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					Consumer
Confidence
Safe and responsible use of
chemicals in everyday products




A Unilever commitment
September 2007
Our purpose

Unilever’s mission is      Vitality is at the heart of everything we do:
                           our brands, our people and our values.
                                                                           Contents
to add vitality to life.   Our name is on all our brands and all of        Foreword                   1
                           our subsidiary companies worldwide, so that     Being safe                 2
We meet everyday           people know who we are, what we do and
                                                                           Feeling safe               5
needs for nutrition,       what we stand for. We want our brands and
                           the company behind them to be understood
                                                                           The opportunity of GHS     8
hygiene and personal       and trusted throughout the world.
                                                                           Our position in summary    9
care with brands that      This report is part of that commitment.
                           We recognise that consumers everywhere          Our H&PC partnerships     10
help people feel good,     are increasingly concerned about health and
                           environmental issues and are demanding
look good and get more     more openness and information from
out of life.               companies. We welcome these expectations
                           and believe that consumer confidence is
                           essential, not only for the success of our
                           business, but also for the wellbeing of
                           society, its citizens and the economy.
                           We are committed to building consumer
                           confidence on a strong foundation of
                           regulation, responsible practices and
                           transparent communication with consumers,
                           customers and other stakeholders.

                           Unilever consistently applies the highest
                           safety standards around the world, regardless
                           of where the product is made, sold, or used.
                           In this report we explain our approach to
                           ensuring that consumers can have confidence
                           in our home and personal care products:

                           CONFIDENCE that they can use them safely.

                           CONFIDENCE that they will effectively deliver
                           the benefits they need.

                           CONFIDENCE that they can trust our brands,
                           and Unilever, as the company behind
                           those brands.
Foreword
by Ralph Kugler, President,
Unilever Home & Personal Care


Our home and personal care products are           – is a chemical, and chemicals enable us
used every day in millions of homes around        to deliver many of the hygiene and other
the world. Whether it’s Skip or Cif, Axe or       benefits that consumers demand.
Dove, people trust our brands – and with
                                                  We fully support consumers’ right to know
good reason.
                                                  about the ingredients in our products and
We place great emphasis on product safety,        we are concerned that evidence shows
and have a long established track record          current hazard warnings and product safety
of ensuring that our products are safe for        advice are not always well understood by
people and for the environment.                   consumers and users, particularly in relation
                                                  to chemicals. Consumers are better informed
Benefits                                          from risk-based labelling which clearly
                                                  indicates the safest way to use products.
We gain satisfaction from the fact that
our products have made – and continue to
                                                  Clear CommuniCation
make – a huge contribution to maintaining
hygiene, health and wellbeing. From               The rapid pace of development in science          It is vital that
shampoos to moisturisers, detergents to           and technology brings huge potential
surface cleaners, our products help people to     benefits but also poses new challenges            consumers are
improve their quality of life on a daily basis.   for society. Consumers are constantly             provided with
                                                  bombarded with a mass of information
familiar and trusted                              and mis-information on product and                clear and effective
While our products are used safely millions of
                                                  ingredient safety.                                usage advice so
times a day, we have a duty to communicate        That’s why we believe there is an urgent          that product safety
                                                  need for consumer goods companies to
to consumers both the benefits and risks of
our products and give advice on their safe        review and improve communication to
                                                                                                    is guaranteed.
and effective use. We take this responsibility    the public on the benefits and safe and
very seriously.                                   effective use of all products. Clearer and
                                                  simplified labelling and greater clarity about
As a global company, we believe that the
                                                  ingredients will ensure that consumers
regulations governing safety instructions
                                                  are better informed. Building consumer
for home and personal care brands should
                                                  confidence in this way – providing the right
be consistent around the world. It is vital
                                                  information, at the right time, in the right
that consumers are provided with clear and
                                                  place – has positive implications for everyone:
effective usage advice so that product safety
                                                  business, civil society, legislators and, most
is guaranteed. It’s important to me that every
                                                  importantly, our consumers themselves.
one of our consumers knows that a Unilever
product means the optimal combination of
                                                                                                                          Consumer Confidence – Safe & responsible use of chemicals in everyday products




safety and efficacy.


