European Cosmetics Legal & Regulatory Forum

The EU’s Chemicals Omnibus marks one of the most significant regulatory developments for the cosmetics industry in recent years. By introducing coordinated amendments to the Cosmetics Products Regulation, the Classification, Labelling and Packaging (CLP) Regulation, and related chemicals legislation, the package aims to simplify compliance while maintaining high standards of consumer protection.

• Understanding the Chemicals Omnibus and the coordinated amendments to the Cosmetics Products Regulation, CLP Regulation, and related chemicals legislation
  • Assessing what the reforms mean in practice for cosmetic manufacturers, importers, and brand owners
• Examining the interaction between the Cosmetics Regulation, CLP, and REACH, and how companies can manage overlapping obligations
• Reviewing key changes affecting product classification, labelling, digitalisation, and regulatory simplification

Sustainability remains a key commercial priority and environmental marketing claims have been a key focus for companies and regulators. While the proposed Green Claims Directive has been withdrawn, the Directive on Empowering Consumers for the Green Transition introduces new restrictions on misleading environmental claims and vague sustainability messaging.

• Understanding the new requirements under the Directive on Empowering Consumers for the Green Transition and what they mean for cosmetics and personal care companies
• Substantiating environmental claims in the absence of the proposed Green Claims Directive
• Highlighting claims around “healthy skin,” “longevity,” and “inside-out beauty”, testing the limits between cosmetics, supplements, and medicinal claims
• Developing practical guidance on obtaining environmental data, life-cycle assessments, and avoiding misleading terminology like “biodegradable” or “eco-friendly”
• Examining advertising and enforcement trends regarding sustainability
  • How are EU and UK regulators (including the CMA, ASA, and national authorities) targeting greenwashing cases?

With influencers now being a key extension of cosmetic and personal care marketing and dominating brand strategies, there is a pressing need to ensure full compliance with advertising, consumer protection, and product claim regulations.

Our panelists will assess how to best navigate the evolving digital marketing landscape, helping you tailor your compliance strategy.

• Ensuring influencer agreements comply with disclosure, content, and cross-border advertising rules
• Reviewing the latest guidance from the UK Advertising Standards Authority (ASA) and Competition and Markets Authority (CMA) on influencer endorsements and paid partnerships
• Understanding the growing differences between UK and EU rules for cross-border influencer marketing
• Analysing common compliance pitfalls in influencer content
• Misleading claims, undeclared sponsorships, and the misuse of “clinically proven”, “safe”, or “medical-grade”
• Best practices for drafting social media and influencer agreements to mitigate brand and regulatory risks
• Lessons from recent cases and enforcement trends around influencer marketing and digital advertising claims

The next few years will bring extensive changes for cosmetic and personal care formulations as the EU tightens restrictions on microplastics, silicones, and other substances of concern. With upcoming deadlines for silicone restrictions by 2027 and new allergen labelling obligations by mid-2026, compliance is becoming increasingly difficult.

• Identifying the ingredients and substances of concern expected to have the greatest regulatory impact over the coming years, including:
  • Microplastics, cyclic silicones (D4, D5 and D6), PFAS, CMR substances, endocrine disruptors, and UV filters
• Understanding where the EU and UK regulatory approaches are beginning to diverge and what this means for companies marketing products in both jurisdictions
• Examining upcoming restriction timelines, transition periods, and reformulation priorities to prepare products for future compliance
• Monitoring emerging scientific opinions and regulatory initiatives that may drive the next generation of ingredient restrictions

Where does a product stop being a cosmetic, and start being a medicine or medical device? This long-standing question continues to challenge regulators and manufacturers, as the boundaries between function, presentation, and intended use continue to be blurred.

• Understanding the legal and practical criteria for product classification of cosmetics, medical devices, and medicines
• Examining how marketing language and intended use influence classification decisions
• Assessing recent EU and national rulings on borderline classification disputes, and what they reveal about regulatory priorities
• Emphasizing the need for scientific substantiation for product classification
  • How do evidence requirements differ across product types
  • How can manufacturers prepare robust documentation, to support their classification claim?
• Assessing the classification of aesthetic devices and clinic-based products, including microneedling systems and other borderline cosmetic/medical applications

• Analyzing the new Packaging and Packaging Waste Regulation (PPWR)
  • What are the main obligations and implementation timelines leading up to 2030?
• Assessing waste reduction and recyclability goals and how producers are preparing to meet new reuse and recycled-content targets
• Developing best practices in balancing innovation, design changes, and financial impact as sustainability requirements tighten
• Understanding how the PPWR’s eco-design requirements will influence packaging design, material selection, and product development decisions

Though the EU historically faced fewer group actions and product liability lawsuits than the U.S., this landscape is shifting. This session will examine recent legal developments, key cases, and enforcement trends shaping litigation and liability risk.

• Assessing the implications of the revised EU Product Liability Directive (PLD) and Collective Redress framework for cosmetics manufacturers, distributors, and brand owners
• Understanding how consumer class actions and representative actions are evolving across the EU and UK, and what this means for litigation preparedness
  • Examining litigation and enforcement trends surrounding product claims, including efficacy, “natural,” “clean beauty,” sustainability, collagen, hair growth, longevity, and other emerging marketing claims
  • Reviewing recent UK and EU court decisions affecting cosmetics manufacturers, including cases involving ingredient restrictions, regulatory compliance and product safety

Cosmetics companies operate across increasingly complex markets and regulatory changes are reshaping how products are formulated, labeled, and brought to market.

As we anticipate Europe’s upcoming Omnibus revisions, it is important to take note of other cosmetics regulatory reforms throughout the globe, including the U.S. implementation of MoCRA, Canada’s growing ingredient bans, and China’s evolving CSAR framework.

• Unpacking MoCRA (The Modernization of Cosmetics Regulation Act) in the US
  • A quick overview of FDA enforcement timelines, safety substantiation, adverse event reporting, and facility registration updates
• Examining Canada’s modernized cosmetic ingredient hotlists, labelling, and oversight mechanisms
• Analyzing China’s implementation of CSAR reforms
  • Easing of animal testing requirements
  • New expectations for efficacy claims and ingredient traceability
• Developing strategies for global brands to manage compliance across multiple jurisdictions and evolving regulations