Getting ready for regulatory landscape under EGD
Navigating the ever-changing regulatory and policy frameworks can be a daunting task for businesses. However, with the right approach, companies can proactively prepare themselves to tackle these complexities head-on. In this article, we'll explore some proactive steps you can take to ensure your company is ready to adapt and thrive in an evolving regulatory environment, focusing on aspects of the European Green Deal (EGD).
Ingredient selection
Classifications & essentiality: To effectively manage chemical hazards, it's crucial to conduct a comprehensive assessment of your ingredient portfolio's hazard categories and implement hazard checks for new substances discussed at the R&D or innovation level. We recommend that you:
Evaluate existing classifications under the Classification, Labelling, and Packaging Regulation (CLP), including any self-classifications by suppliers, and stay informed about potential future impacts on CLP harmonized classifications.
Assess the essentiality of materials in products and consider their function.
Understand the Margin of Safety (MAF) related to ingredients in your formulas.
Consumer perception: Recognize that consumer perception varies and certain classifications may pose greater public relations risks. Involve a diverse group of internal stakeholders when establishing ingredient blacklists to prevent undue restrictions on innovation. Prioritize future sustainability when selecting alternative materials, avoiding unintended consequences observed in past industry shifts, such as the transition from parabens to Methylisothiazolinone (MIT) resulting in increased consumer sensitivity.
Claims
Audit your packaging and marketing communications and establish what green claims you are making. Be cautious of generic environmental claims such as ‘environmentally friendly’, ‘natural’, ‘biodegradable’ and ‘eco’ that could mislead consumers as to the environmental impact of your product and are likely to be targeted by regulatory authorities. In particular, avoid any claims that imply a positive impact on the environment as generally production of any kind is never good for the environment! Ensure that you hold robust substantiation for any green claims made that will hold up under regulatory scrutiny.
Packaging
To prepare for the Packaging and Packaging Waste Regulation, establish information on your full packaging portfolio including each product's packaging components, what material each component is made of and whether they are recyclable or made from recycled content. Find out from your packaging suppliers whether any components contain hazardous substances e.g. endocrine disruptors, SVHCs or heavy metals.
Assess whether your product range includes single-use hotel miniature packaging, particularly for hygiene and toiletry products. Be mindful of regulatory thresholds under the PPWR, such as volumes of less than 50 ml for liquid products or less than 100 g for non-liquid products and explore opportunities to minimise single-use packaging through innovative design or alternative packaging formats.
And that brings us to the end of our first ever article series! Many thanks for your engagement over the last 6 weeks and we look forward to bringing you more updates on the European Green Deal.
If you are interested in how Bloom Regulatory can support you with the transition, we offer various services that provide expert guidance and tailored consultancy on the European Green Deal, as well as audits to ensure readiness and empower your team with the knowledge and skills needed to navigate this new landscape. For more information, get in touch today!
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