1. In a few words, can you explain your responsibilities and FEBEA’s activity?

I am Environmental Affairs Officer at the FEBEA and, as my title indicates, I handle environmental issues regarding the cosmetics industry, in particular files related to circular economy of which a lot of topics concern packaging. My duties consist majorly of answering various questions from members regarding the current environmental regulation. I also provide regulation monitoring and information to members. Finally, I organise and lead working groups to discuss collectively the sector’s environmental issues.

The FEBEA is the only professional federation for manufacturers operating in France (perfume, skincare, make-up, hygiene products, etc.). We have more than 300 members (82% VSE/SME and 18% large groups), accounting for more than 95 % of the industry’s turnover.

As a professional syndicate, we have a mission to represent the interests of the sector by a strong presence with the public authorities, as well as an information mission towards our members, our stakeholders and civil society more generally. We also provide technical, legal and social services to our members.

In a context of sustainable development, professional syndicates become crucial and are taking on a new role: uniting individual initiatives and catalysing collective projects, all the while being proactive.

2. The FEBEA joined the CNE this year as a member at its 1^st college (Consumer Products Companies): could you explain FEBEA’s motivation in supporting the CNE and its action?

The FEBEA was already actively taking part in CNE’s working groups as a guest member; for example, we participated in the writing of the recent paper “Recycled materials and packaging: state of play, assets, drawbacks, challenges and perspectives”. In 2019, we made our membership official.

There are multiple reasons behind the FEBEA’s support of the CNE and its action. On one hand, packaging plays an important role in the cosmetics industry, since it is essential to protect and maintain products for as long as possible in compliance with health standards, and because it also has many other functions (sociological, among others). On the other hand, we are fully aware that the eco-design of packaging will stay at the heart of the cosmetics industry’s concerns in the future.

Furthermore, we would like to integrate and represent our industry’s specificities in the thinking process surrounding eco-design within the CNE. Our companies are making more and more eco-design efforts in their packaging, as the white paper “Circular economy and cosmetics sector” can attest and which we would like to share.

In addition, taking part in working groups about eco-design with other stakeholders of the value chain who share a holistic view of the product’s cycle of life constitutes a lever for progress and is of major importance nowadays.

3. The FEBEA joined the working group focusing on the review of the “methodological guide for the eco-design of packaged products”

• What are the positive aspects you’ll remember from this experience of collective intelligence?

Beyond being able to contribute to a common core of eco-design “principles”, I most of all appreciated the opportunity to contribute, among other engaged stakeholders, to demystify popular misconceptions on a topic that sometimes leads nowadays to heated debates. It is crucial to remind that an eco-design action must constitute a real solution regarding a product’s efficiency and its functional unit, and not be about a transfer of pollution or compromise consumer’s safety.

• What follow-up should be given to the topic of eco-design within the CNE?

An application of this guide adapted to the problematic of cosmetics, a sector in which eco-design is particularly challenging regarding the use of complex packaging that suit the consumer’s expectations (the aesthetical aspect is an important component of our packaging).

For cosmetics, the use of secondary packaging tends to decrease, but it should be noted that some of them contribute to the valorisation of the product (sensory experience related by consumers to the opening of a gift or the opening of a luxury package).

4. The FEBEA released in March 2018 its white paper on “Circular economy and cosmetics sector”. What are the topics related to Fair Packaging which you consider important to highlight?

The white paper « Circular economy and cosmetics sector » references 120 good practices of the cosmetics industry. Topics related to packaging which we would like to highlight are:

• limiting the environmental impact of materials (using for example recycled raw materials);
• reducing the weight and size of packaging, for example because of a product’s concentration (less product for the same volume of active substance);
• offering refills;
• improving the recyclability of packages.

Solutions implemented by companies have often been subjected to a life cycle analysis in order to find the most adequate solution to the functional unit of the product. The example of GUERLAIN’s Orchidée Impériale range illustrates the significates of a general life cycle analysis: in a concern for eco-design, the brand introduced heavy and resistant refillable jars. Seeing the failure of this initiative (the number of refills purchased by consumers was not high enough) led GUERLAIN to rethink its packaging (reduction in packaging weight and box size, work on recyclability) for a 58% decrease of the products’ carbon footprint even though their packaging is not reusable anymore.

5. Which are the major concerns of FEBEA members regarding packaging? Can the CNE legitimately document some of these concerns?

The major concern for our members is to implement environmentally virtuous solutions ensuring functions dedicated to the product and consumer use, as well as their health safety, all the while being economically viable and corresponding to the consumer’s expectations.

According to an expert in our industry, “Packaging is the first identity bond between a brand and its consumer (…). It must respect the brands’ identity while meeting the user’s expectations. It is necessary to know how to combine in its conception, the sensory, the rational, the emotional aspect, while integrating sustainable and societal criteria, omnipresent requirement linked to our environmental policy”. (Excerpt from the white paper Circular economy and cosmetics sector)

Thus, for our industry, the major difficulty resides in the conciliation of improving packaging’s recyclability or the integration of recycled raw materials in this packaging meant to be robust and complex in order to ensure a result coinciding with their image and the consumer’s, as well as with health requirements.

The CNE would be entirely legitimate to document our concerns in terms of packaging; and why not a collaboration with the FEBEA on an application of the eco-design guide adapted to the cosmetics sector’s specificities?