Consumers’ right to know

We are committed to being a transparent
source of information for consumers on
the social, environmental and safety issues
relevant to our brands. This also applies to
the chemicals used in them. Everything we
touch, taste and feel – natural or man-made
                                                                                                                          1
                                                                                 Being safe

                                                                                 There is no question       We place the highest priority on safety
                                                                                                            and environmental protection. Of course
                                                                                                                                                             our safety proCess

                                                                                                                                                             Our Safety and Environmental Assurance
                                                                                 that the starting point    we comply with all laws and in several
                                                                                                                                                             Centre (SEAC) ensures that safety and
                                                                                                            areas we set our own globally applied
                                                                                 for building consumer      standards higher than the regulations require.
                                                                                                                                                             environmental decisions are made
                                                                                                                                                             independently of commercial considerations.
                                                                                 confidence lies with us,   We assess, and regularly re-assess, all our
                                                                                                                                                             All Unilever products must be approved
                                                                                                            products thoroughly. We have a long and
                                                                                                                                                             by SEAC which plays a continuous role
                                                                                 in ensuring day after      proven track record of ensuring that our
                                                                                                                                                             in assessing product safety from the
                                                                                                            products are safe and can be trusted.
                                                                                 day, around the world,                                                      first product idea through to a final
                                                                                                                                                             rigorous pre-market assessment and
                                                                                 that our products are      our standards
                                                                                                                                                             post-launch monitoring.

                                                                                 safe for people to use.    Unilever maintains a set of mandatory
                                                                                                                                                             SEAC also works closely with a network
                                                                                                            requirements for the use of ingredients
                                                                                                                                                             of experts throughout the company to
                                                                                                            and materials in its home and personal care
                                                                                                                                                             make safety an integral part of the design
                                                                                                            products, which are owned by the Global
                                                                                                                                                             of new products.
                                                                                                            Senior Vice President for R&D and authorised
                                                                                                            by the President of the Home and Personal
                                                                                                                                                             safe for you
                                                                                                            Care business. They set restrictions on the
                                                                                                            type and level of ingredients we will use and    We carry out risk assessments to establish
                                                                                                            impurities that we will tolerate.                whether products are safe for consumers.
                                                                                                                                                             The welfare of vulnerable groups, such
                                                                                                            These standards cover all Unilever home
                                                                                                                                                             as young children, pregnant women and
                                                                                                            and personal care products and promotional
                                                                                                                                                             old people, is always taken into account.
                                                                                                            items (i.e. items that Unilever places on
                                                                                                                                                             We keep a constant watch on scientific
                                                                                                            the market, or is otherwise responsible for).
                                                                                                                                                             developments, review our findings in the
                                                                                                            They take into account the key regulatory
                                                                                                                                                             light of new information, and pursue
                                                                                                            requirements together with human and
                                                                                                                                                             a deliberate policy of substitution for
                                                                                                            environmental safety factors (including
                                                                                                                                                             products already on the market.
                                                                                                            occupational safety) and are continually
                                                                                                            reviewed and updated in light of new             Internationally recognised risk assessment
                                                                                                            information and developments.                    methods are used to objectively and
                                                                                                                                                             impartially assess the safety of our ingredients
                                                                                                            Our standards are an essential internal
                                                                                                                                                             and products. Our risk assessments take
                                                                                                            reference for product formulators,
                                                                                                                                                             into account both the inherent properties of
                                                                                                            specification writers, supply managers
                                                                                                                                                             chemicals (hazard) and the way they are used
                                                                                                            and quality control. This is one of the main
                                                                                                                                                             (the risk, which is the exposure to the hazard)
                                                                                                            mechanisms which, together with local
                                                                                                                                                             to determine if a product is safe.
                                                                                                            technical and regulatory clearance, ensures
Consumer Confidence – Safe & responsible use of chemicals in everyday products




