Updated: Jan 29
Clean beauty demands use of nontoxic and safe ingredients, reducing environmental impact of formulation, and being transparent with ingredient labeling and product claims. But nontoxic and safe does not always equal all—natural and organic. And this is where our story begins.
Lead in lipstick, forever chemicals in dental floss, formaldehyde in Brazilian blowout, phthalates in nail polish and hair sprays, benzene in sunscreen... These are just some examples of toxic chemicals whose presence in our personal care products has been exposed in the past few years.
So it comes as no surprise that all—natural and clean beauty have been gaining exponential interest and support from the consumers who are looking for products that will not harm them and the environment. Consumers are becoming more informed and curious, asking questions about ingredient performance, origin, and safety, like never before. At the same time, retailers and brands are quickly picking up on consumers' cues, recognizing the importance of marketing cosmetics that aren't loaded with potentially harmful ingredients. The clean beauty sector is projected to grow to $22 billions in global sales by 2024. This is huge! So companies resistant to change will have to adapt or disappear. The push for all—natural is so strong that even some safe ingredients, like propylene glycol for example, get blacklisted and rejected by consumers. This trend is often met with frustration from some mainstream cosmetic scientists and industry experts who maintain that all personal care products and all synthetic ingredients are safe. The heated debate often boils down to all—natural vs. all—synthetic. Needless to say both sides of this argument are one sided as things are rarely black and white and this debate is more complicated than it appears.
In this post we will focus on challenges of all—natural movement and why all—natural is not all better. In the upcoming post, we will address the other side of the story: why insisting that all ingredients in personal care are safe and well—regulated is damaging and counterproductive, and what clean beauty really should be all about.
WHAT'S IN THE NAME?
All—Natural, Organic, Nontoxic, Clean...
The past few years have seen an explosion of new terms and claims used predominantly in natural and clean beauty space. These terms are coined by brands in attempt to satisfy and profit from the consumers' demand for better beauty. All—natural, nontoxic, clean, green, organic, hypoallergenic, free from... if you are into health and beauty, you've definitely heard them all. But, have you ever wondered what these terms actually mean and if they are regulated? Would you be surprised if I told you that many of them mean whatever a company wants them to mean? Due to lack of regulations in the US, many marketing terms and claims have no official definitions or mandatory testing criteria. Shocking? Yes. How is this possible? Mostly because FDA, FTC and other regulatory agencies in the US lag behind industry trends and consumer demands. And they often don't have resources and capacity to review large volume of potential cases and to enforce many regulations. But just because you can legally say something, doesn't mean you should. And this is where the issue with some all—natural brands begins.
To better understand the problem, let's look at the terms most frequently used and the meaning (or the lack of) behind them.
Claims and Their Meanings
All—natural, Natural, Made with natural ingredients
Currently there are no regulations for these terms, so a brand can use them any way they see fit. FDA has been working on defining the term "natural" since 2016 and we are still waiting for the results. So don't rush to make your purchasing decisions solely on seeing this term on product packaging. If all—natural cosmetics are important to you, look for verified third party certifications instead, like Cosmos Natural, Ecocert, or NPA Seal.
Clean, Nontoxic, Toxin—free
These claims are also not regulated by FDA. EPA regulates toxic chemicals, like asbestos, lead etc. but not in food or cosmetics. Shockingly, according to CPSC (Consumer Product Safety Commission):
"A product can be considered "nontoxic" if it kills less than 50% of lab rats it was tested on."
This sounds like a joke, but it isn't. FTC (Federal Trade Commission), which regulates advertising for cosmetics, OTC products, food, and some medical devices goes one step further by providing a reasonable guideline:
"Marketers who claim nontoxic product need competent and reliable scientific evidence that the product is safe for both people and environment."
This sounds good, but combined with CPSC definition of nontoxic, it leaves a lot of room for interpretation. Hence, brands have their own definitions and meaning behind these terms. This is less than ideal and can seem confusing and dishonest, even if it's not the intention of a brand.
Cruelty—free, Not tested on animals
Again, FDA does not regulate or define these terms, so brands can use them any way they like. The solution is to look for third party certifications, like Leaping Bunny, internationally recognized standard that ensures manufacturers don't do any animal testing and PETA Cruelty—Free bunny, which ensures no animal testing is done at any point in product cycle by manufacturers and also their suppliers.
According to FDA:
"There are no Federal standards or definitions that govern the use of the term "hypoallergenic." The term means whatever a particular company wants it to mean. Manufacturers [...] are not required to submit substantiation of their hypoallergenicity claims to FDA."
FDA has authority to require allergen labeling for food, but not for cosmetics. A 2017 study published in Jama Dermatology revealed that 83% of tested moisturizers labeled "hypoallergenic" contained one or more allergens. Hence, this claim, used by both all—natural and conventional beauty brands, can be pretty meaningless and misleading.
