CTFA Annual Report 2020

AFRICAN STRATEGY UPDATE Through CTFA's relationship with the Department of Trade, Industry and Competition we have received support in reaching out to the various African regulators for the cosmetic industry. CTFA conducted a survey within the industry to understand the countries of trade interest as a means to plan and prioritise our strategy. As part of this the following countries have been prioritized in 2020: - Nigeria: CTFA reached out to National Agency for Food and Drug Administration and Control (NAFDAC), the regulatory and control authority that is responsible for cosmetic oversight. We held a few engagements in 2020 providing an in-depth explanation of the South African regulatory framework with the intent to influence the finalization of their draft regulations published in March 2020. - Botswana: Botswana Medical Regulatory Authority (BoMRA) is the regulator that has indicated an interest to regulate the cosmetic industry with a special category of cosmetics that will require registration with the authority. CTFA’s engagements included a commentary submission with an oral presentation of our concerns as well as future participation in stakeholder engagements prior to the finalization of the draft regulations. - Kenya: Kenya Ministry of Health published draft regulations in 2020 to which CTFA submitted a commentary on behalf of the industry. The publishing of these draft regulations introduced a complexity to their existing regulatory framework as the Kenya Bureau of Standards already has an oversight on the industry through the imposition of their mandatory standards in Kenya. Together with the international industry associations, CTFA started conversations with the Kenyan authorities to influence a clear and workable regulation which will ensure the least amount of barriers and challenges for trade with Kenya. - Rwanda: The Rwanda Food and Drug Authority (RFDA) was contacted following their draft regulations published in 2020. Commentary was submitted on behalf of the industry as well as a meeting was held with the authorities to present the challenges we identified and the proposals we have put forward for their consideration. CTFA will continue to engage along these lines with the various authorities in 2021. TRAINING 2020 It is vital that training sessions are conducted to communicate the importance of compliance to the constantly evolving regulatory framework. Brand owners, manufacturers, raw The South African Health Products Regulatory Authority (SAHPRA) further issued guidelines on hand sanitiser products to include: - use on human skin - contain antiseptic ingredients used to kill microorganisms or prevent the growth of micro-organisms - can be handwashes for use with water or handrubs for use without water - “rub” or “Leave on” products primarily used to sanitise the skin, when soap and water are not available, and are left on and not rinsed off with water. Due to the status of hand sanitisers being outside the scope of cosmetics, CTFA does not have the mandate to advise on or assist members with hand sanitiser products. It is our recommendation that member companies who also manufacture, distribute or sell hand sanitiser products, or have the intention of doing so, refer to SAHPRA for guidance on the process of registration. COSMETIC PRODUCT TRENDS: MICROBIOTA & CANNABIS CTFA engaged with the regulator on the growing trend in cosmetics that claims to have a benefit to the skin’s microbiome and the use of cannabis in cosmetic products. The regulator has not provided a clear regulatory direction for application of these ingredient types in cosmetic products, except through an exception to the Medicines and related substances Act 101, which has been interpreted as hemp seed oil being the only component of the cannabis plant that can be used due to its low levels of CBD and THC. CTFA has under the auspices of the expertise within its technical committee taken the decision to convene working groups to provide further guidance for the industry on these aspects in 2021. AFRICAN ORGANISATION FOR STANDARDISATION (ARSO) In 2020, ARSO proposed draft standards for the voluntary adoption by national standards bodies on the continent. CTFA, through the South African Bureau of Standards (SABS), has previously submitted commentary and an oral presentation of the challenges that such vertical standards will pose in terms of trade and innovation of products. CTFA is working closely with SABS, the SADC region and Sub-Saharan Task Force (headed by USA and EU trade associations) to encourage a reconsideration of the draft proposed standards. CTFA will endeavour to keep members updated on the progress in 2021. COSMETIC TOILETRY AND FRAGRANCE ASSOCIATION OF SOUTH AFRICA 12