                                                                                                            that we:                                         First, we determine the hazard profiles of
                                                                                                                                                             the ingredients in a product and establish
                                                                                                             Always meet or exceed any regulatory
                                                                                                                                                             the level at which the ingredients have
                                                                                                             requirements.
                                                                                                                                                             ‘no effect’. Second, we calculate the level
                                                                                                             Apply consistent standards of human             of exposure to the ingredients (via skin,
                                                                                                             and environmental safety worldwide.             breathing, swallowing). This will depend
                                                                                                                                                             on the type of product we are assessing
                                                                                                             Manage the proactive substitution
                                                                                                                                                             and the amount of each ingredient in the
                                                                                                             of materials when robust, lower risk
                                                                                                                                                             product. For example, a person’s exposure
                                                                                                             alternatives are available.
                                                                                                                                                             to ingredients in a skin cream will be higher
                                                                                                                                                             than those in a laundry detergent. In this part
                                                                                                                                                             of the scientific risk assessment we also take
                                                                                                                                                             into account the possibility of foreseeable
                                                                                                                                                             accidents or misuse of the product.
2
We then compare the predicted exposure             promoting Consumer safety
with the ‘no effect’ level for any potential
                                                   As well as complying fully with all relevant
hazard. This gives us the margin of safety,
                                                   legislation, we encourage the development
representing the risk for the user. We use
                                                   of new laws to enhance consumer safety.
accepted safety factors to assess the safety
of the product, including a separate               We have actively supported the development
assessment for children under the age              of the new EU legislation on chemicals
of three. If the exposure cannot be safely         known as REACH (Registration, Evaluation
managed, we will not market the product.           and Authorisation of Chemicals) and we are
                                                   reviewing the chemicals we use to ensure
We also monitor the product in the market
                                                   they will comply.
to confirm its safety. We do this by reviewing
feedback from our consumer Carelines and           We have also worked hard to help make the
service groups as well as information from         US High Production Volume Chemicals (HPV)
poison centres.                                    programme a success by taking the lead on
                                                   key ingredients which we manufacture and
safe for the environment                           by providing safety data on other ingredients
                                                   to our suppliers.
We carry out environmental risk assessments
to establish if our products are safe for the      We believe that such initiatives will not only
environment. We use accepted scientific            help to reassure the public that the chemicals
techniques to work out the amount                  used in everyday products are safe but also,
of ingredients that will end up in the             by increasing transparency, will help establish
environment and whether this poses a risk          more consistent global requirements for
of toxic effects.                                  chemical safety.

We also estimate the total concentration
of each chemical resulting from all the
different products we make and other
sources. For example, we work with other
companies to assess the total releases of
some chemicals into the environment.
This helps us to determine our own impact
in the context of society’s wider emissions
and the capacity of the environment to
break them down.



  Safe concentrations
                                                                                                     Consumer Confidence – Safe & responsible use of chemicals in everyday products




  The conservative safety factors that we
  use are well established and accepted by
  regulators, industry and academic scientists.
  They take into account all types of consumers:
  children, adults, males, females and
  individuals that may be more sensitive
  to the chemical than on average.
  Safety factors are also applied to
  environmental toxicity test data to derive
  safe concentrations for long-term exposure
  as well as different life stages, species and
  physiological states.
                                                                                                     3
                                                                                 preCaution and suBstitution

