Colipa - Confidence tricks

Consumer confidence is more important than ever in light of sluggish markets and the onset of potentially disruptive legislation, says Colipa. That’s why the European trade association took it as the theme of its Annual Congress held in Cascais, Portugal (31 May - 2 June)

Times were tough for the C&T industry in 2005, a fact underlined by the figures collated by Colipa and presented at its Annual Congress. Beautiful sunshine provided an incongruous backdrop to the rather gloomy news coming from the Western European markets. The developed markets naturally found growth hard to come by, underlined by the fortunes of the leading markets of France, Germany, Italy, Spain and the UK, which between them account for just under 77% of sales. Worst hit was France, whose sales fell a disappointing 1.2% to €10.1bn. Italy’s market was static on €8.49bn, the usually reliably buoyant UK market slowed dramatically to €9.28bn, representing growth of just 1%. Even Spain’s market showed signs of wear and tear, putting on a relatively cautious 4.8% to €7.1bn. On a more optimistic note, Germany returned to growth, albeit modestly, rising 0.2% to €11.1bn.

Better news came from the smaller markets, but again results were mixed. The most dynamic market was to be found in Finland, whose sales grew 6.8% to €0.72bn. Denmark also reported good growth, putting on 6.6% to €0.93bn. Ireland turned in growth of 4.8% but remained the smallest market with sales of €0.55bn. Sweden, Norway and Austria registered growth of 3.8%, 3.4% and 3% respectively, while Greece grew 2.7%. Elsewhere, Portugal was hampered by its low per capita income to rise just 0.8%, while economic troubles held back growth in Belgium/Luxembourg and the Netherlands to the tune of 0.5% and 0.3%.

Overall, this meant that the EU15 (plus Switzerland and Norway) saw overall growth slide a percentage point to 1%, accruing a total of €60bn. Skin care, toiletries and hair care dominated the market. Skin care was the most dynamic of the categories, driven by innovation and added value to grow 3.9%. Toiletries was another winner, rising 1.1%, while fragrance saw a 1% rise. All these were driven strongly by the continued growth of men’s grooming. Hair care showed no lack of launches but was hampered by ferocious price competition and dropped 1.3%.

These results show that innovation is more important than ever if the markets are to enjoy widespread growth again. But innovation can only go so far if consumers fail to buy into it. And that’s where consumer confidence comes in - a topic that formed the backbone of all the presentations.

Reach progress

Consumer confidence should touch on every point of a product’s journey to the marketplace, and with key legislation such as Reach and the 7th Amendment on their way, the congress provided an ideal opportunity to give the industry a progress report.

The journey towards Reach (Registration, Evaluation and Authorisation of Chemicals) has been long and arduous, but Veronique Scailteur, chair of the Chemicals Policy PT at Colipa, said it was nearing the end. “We now have a Common Council Position and are looking at a second reading in Parliament by the end of the year,” said Scailteur, who is confident that the legislation will be ready in its final form by mid 2007.

Colipa has been involved in the advocacy process, trying to ensure that Reach should complement and not conflict with the Cosmetics Directive and has tried to advocate the elimination of unnecessary bureaucracy and the creation of a workable text. It has also called for assessment to be based on risk rather than hazard alone, avoiding the loss of many chemicals, authorisation when the product is clearly safe (still up for grabs) and international cooperation with other agencies. She also stressed the importance of making useful information available to the public if they are to ensure consumer confidence.

For now, Reach covers all substances supplied at one ton per year by manufacturers or importers and calls for data collection, classification and safety data sheets, risk assessment and risk management if required. With time fast running out, Scailteur urged the industry to get prepared. “This means the downstream user, the producer and the importer since Reach covers the whole supply chain. We need to define the roles and responsibilities along the supply chain, a definition of the word ‘article’ and to maintain a continuous dialogue between suppliers and users.” She directed those not yet fully prepared to help desks at CEFIC and some national ministries and consultants. Colipa is preparing a guidance package for the summer.

Nano concerns

Nanotechnology has had a lot of media attention and has caused some unease. Gerd Nohynek, scientific director of the global safety department of L’Oréal Research, said: “You need incredibly high loads for a carcinogenic effect - and that’s in rats rather than humans. Some nano materials can be a little more toxic than microparticles because their surface area is larger. However, often these studies have no microparticle control groups so they have reduced validity.” And while some in vitro studies have shown some penetration into living skin, in the main the nano particles are too large to move into the skin by diffusion; Nohynek suggested that they entered through the follicles.

