Submission to ACCC: Review of the information standard – Cosmetic ingredient labelling

In response to Consultation Paper: Review of the information standard – Cosmetic ingredient labelling

Submitted 6 January 2020 to: Australian Competition & Consumer Commission (ACCC)

Our position in brief:

The NRA submits that a combination of Option 1 (to maintain the current information standard) and Option 3 (to allow overseas standards) is the preferred option.

The Information Standard is the already complex and regulation is fragmented in Australia. The labelling requirements for cosmetics are currently included across various pieces of legislation including:

• Commerce (Trade Descriptions) Regulation 2016 – trade descriptions required on imported products.
• National Trade Measurement Regulations 2009 – for pre-packaged goods, the name and address of the Australian packer.
• Standard for the Uniform Scheduling of Medicines and Poisons (as enacted in State and Territory legislation) – the name and address of the Australian manufacturer or distributor.

Regulatory duplication and overlap must be avoided to ensure the requirements are clear and unambiguous, and that costs of compliance do not become prohibitive, or a disincentive to compliance. Considering the effectiveness of past product recalls, the mandatory standard has been effective.