular Economy at the European Environmental Bureau (EEB).

Moreover, the EEB also revealed last month that it expects the EC to present the Green Claims Directive to regulate how companies meet and communicate their green claims. It is dubbed a much-awaited law that seeks to crack down on greenwashing.

Edited by Radhika Sikaria