Whatever the case, Nohynek said that there is no evidence that nanoparticles used as UV filters can penetrate into or through human skin or human local or systemic exposure. Instead, he pointed to an exciting vision of nanobots used as ‘hair jockeys’ and ‘barber saucers’ to cut hair or shave.

Fragrance has also come in for its share of negative attention. Anne Marie Api presented the results of a joint epidemiology study by RIFM and IFRA concerning fragrance allergy. The study aims to examine the prevalence and severity of contact dermatitis caused by fragrance in different regions, starting with Europe. There is currently no data, but the best estimate is that 2% of the population is affected by fragrance-related contact dermatitis. The study is currently in phase II - the design stage - but will look at 100 subjects in five European regions: Malmo, Bergamo, Germany (East and West) and the northern provinces of the Netherlands. Once designed and refined, phase III will increase the original 100 in each country to thousands. These will be asked about the prevalence and severity of their contact dermatitis. The rate of sensitisation will then be determined through patch tests and clinical corroboration. One-to-one interviews will support the study. The result will be definitive data that will take the guesswork out of the area and will set RIFM up as the source of such knowledge. The body also plans to expand its collaboration with the dermatological community and to assist in future policy decisions.

Data is always highly prized by the industry, but there has never before been an accurate measure of how much product is applied by consumers. Barbara Hall described how Taylor Nelson Sofres’ ETCD and Europanel teamed up with Ian Smith Consultancy to run a study of 62,157 individuals in Denmark, France, Great Britain, Germany and Spain to measure their use of body lotion, apds, lipstick, facial moisturiser, shampoo and toothpaste.

Based on diaries, the study measured all the usage occasions against the quantity used (judged on pack weight before and after use) and the subjects’ height and weight. From this information it was found that there is an inverse correlation between the frequency of use and the quantity used per application. The only exceptions were non-spray apds and lipstick, which remained relatively stable. Knowing this should help to avoid overestimations. Another finding is that people use shampoos less frequently as they get older. Hall concluded that the complexity of such exposure patterns calls for new evaluation tools, allowing the industry to express data as quantity per day and to provide a sound safety assessment model for cosmetic ingredients.

Ingredients at risk

One class of ingredient that has come in for significant safety assessment is cyclic volatile methyl siloxanes. Dow Corning’s Kathleen Plotzke ran through assessments of these silicones as persistent bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB). She said D4 was determined to be PBT and delisted in July based on hydrolysis of its half life. Now she and her colleagues are focusing on D5, which is listed as vPvB pending further data. A tiered approach based on analysing D5’s persistance in the air, water, soil and sediment has so far found no toxicity, although its persistence and bioaccumulation are yet to be determined. Plotzke’s group now plans to assess the material’s true potential for bioaccumulation in fish and further environmental studies. It is also participating in regulatory studies and is attempting to develop alliances with other chemical sectors.

Florian Schellauf gave an update on ingredients still up for discussion. Formaldehyde, for example, has already been reclassified as 2b by the IARC but France wants to reclassify it as a CMR or 2. This could lead to a ban of formaldehyde and all preservatives with deliberate release of the substance, losing the industry one of the most important classes of preservatives. Colipa is proposing that it should be classified only for inhalation and is conducing a study on this.

The situation regarding IPBC has been clarified. The SCCP has defined a maximum acceptable iodine exposure from cosmetics in addition to the normal uptake from food and advises that products exceeding these limits should carry a strong warning label.

Products containing algae are often spa-focused so are not used regularly. Sodium iodate and two iodine-containing colourants will be proposed for a ban. Meanwhile, Schellauf said only those products containing high levels of iodine need to be controlled via labelling.

The SCCP has also issued its opinion that methyl- and ethyl parabens are safe but is missing data for others. A joint Colipa/CTFA taskforce submitted this data in September 2005 but more is still needed to produce an opinion on iso-alkyl parabens.

The confusion over Peru Balsam demonstrates the hazards of legislating too swiftly. Although IFRA and the SCCP agreed that only the crude material should be banned, the legislation accidentally bans both the crude material and its extracts and distillates.

Schellauf concluded by outlining important submissions for 2005-6, namely nearly 100 updated hair dye ingredient dossiers, triclosan and bacteria resistance, zinc oxide, nanosized materials, phthalate traces and follow-up submissions for preservatives.