                                                                                 We recognise that the science surrounding
                                                                                                                                     The Precautionary                                    The Substitution
                                                                                 chemicals and their impact is sometimes
                                                                                                                                     Principle                                            Principle
                                                                                 not fully understood. This is why we apply          For every new product or change in product           Once a product is on the market,
                                                                                 both the Precautionary Principle and the            we act on the side of caution. If there are          we replace safe but hazardous
                                                                                 Substitution Principle.                             uncertainties about whether a chemical or product    substances if less hazardous substitutes
                                                                                                                                     poses unacceptable risks to the environment          are available which can deliver the
                                                                                 In practice, there are a number of substances       or the health of people or animals, we will          necessary benefits robustly and cost-
                                                                                 we no longer use:                                   not put the product onto the market. We also         effectively. We also apply substitution
                                                                                                                                     continuously monitor scientific developments and     to new product launches.
                                                                                  Well before the adoption of the detergents         in-field experience and we re-assess our existing
                                                                                                                                     products if new information is generated.
                                                                                  regulation in the EU we stopped using
                                                                                  highly branched or structurally complex
                                                                                  surfactants because of their inferior
                                                                                  biodegradability. Nor have we used                In selecting our perfumes, we apply                   A voluntary reduction lowered
                                                                                  alkyl phenol ethoxylates for approximately        stringent biodegradability and toxicity               environmental concentrations and
                                                                                  30 years.                                         standards which has resulted in a major               improved safety margins. We are
                                                                                                                                    screening exercise to ensure sufficient data          now in the process of phasing out
                                                                                  Preservatives are key ingredients to
                                                                                                                                    is available to support the materials we use.         PCMs in our home and personal care
                                                                                  ensure product safety. Without them,
                                                                                                                                    Our internal standards are indeed tighter             products worldwide.
                                                                                  products would be susceptible to bacterial
                                                                                                                                    than the fragrance industry norms.
                                                                                  contamination which could result in                                                                    – When new data led the industry to
                                                                                                                                    For example:
                                                                                  poor efficacy and/or an increased risk to                                                                reassess the safety of geranyl nitrile,
                                                                                  consumer health. Our use of preservatives         – We no longer use nitromusks in                       we began an active programme of
                                                                                  is restricted to formulations where self-           our perfumes.                                        substitution resulting in the majority
                                                                                  preservation is not feasible and there is a                                                              of our use being substituted well ahead
                                                                                                                                    – An environmental risk assessment
                                                                                  risk of product contamination. Our primary                                                               of the fragrance industry’s deadlines.
                                                                                                                                      of polycyclic musks (PCMs) in the
                                                                                  concern is the safety of consumers and as
                                                                                                                                      mid-1990s indicated that European
                                                                                  such we carefully select our preservatives
                                                                                                                                      safety margins were quite small
                                                                                  and use the minimum level to ensure
                                                                                                                                      under specific conditions (for example,
                                                                                  effectiveness. Like all of our ingredients,
                                                                                                                                      where sewage was discharged untreated
                                                                                  they are thoroughly assessed for safety
                                                                                                                                      into the environment). There were
                                                                                  before being used.
                                                                                                                                      also concerns about bioaccumulation.




                                                                                    Child resistant closures
                                                                                   We also take a precautionary approach to         At the same time, we are aware that,
Consumer Confidence – Safe & responsible use of chemicals in everyday products




                                                                                   child resistant closures (CRCs) and sometimes    to maintain their effectiveness, it is important
                                                                                   use them where they are not required by          only to use CRCs where strongly indicated.
                                                                                   legislation, especially:                         Over-use of CRCs could lead to:

                                                                                     When a CRC is the market norm for a specific    Reduced ability of consumers to distinguish
                                                                                     product type                                    between higher and lower risk products

                                                                                     When appropriate safety risk assessment         Increased risks to elderly or arthritic
                                                                                     indicates a CRC could improve safety margins    consumers who do not reseal the closure
                                                                                                                                     so that they are able to re-open it
                                                                                     Where the product could cause damage to
                                                                                     property – for example, some bleaches           Children being taught to open CRCs on
                                                                                                                                     low risk products and then being able to
                                                                                     If a product has an unusual degree of           gain access to high risk items in the home,
                                                                                     child appeal                                    including medicines
4
Feeling safe

Our responsibility does
not end with making
sure that the products
we place on the
shelves are safe for          Hazard                 Risk management                       Zero risk?                      ...Impossible!

people to use.            the difference between risk and haZard (no animals were harmed in the making of this cartoon).




                          We need to make sure that we communicate                    responsiBle CommuniCation
                          clearly with consumers to help ensure they
                                                                                      In Unilever, we are continuously working to
                          understand the benefits and any risks when
                                                                                      improve our labels and other communication
                          they choose our products and that they use
                                                                                      channels to ensure that consumers get the
                          them safely and effectively.
                                                                                      right information at the right time in the right
                          This is a vital part of product safety and,                 place to ensure their safety. We also list the
                          at the same time, is part of our commitment                 ingredients used in our home and personal
                          to be a trusted source of information for our               care products typically either on the label or
                          consumers. Consumers want to be able to                     on our website and we respond directly to
                          take our word for it – industry, retailers and              queries received via telephone, letter or via
                          government’s – that products on the shelves                 our websites.
                          are safe for them to use.
                                                                                      We do recognise that there is more to be
                          Sometimes they may want more than the                       done to earn and build consumer confidence.
                          basic information – for example, because
                                                                                      Consumer communication and education
                          someone in their family has allergies.
                                                                                      is key. Unilever is working with stakeholders
                          And sometimes their confidence may be
                                                                                      around the world to help to provide
                          shaken by scares, often spread through
                                                                                      both the impetus and the opportunity to
                          the media. They want to be able to inform
                                                                                      develop a coherent, consistent framework
                          and reassure themselves that they are
                                                                                      to ensure effective and responsible safety
                          making the best choices for themselves
                                                                                      communication. As part of those efforts,
                          and their families. Because being safe is
                                                                                      both we, and some of the trade associations
                          also about feeling safe.
                                                                                      to which we belong around the world, have
                          This is why it is critical to have labels that              conducted workshops with a wide variety of
                          tell consumers how to use products safely                   experts and stakeholders that have yielded
                                                                                                                                            Consumer Confidence – Safe & responsible use of chemicals in everyday products




