Submissions to the 2012 Review of the National Industrial Chemicals Notification and Assessment Scheme - The Comestic, Toiletry and Perfumery Association

The Discussion Paper: Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)–June 2012 was released on 1 June 2012. Submissions were received betweeen 1 June and 27 July 2012. The comments received from this consultation process will be used to inform the government of stakeholder views

Page last updated: 19 September 2012

PDF printable version of The Cosmetic, Toiletry and Perfumery Association submission (PDF 80 KB)

The Cosmetic, Toiletry and Perfumery Association
Dr Christopher Flower
Director-General
+44 (0)20 7491 8891
+44 (0)20 7493 8061
Josaron House, 5-7 John Princes Street
London, UK
W1G 0JN

Summary

Please provide a short summary, up to half a page, outlining the key points of your submission: Australia imports the majority of cosmetic products sold yet remains a relatively small market in global terms. I am told that the current legislative framework for cosmetic products operating in Australia actively deters many companies from trying to export to Australia because of the significant differences between the current regime and the legislative requirements operating in other large global market sectors. In addition, the relatively small size of the market makes it uneconomic to develop products specifically for Australia. This is to the detriment of the Australian consumer who does not have access to the wide range of products available to consumers elsewhere. In addition, local manufacturers serving the home market will find it difficult to develop products that meet both Australian legislation and other regimes, thus damaging Australian export opportunities.

If the current review leads to a situation where these impediments to trade are reduced, clearly there is an immediate benefit to companies exporting to Australia who will find they can now provide a wider range of innovative products but there is also an immediate benefit to the consumer who now has access to a wider range of products from the global market. Common experience is that this will inevitably stimulate growth in the retail sector to accommodate the extra product ranges. In the longer term, as it will be easier for local manufacturers to develop products compliant with legislation covering broader markets, this may well stimulate those companies to look to developing exports.

Given that the major regulatory frameworks seek much the same objectives, namely that cosmetic products on the market should be safe, effective and of high quality, the means by which they achieve these common objectives become less important than the objectives themselves. If that principle is accepted, and given the potential advantages to be gained as a consequence, I would encourage the Australian government, through the Department of Health and Ageing, to seek opportunities to achieve harmonisation, alignment and mutual recognition of legislation or mutual acceptance of products wherever possible.

A full list of all 2012 submissions can be viewed at June 2012 submissions to the review of NICNAS.