And Europe isn’t the only region to re-examine its ingredients legislation. John Bailey, vice president of the US CTFA, described the last year as challenging but successful for innovation. He said the industry was heartened by the FDA’s rejection of the EWG’s petition for ingredient bans, premarket clearance and the outsourcing of the regulatory system. Instead, California SB484 requires the report and assessment only of matters of concern, covers only companies making sales of $1m-plus and only materials identified as causing cancer or reproductive toxicity.

In Japan the shipment value of cosmetics was measured at ¥1.5 trillion in 2005, a rise of 5.9% over the previous year. But while both imports and exports are growing, the import value doubled that of exports, resulting in a significant trade deficit. The Japanese C&T association, the JCIA, is therefore attempting to stimulate consumer confidence in Japanese products by tightening its regulations, the most important measure being the indication of ingredients of quasi drugs such as hair dyes, permanent waving agents and medicated soaps as a voluntary standard. This was introduced in April. The labels should be legible, visible and must class the ingredient as either active or other.

Directive change

And when it comes to that steady regulatory environment, there’s none so stable as the Cosmetics Directive, which is taken as a model of excellence throughout the world, said Sabine Lecrenier, the head of unit for Cosmetics and Medical Devices in the EC’s Directorate General of Enterprise and Industry. The Directive directly inspired Japan’s regulations and served as a guide for the US and Chinese systems. But it is also in need of simplification. “The need for consolidation is clear from the 44 amendments. We want to produce one text with simplified terminology,” said Lecrenier. She also acknowledged that the EC needs to simplify its procedures. What won’t be changed is the animal testing regime. “It’s not a lack of money but a lack of ideas that is holding back the development of alternatives for 2009 and 2013,” she said.

That interpretation was not completely dismissed by Odile de Silva, chair of Colipa’s SCAAT (Steering Committee on Alternatives to Animal Testing), who gave a progress report on the industry’s search for alternative methods. “The main challenges are the creation of cutting edge science, attracting the best scientists from academia, learning how to integrate data, developing new thinking and, of course, meeting the deadlines.”

The 2009 deadlines concern acute toxicity, skin irritation, eye irritation and genotoxicity, while 2013 calls for alternative skin allergy tests. De Silva said that SCAAT and ECVAM (European Committee for the Validation of Alternative Methods) need to do more work on the integration of methods but remain optimistic. The best news concerns skin irritation, where two methods may be validated by the end of 2007.

Eye irritation remains the biggest challenge, largely because there are so few companies working in the area. “We hope to get something in the file for validation studies by 2008, but we still have no clue about cornea recovery and we don’t know if this will be ready for 2009.” Genotoxicity tests also need a lot of work as the current battery is only partially effective, warned de Silva. “We need to urgently improve current tests and to think about better ones. It’s not only about safety but about business. If we don’t get it right, we’ll lose ingredients.” It’s a different story when it comes to skin allergy, where many projects are underway and SCAAT hopes to give something to ECVAM in 2008.

That’s why de Silva called for much more industry. “We don’t expect replacements to be ready by 2013 but we’re working towards it. It’s about cooperation. We have to increase collaborations and bring in more companies to support the programme.” As a measure of how little collaboration is taking place, de Silva pointed out that only five cosmetics companies are working with the European Partnership on Alternative Approaches to Animal testing (EPAA).

The new regulations may actually create distrust, warned George Gaskell, professor of social psychology at the London School of Economics. “New regulations on chemicals are likely to highlight gaps in science, increase uncertainties about familiar products and lead to scare stories and threats to your trust.”

Problems arise when stories of scientific discoveries make it into the news pages and become campaigning issues. Gaskell said that stories often have a snowball effect, with the public equating volume of coverage as a signal that there really is a problem. “You have to think about the dynamics of public confidence. We need to know how the public thinks about risk, trust and credibility.”

The importance of keying into consumer values was also the key message from Oliver Gray, director general of the Advertising Standards Alliance. Consumers, he warned, don’t like to be misled and are increasingly willing to make their grievances heard through complaints or felt at the cash register. And new advertising media is bringing its own problems to the industry, chiefly through the sheer volume and accessibility of ads.

The challenges and opportunities for the industry are clear, said Bas de Leeuw, head of the strategy unit of the Production and Consumption Branch of UNEP (United Nations Environment Programme). “We have a global consumer class which wants to know how, where and by whom a product has been made. Business and government must build on this growing awareness.”