CTFA Annual Report 2019

3. European Commission- Draft Commission Regulation Amendments and Corrections- WTO Notification no. G/ TBT/N/EU/666 On the 6th of August 2019, CTFA submitted comments to the European Commission regarding their Draft Commission Regulation Amendments and Corrections- WTO Notification no. G/TBT/N/EU/666. The main purpose of the comments was to draw attention to the potential impact that the amendments and corrections have for the South African cosmetic industry. In terms of export to the European Union (EU) from South Africa, both product formulary and packaging components of products will be impacted. Therefore, the proposal was for the South African industry to be granted a transitional period for compliance. It was also mentioned that the South African Draft Regulations are premised on the Regulation (EC) No.1223/2009, therefore any proposed amendments are viewed with a futuristic adoption into the SA regulatory reform, and the associated impact thereof. The comments submitted were acknowledged by the European Commission. 4. African Organisation for Standardisation- New Work Item Proposal On 1 November 2019, CTFA submitted comments to the African Organisation for Standardisation (ARSO) regarding the “New Work Item Proposal” stating support for ARSO's move towards international convergence of cosmetic control in terms of recognition of consumer safety and industry responsibility. However, general comments from CTFA explained that the proposed new work items posed as technical barriers to trade that South African cosmetic companies encounter when they export products to East African Countries. The belief is that the new work item proposals would further isolate not only locally manufactured cosmetic products but additionally cosmetic products manufactured from other parts of the world that follow a standardization system similar to that of South Africa, based on global harmonisation driven by the International Standards Organisation (ISO). ARSO’s proposed approach to standardization is premised on product quality whereas in South Africa the approach is product safety driven. In light of this, the CTFA’s proposal was for ARSO to reconsider the adoption of existing ISO/TC 217 Cosmetic Standards that are in use in South Africa and the rest of the world so that Africa is not isolated in terms of trade with the continent on the chosen harmonization standards. CTFA encouraged ARSO to adopt a more global approach to harmonization instead of one that is continental and suggested that ISO is a suitable basis for this. Regulatory Industry Trends Animal testing ban: In 2019, there were many international regulatory trends that were prevalent in various areas of the regulatory scope. One that has been trending for the last few years and proving to gain more traction was the animal testing ban. With CTFA’s engagement with other international cosmetic trade associations it was evident that animal protection activists were stepping-up their methods of securing attention and results from regulators. This led to the international cosmetic community to get more involved with such groups and manufacture animal testing code/policies that could be adopted in various regions. As a result, the industry saw the USA government change policy around animal tested ingredients and products entering their markets. Chinese authorities will hopefully also consider a ban especially with regards to imported products. Back home, Beauty Without Cruelty, has contributed to an article in the media stating its plans to initiate an amendment to the Animal Protection Act that would ban cosmetics testing on animals in South Africa. The intention of this amendment would “prohibit the sale and manufacture of cosmetics final products and ingredients which were tested on animals in South Africa and to criminalise testing of cosmetics on animals” Weekend Argus, 10 Jan 2020. Cosmetic product claims: The South African cosmetic industry relies on the European Union regulatory developments to inform guidelines within the local self-regulated framework has been the case for the last 25 years. One such area that is adopted is the principles and guidelines for product advertising specifically as it refers to product claims. CTFA updates the Advertising Regulatory Board’s Advertising code of practice Appendix B – COSMETIC TOILETRY AND FRAGRANCE ASSOCIATION OF SOUTH AFRICA 12