                          and effectively and, just as importantly, tell              extremely useful findings.
                          them where they can obtain more detailed,
                          comprehensive information than can be                       risk-sensitive soCiety
                          placed on a label.
                                                                                      Consumers are more informed and as
                                                                                      risk-sensitive as ever. Therefore the need to
                                                                                      maintain and build confidence and trust has
                                                                                      never been higher.

                                                                                      Concerns about risk do seem to be higher
                                                                                      among younger consumers, and people are
                                                                                      more able to make sensible decisions when
                                                                                      they feel familiar with a risk and how to deal
                                                                                      with it.
                                                                                                                                            5
                                                                                  trust                                              perCeptions of everyday produCts                  Clarity and relevanCe

                                                                                  “The key to navigating the risk                    Consumers trust the combination of                Consumers need labels to enable them to
                                                                                  communication process lies in paying more          benefit and safety that established brands        use products safely and effectively. What they
                                                                                  attention to the social amplification of risk      offer.3 They generally consider home care         consistently ask for is, not more information,
                                                                                  and the role of trust,” according to experts       products as safe4, but they have developed        but clarity: clear advice on the safe and
                                                                                  at the King’s Centre for Risk Management,          a perception of risk associated with common       effective use of a product to get the
                                                                                  King’s College, London.1                           products, and discriminate between products       desired benefit.
                                                                                                                                     they consider low risk (like washing-up liquid)
                                                                                  Consumers want to trust the products on                                                              Research shows, time and again, that labels
                                                                                                                                     and high risk (like oven cleaners, highly
                                                                                  the shelves. In other words, they want to                                                            are not well-read by consumers and current
                                                                                                                                     flammable products).5
                                                                                  drive the car – they don’t want to have to                                                           hazard labels are poorly understood.7
                                                                                  look under the hood at the engine.                                                                   The sheer weight of information available
                                                                                                                                     BalanCe Between stakeholders
                                                                                                                                                                                       can make it opaque and confusing rather
                                                                                  More transparency may not increase public
                                                                                                                                     At the same time, consumers recognise that        than helpful. If there are several warnings
                                                                                  trust. But lack of transparency increases
                                                                                                                                     knowledge is constantly evolving and know         on a pack, the most important ones may
                                                                                  public distrust. This is the challenge for both
                                                                                                                                     there may be no black and white answers.          be overlooked.
                                                                                  industry and authorities. Research shows
                                                                                                                                     They can therefore be reassured if they can
                                                                                  that “discussing a low-probability hazard…
                                                                                                                                     see an active debate going on over an issue
                                                                                  may actually serve to increase its imaginability
                                                                                                                                     in which all the main parties are involved,
                                                                                  and thus its perceived riskiness.”2 Yet not
                                                                                                                                     because then they can see a process taking
                                                                                  talking to consumers about risk may increase
                                                                                                                                     place in which each is helping to keep the
                                                                                                                                                                                         What is natural?
                                                                                  public distrust if an issue emerges.
                                                                                                                                     other in check.                                     There is an enthusiasm for all things natural,
                                                                                                                                                                                         often coupled with a feeling that natural
                                                                                                                                     “At its best, risk communication is not a           materials are in some way safer or preferable
                                                                                                                                     top-down communication from expert to the           to those which are synthetic8.
                                                                                                                                     lay public, but rather a constructive dialogue      This can be true but is not necessarily
                                                                                                                                     between all those involved in a particular          the case. Some of the world’s most toxic
                                                                                                                                                                                         chemicals are natural – curare, snake
                                                                                                                                     debate about risk.”6                                venom, belladonna.

