Cosmetics and the future 655 European Parliament, with their facile demands for instant positive lists, is unimpressive. Experience in the food industry in this regard is dispiriting. It is only too easy for an additive to be struck off the list on real or supposed grounds of danger. To get a new additive included in a permitted list is something else again. The time from first applica- tion to the coming into effect of regulations enabling a new compound actually to be used in manufacturing is usually to be measured in years rather than months. Somehow, some better system has got to be found for cosmetics ingredients. There is also the ques- tion of cost. I have had something to do recently with the funding of toxicological studies on six well-known food colourings in order to establish their safety in use by developing new, additional data demanded by the EEC Scientific Committee for Food. The cost of this work will be about oe700 000 at 1976 prices and will take 5 years. What would the cost be of establishing the safety in use to modern toxicological standards of the 400 + colourings now used in cosmetics in the EEC? It is estimated that it will cost oe2.5m to generate the extra toxicological data required for the 215 substances that have been proposed for positive listing as food flavourings. Who can guess what it would cost fully to evaluate the 13 000 cosmetic ingredients to which I have just referred? The CTFA have tackled the problem in a forthright way with their Cosmetic Ingredient Review programme in which independent experts will assess the safety in use of all the compounds (except fragrances) used in the industry and indicate where further toxicological data are required. I very much hope that some means will be found for the European industry to co-operate in this exercise, because otherwise we are going to dissipate money and scarce resources in duplicating their efforts when preparing our own positive lists. A more encouraging lesson from the food industry is to be found in the field of government-industry relations. Over the years a system of informal and formal con- sultation at every stage of the legislative process has been built up. I hope that this tradition of collaboration rather than confrontation will prevail in the new field of cosmetics regulations. The signs so far are good. The Government sought the views of industry in the discussions in Brussels on the Directive, and industry is currently being consulted in the drafting of the necessary implementing legislation. Thus it has been possible at an early stage to suggest the inclusion of legislative features that the food industry have found by long experience to be valuable, for example enforcement through local authorities rather than by an FDA-like monolithic machine. Should the industry go further and seek the establishment of an independent advisory body like the Food Standards Committee (a 'Cosmetic Standards Committee')? This Committee comprises three persons from the scientific field, three from the food industry and three generally representative of the public interest under an independent chairman (8). Together with the similarly structured Food Additives & Contaminants Committee it advises Ministers in the exercising of their regulation making powers under the Food & Drugs Act. You may think that a more formal but also more 'open' system incor- porating an advisory committee of this kind could provide some protection should the industry ever have to negotiate in regulatory afi•tirs in a more hostile political environ- ment than we have at present. Our present good but informal relations with the authori- ties might not necessarily survive the coming to power of elements already active in politics in this country. We can reasonably expect that non-tariff trade barriers will wither away within the Community but there is not much sign of this happening in the wider world scene. In 1962 a few major firms in the food industry got together to provide money to launch the

656 R. J. L. Allen Codex Alimentarius Commission under the joint sponsorship of the World Health Organisation and the Food & Agriculture Organisation of the United Nations. The aim was the removal of non-tariff trade barriers by harmonisation of food standards worldwide. Fifteen years later many 'recommended international standards' have been elaborated, but I cannot say that the results in terms of freeing international trade have been commensurate with the time, money and effort expended. On the whole, I would advise the international cosmetics industry to seek some other procedure, perhaps with a much stronger industrial orientation, to solve their problems. A word of warning from food industry experience relating to food additives may be timely. The Food & Drugs Act requires the technological need for an additive as well as its safety to be demonstrated. In addition, there is constant pressure to keep the per- mitted lists as short as possible and so restrict the actual number of colourings, for example, that are available for use. I hope that no one is going to try to apply these principles to positive lists of cosmetics ingredients, because I believe that this would not only discourage innovation but would in addition be inappropriate and perhaps harmful. Need should be left to market forces and, by spreading the total toxicological load, having more rather than fewer compounds could be advantageous in terms of safety rather than the reverse. The only aspect of quality I want to discuss is product stability in relation to label expiry dating. Regulations under the Medicines Act require an expiry date to be shown when the shelf life is less than 3 years. Voluntary marking with a 'sell by' or 'use by' date is now quite common with perishable foods, and a 'best before' date will become mandatory under the draft EEC Food Labelling Directive. The requirement under the Cosmetic Products Directive for an expiry date on products with a stability of less than three years is thus nothing new, and should not cause too much trouble so long as it is reasonably interpreted in the UK counterpart regulations. In the field of labelling mandatory declaration of ingredients of cosmetics is, I know, an issue that raises strong feelings. Ingredient declaration was violently opposed by the UK proprietary medicines industry in 1941 and by the UK food industry from 1945 onwards, but both industries have learned to live with it. With these precedents, and consumerist pressure, perhaps it will come here one day as it has in the US. I personally doubt whether it would prove any more disastrous for the cosmetics industry than it has for pharmaceuticals and food. I would myself trade mandatory compositional standards for ingredient labelling any day. As for advertising, I want only to mention that for 40 years the Proprietary Associ- ation of Great Britain has been vetting members' advertisements for proprietary medi- cines. The strength and reputation of this voluntary system has stood the industry in good stead and it looks as if it will gain official recognition by formal association with the regulations on advertising under the Medicines Act that are now being drafted. Thus the industry will retain a substantial measure of independence in this important matter. I am not necessarily advocating a system of this kind for operation by the Toilet Preparations Federation: I just draw attention to its success in a related sector of industry. My last problem is animal experimentation. Criticism of the use of animals in safety and efficacy studies has swung away from pharmaceuticals and towards allegedly non- essential items, including food additives and especially cosmetics, which we must admit has become an emotive word in this context. Whatever one's personal feelings are about the use of animals for any experimental purpose, I see no way in which a manufacturer