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ICADA - DER KOSMETIKVERBAND
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Projects

ICADA is involved in numerous projects on behalf of the cosmetics industry and stands in the way of the legislator's regulatory wishes when restrictions and market restrictions appear disproportionate and/or particularly hinder small and medium-sized companies. The following is a - very abbreviated and selective - list of various ICADA projects:

Eyelash serums

Various national authorities - including the Federal Institute for Drugs and Medical Devices - have lobbied the EU Commission for a ban on eyelash serums on the grounds that they are functional medicinal products.

ICADA has repeatedly opposed this in the past and has criticized the data collection presented, but has also criticized the fact that a significant physiological effect has not been demonstrated. To date, there has been no ban on eyelash serums in cosmetic products. ICADA is still active in this area.

Endocrine disruptors

Endocrine active substances (EAS) are substances that can influence or disrupt normal hormone activity. If this leads to impairments, they are referred to as endocrine disruptors (ED).

ICADA points out that not every endocrine disruptor poses a risk. Rather, there are different sources of endocrine disruptors, such as in plants (e.g. soy). ICADA therefore calls for a differentiated assessment based on whether a substance is dangerous; this depends on the dose, duration and time of contact.

CBD in cosmetic products

CBD does not contain THC and does not have a psychoactive effect. Nevertheless, there have been repeated discussions as to whether and, if so, how CBD may be used in cosmetic products.

The ECJ ruling of 19.11.2020 (Case C 663/18), in which the Court held that CBD is not to be classified as a narcotic substance; there is no psychoactive effect, fell within this discussion. Other negative effects on human health are possible, but have not been proven. 

ICADA is of the opinion that bans can only be justified if they serve to protect public health. However, there are no scientific results that prove any adverse effects on health.

Animal-free testing

According to Art. 18 of the European Cosmetics Regulation (Regulation EC No. 1223/2009), animal testing of cosmetics has been prohibited in the EU since 2013. It is also prohibited to place cosmetics on the market in the EU that have been tested on animals outside the EU in order to demonstrate compliance with the EU Cosmetics Regulation.

ICADA believes that the new European chemicals strategy and its principle of "one substance one assessment" jeopardizes the principle of animal-free testing in cosmetic products. According to this principle, substances should only be tested and assessed once. Although this sounds like a simplification at first, if substances for cosmetic products are tested in future according to the rules of other chemicals regulations that do not apply a similarly high standard of animal-free testing, the principle of animal-free testing could be undermined. Together with the association Ärzte gegen Tierversuche e. V., ICADA has submitted a statement to the responsible working group of the EU Commission.

Microbiome

After a break of more than 2 years, the EU Commission's Borderline Working Group met again on March 2, 2023. Many topics that had accumulated during the coronavirus period were discussed and worked on.

However, the focus was on microbiome cosmetics. This is still not based on solid regulatory rules. ICADA discussed the two fundamental issues with the Commission management and the other stakeholders;

  • Probiotics are neither substances nor mixtures in conformity with Article 2 KVO. Probiotics are "articles", but their use is not regulated in the KVO;
  • The target organs of cosmetic products are the skin and its appendages. The microbiome does not belong to any of these. 

ICADA is working on solutions to these problems.

There are also numerous other projects that ICADA is driving forward for the cosmetics industry: Declaration of essential oils, microplastics, environmental claims, new cosmetics regulation with fundamental changes, obligations and scope of digital labeling, prostaglandins, allergen declarations, defense against the ban on tea tree oil in cosmetic products, etc.