                                                                                           The brand is a                                                                                Natural molecules are made up of the same
                                                                                                                                                                                         atoms, often stuck together in exactly the
                                                                                           signal of less risk.                                                                          same way as synthetic ones. The true measure
                                                                                                                                                                                         of safety is how any risks are managed.
                                                                                           Consumer, spain9
                                                                                                                                     The product itself is                               The best measure we have of sustainability
                                                                                                                                                                                         is the total life cycle impact – including any

                                                                                                                                      not dangerous, it is                               deforestation, fertiliser impact, etc.

                                                                                                                                                                                         In Unilever, we are careful about how and
                                                                                                                                     what you do with it.                                why we will use natural and naturally derived
                                                                                                                                                                                         materials and how we will communicate and
                                                                                                                                                            Consumer, spain              the advertising claims that we might make.
                                                                                                                                          keystone, risk perception research             For example:
                                                                                 You lose yourself
Consumer Confidence – Safe & responsible use of chemicals in everyday products




                                                                                                                                                                  June 2005
                                                                                                                                                                                           We aim to protect exotic and endangered
                                                                                 in too much                                                                                               species – both plants and animals. It is our
                                                                                                                                                                                           objective always to ensure that our materials
                                                                                 information.                                                                                              are derived from farmed/husbanded sources
                                                                                                                                                                                           consistent with our sustainability and CSR
                                                                                 Consumer, france                                                                                          commitments and policies.

                                                                                                                                All we want is                                             We are objective, risk-based and use Life
                                                                                                                                                                                           Cycle Assessment in our raw material and
                                                                                                                    structure and simplicity                                               process selection, formulation thinking
                                                                                                                                                                                           and as the basis for any environmental
                                                                                                                           – it should not be                                              improvement claims.


                                                                                                                        like reading a book.                                             We believe that greater consistency
                                                                                                                                                                                         within the industry, starting with agreed
                                                                                                                                                                                         definitions and approaches, would reduce
                                                                                                                                                   Consumer, uk
                                                                                                                                                                                         consumer confusion.
6
Consumers want information structured,
so that they can easily access what they                            Labelling do’s and don’ts
want to know, when they want to know it.
                                                                    P   Keep it simple and clear                     O   Clutter labels
They are asking that we simplify, clarify and
prioritise, as follows:                                             P   Focus on use not on problems                 O   Use technical language

                                                                    P   Structure the content – separate             O   Duplicate information
    Usage – what’s it for and how do you use it                         sections, space
                                                                                                                     O   Over-communicate on low risk products
    Warnings if there are dangers (using icons                      P   Use images to draw attention to
                                                                        important points                             O   Write on bottom of pack
    and/or text)
                                                                    P   Warnings and advice should be fact-based     O   Write too small
    Clear company contact details (telephone
                                                                    P   Make it clear where to go for extra advice   O   Let bar codes get too big
    number or website)
                                                                        (telephone, internet, leaflets)
                                                                                                                     O   List unimportant ingredients
    Poison control centre details if it is a
    dangerous product (in countries where
    poison control centres exist)

    Disposal information including recycling

Unilever’s research gives practical indications
on how to improve clarity in labelling:
by prioritising the information that is more
important and helpful to consumers, and
removing information that is not essential
on-pack, presenting it instead accessibly on
a website, layered for greater clarity, and to
meet the needs of various stakeholders.




                                                                                                                                                                 Consumer Confidence – Safe & responsible use of chemicals in everyday products




1
  Rogers, Löfstedt, Coldbeck, 2005, King’s Centre for
  Risk Management, King’s College, London
2
  Slovic et al, 1981, Perceived Risk: Psychological Factors and
  Social Implications, Proc. R. Soc., London
3
  Keystone, 2005, Risk Perception Research – Qualitative Research
4
  SDA Survey 2006
5
  Keystone, 2005, Risk Perception research
6
  Löfstedt, 2003, Risk Communication: Pitfalls and promises,
  European Review 11(3)
7
  Keystone, 2005, Risk Perception research
8
  See also UKCPI publication “Meeting Natural Expectations”
9
  Keystone, June 2005, Risk Perception research
                                                                                                                                                                 7
                                                                                 The opportunity of GHS

                                                                                 The Globally Harmonised System of                  will likely create ‘warning fatigue’. We want
                                                                                 Classification and Labelling of Chemicals          to avoid a situation where consumers are
                                                                                 aims to enhance human and environmental            desensitised to product labels to the point
                                                                                 safety by establishing a single, universal         that they dismiss or underestimate the risks
                                                                                 standard and system around the world for           of high-risk products and do not follow safe
                                                                                 the classification and labelling of chemicals.     use instructions. it would take only small
                                                                                                                                    changes to make a big difference and so
                                                                                 Unilever fully supports that goal. We believe
                                                                                                                                    avoid the risk of consumers developing
                                                                                 that GHS has the potential to build on existing
                                                                                                                                    warning fatigue and ignoring important
                                                                                 chemicals legislation to ensure safety and
                                                                                                                                    hazard warnings on certain products.
                                                                                 build consumer confidence in chemicals,
                                                                                 and in products containing chemicals, by           3) The use of ‘by default’ classifications
                                                                                 delivering the right information to consumers      might provide the motivation for unethical
                                                                                 in the right way.                                  business practices such as placing on the
                                                                                                                                    market non-classifiable products through
                                                                                 We are committed to help ensure that GHS
                                                                                                                                    dilute formulations and/or compromising
                                                                                 succeeds, and we are convinced that, for it to
                                                                                 do so, it must take into account the needs of
                                                                                                                                    safety testing procedures for products on the   GHS should not
                                                                                                                                    basis of not affecting classification. we are
                                                                                 its target audience, in particular consumers.
                                                                                                                                    in favour of a regulatory framework for         undermine consumer
                                                                                 We see the key issues that need to be              classification and labelling that does          confidence built
                                                                                 addressed in implementing GHS as four-fold:        not encourage such practices thus
                                                                                                                                    contributing to consumer protection.            through REACH.
                                                                                 1) GHS is a uniquely hazard-based system.
                                                                                                                                                                                    dave duncan,
                                                                                 GHS labels tell consumers to ‘Be Careful           4) Companies could be motivated to do more
                                                                                                                                                                                    Senior Vice President, R&D,
                                                                                 (this is a fire hazard)’ or ‘Be Careful (this is   animal testing as a way to ensure accurate      Unilever Home and Personal Care
                                                                                 corrosive)’ or ‘Be Careful (this could explode)’   hazard classification under GHS. This is
                                                                                 etc. That is important, but it is not enough.      a risk particularly where innovations are
                                                                                 Consumers want and need to know, OK,               concerned, including where new technology
                                                                                 so how do I be careful? What do I do to            is being developed to achieve step change
                                                                                 use this product safely? That is risk-based        improvements in areas such as sustainability.
                                                                                 information. That is, the hazard-based             we want to avoid any system that
                                                                                 system that is ghs must be married to              would result in increased animal testing
                                                                                 a coherent, risk-based information and             or raise artificial barriers to innovation.
                                                                                 labelling system to give consumers the             we support alternative approaches to
                                                                                 relevant information on the safe and               animal testing, and the use of human
                                                                                 effective use of products.                         experience data within a robust
                                                                                                                                    scientific approach to obtain appropriate
                                                                                 2) We are concerned that the classifications
                                                                                                                                    classifications for home care products
                                                                                 established under GHS are not discriminating
                                                                                                                                    and ensure consumer protection.
Consumer Confidence – Safe & responsible use of chemicals in everyday products




                                                                                 enough. For example, according to GHS
                                                                                 classification, a dishwashing liquid and a
                                                                                 laundry powder would have to carry the
                                                                                 same corrosive / eye damage symbol as
                                                                                 a drain cleaner and use a child-resistant
                                                                                 closure. Used in this way regardless of real
                                                                                 risk, ubiquitous hazard pictograms and / or
                                                                                 hazard statements in home care products
8
Our position in summary

Clear, effective, consumer-relevant communication


  Unilever is strongly committed to ensuring that its
  products are safe, properly labelled, advertised and
  communicated since we believe that consumers’ trust
  and confidence in our brands is vital to sustainable
  growth and success.
  We support the goals of the GHS to facilitate global
  trade and harmonise different legislative systems.
  We believe that responsible communication providing
  consumers with relevant information on the safe and
  effective use of products is crucial.
  We continue to promote partnership as a route to
  achieving our goals and believe that multi-stakeholder
  collaboration is required to establish practical
  guidelines for the effective provision of relevant
  consumer information.
  We are particularly concerned that new proposals
  could encourage animal testing in order to avoid
  over-classification. We believe animal testing should
  be discouraged by all possible means and not
  be required to avoid inappropriate labelling in a
  marketplace where the majority of products have
  a long history of safe and effective use.
  We support the establishment and use of expert
  bodies to ensure uniformity in classification and to
  minimise any animal testing requirements. There are
  models around the world that could be used for
  this purpose.
  We also support the establishment of coherent and
  co-ordinated monitoring of market experience to
  provide feedback and trigger any necessary updating
  of labelling on specific products.




                Designed and produced by Red Letter Design.
                Printed by Scanplus on paper made from responsibly managed forests.
Our H&PC
partnerships
Unilever’s Home and Personal Care business works in close        us high production volume chemicals programme
partnership with a wide range of research organisations,         – High Production Volume (HPV) chemicals are those which
trade associations and industry partners on safety and           are manufactured in, or imported into, the United States
environmental issues all over the world. Our partnership         in amounts equal to or greater than one million pounds
activities include:                                              per year. The HPV programme is a collaborative partnership
                                                                 whose goal is to ensure that the American public have access
hera – We are a founding partner in the Human and
                                                                 to the information they need to allow them to participate
Environmental Risk Assessment (HERA) project, a European
                                                                 in environmental decision-making at all levels: federal,
voluntary initiative undertaken jointly by the European
                                                                 state, and local. Since its inception in 1998, Unilever has
Soap and Detergents Industry Association (A.I.S.E.)
                                                                 actively contributed to making the programme a success by
and the chemical manufacturers federation (CEFIC).
                                                                 taking the lead on key ingredients which we manufacture
HERA is effectively a pilot of how targeted risk assessment
                                                                 and by providing safety data on other ingredients to our
can work within REACH, and has now expanded its remit
                                                                 suppliers. Many of the chemicals in the US programme
to risk communication.
                                                                 are also part of the global ICCA (International Council on
swim – In partnership with the UK sustainability                 Chemical Associations) and United Nations initiative on high
organisation, Forum for the Future and others, we have           production volume chemicals, which provide a screening
developed the SWIM (Sustainable Water and Integrated             information data set for 14 toxicological and environmental
catchment Management) principles and guidelines which            areas for these key chemicals.
have been used to evaluate and focus our current projects
                                                                 alliance for Chemical education – Unilever is a key
around the world. The principles are based on an integrated
                                                                 participant in the Alliance for Consumer Education,
approach to water management that balances competing
                                                                 a non-profit organisation whose mission is “to promote
demands for water with environmental protection.
                                                                 responsible and beneficial use of products to ensure a safer,
produCe – Piloting REACH On Downstream Use and                   healthier and cleaner environment in homes, businesses and
Communication in Europe is a strategic partnership led by        the community.” Its core programme areas are: Inhalant
Unilever and designed to test the workability of REACH in        Abuse Prevention, Disease Prevention, Poison Prevention,
a practical context involving suppliers, downstream users and    and Product Management. Unilever is primarily focused on
other stakeholders such as NGOs.                                 preventing inhalant abuse through education and other
                                                                 communication vehicles.
epaa – The European Partnership for Alternative Approaches
to Animal Testing is unique partnership between more than
35 companies from 7 different industry sectors and the
                                                                 If you would like to know more about these initiatives or
European Commission’s services. The EPAA was officially
                                                                 other Unilever social and environmental activities, please visit
launched in November 2005. Unilever is committed to the
                                                                 www.unilever.com/ourvalues/environment-society
elimination of animal testing for its business. We are heavily
involved in assessing new methods for health and safety
testing. To this end, we support a vigorous five-year action
programme seeking suitable non-animal alternatives.




                      Unilever Home and Personal Care
                      PO Box 68, Unilever House, Blackfriars
                      London EC4P 4BQ. United Kingdom
                      www.unilever.com

                      For more information, please contact:
                      alan.barber@unilever.com

				
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