FTC states that "free from" should mean that a product contains only trace amount of substance, which was not added intentionally. And it is deceptive to claim "free from" if a substance is irrelevant for that product (ex. gluten free eggs, since eggs are naturally gluten free). This is a good definition, but again it is a guideline and no testing or substantiation is required to be submitted to FDA or FTC. A responsible company can decide to test this internally, and some large companies with the know—how and resources do conduct tests to confirm that manufactured product is for example "paraben free". But again, this is not required. The only way a brand might get in trouble is if they go too far with their claims and this catches the attention of FTC. In this case FTC may decide to do something about it and to make the brand rewrite or pull their claims. But this usually happens only to larger companies who make outrageous claims and only in some cases. Most of the time these claims go unchecked, especially in case of smaller brands, like many of those in all—natural space.
Organic, Made with organic ingredients
This term is actually regulated in the US. According to USDA, regulating body for organic products, product must contain at least 95% of organic ingredients (excluding water) in order to call it "organic" and to display organic label on packaging. And to claim "made with organic ingredient" a product must contain at least 70% of organic ingredients. In addition to USDA, some other organic certifications in cosmetics are: NSF seal, Ecocert, and Cosmos Organic.
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Taking all account, the issue of unregulated or misused claims is clear. Health—conscious consumers are looking for safer, more natural, ethical, and transparent products. But if claims used to attract this type of consumer are not regulated or without universally accepted definitions, they can actually lead to more consumer confusion and less transparency. While many brands in natural space do take their claims, ethics, and product safety seriously, some others will inevitably abuse the opportunity to differentiate their products and profit from marketing in natural space by using misleading claims with little meaning.
For brands: Just because you can legally say something it doesn't mean that you should. To build consumer trust, avoid generalized claims and vague wording. Focus on claims substantiated with real data instead of just using latest marketing buzz words. Brands need to always put transparency and ethics above misleading their consumers for profit. For consumers: Just because a product claims it's natural, free from, or clean it doesn't necessarily mean that this is true or that a product is safer or more effective than conventional products. When choosing a product, take a few extra minutes to read the ingredient list and scroll through a company's website. Good rule of thumb is: the more generalized and vague the claim, the less meaningful it is. Look for claims supported with real testing data.
SAFETY CONCERNS IN ALL—NATURAL BEAUTY
Does Natural Equal Safe?
The usual assumption is that if something is natural it is by default both safe and sustainable. But this is not always the case. When talking about safety, customers and even some smaller brands are often surprised when I tell them that high concentrations of certain natural oils, butters, or essential oils can cause skin reaction and sensitization.
Many consumers turn to natural personal care in attempt to use more gentle products and to avoid breakouts, skin reactions, and irritations. But you might be disappointed, as all—natural products won't necessarily be a better option for addressing these skin issues. In the US 5—45% of consumers report having sensitive skin. This includes those with atopic dermatitis, allergic contact dermatitis, and eczema, which can all be exacerbated by some cosmetic products. In proper formulation, which follows standard cosmetic safety and testing criteria, each ingredient natural or synthetic has its recommended and maximum in use concentrations that should not be exceeded in order to ensure a safe and non—irritating product. We cannot just mix bunch of oils, butters, and extracts at any level and expect them to be safe for all consumers.
Essential oils are one example of this as they can trigger allergic reactions, contact dermatitis, or eczema in sensitive consumers. One example is citrus—based oils, like lemon, orange, or bergamont, being phototoxic. This is why some brands, like Drunk Elephant, intentionally choose to avoid them completely. But some smaller, natural brands are unaware of these concerns. So they might overuse essential oils, formulate with levels that are too high, or go as far as claiming their many health benefits (which are both, outside of legal scope of cosmetics and often not supported by science). For additional natural ingredients that can be sensitizing, check out this list from Bryan Barron of Paula's Choice.
"We need to end the misconception that all synthetic ingredients are harmful and all naturally—occurring ingredients are non—toxic." Scientific American
Made In My Kitchen Story
Another consideration is that all—natural cosmetics often come from "homemade" or "made—in—my—kitchen" brands. Supporting small, local brands sounds like a wonderful and sustainable idea. Admittedly, it makes us feel good knowing that we are helping independent business owners. However, homemade products often lack important safety, micro—bio, or efficacy testing.
Micro—bio testing — This necessary test confirms that a product will be free from bacteria and microorganisms for the duration of its shelf life and use. With growing demand for all—natural products some brands skip using effective and much needed preservatives or skip this important test altogether. Nasty eye infections from insufficiently preserved eye makeup are just one example of what can go wrong here.
Efficacy testing — Another example of this issue is lack of efficacy testing that confirms a product will actually deliver its advertised benefits. This is especially important in OTC products, like sunscreens and hand sanitizers. When these products are formulated in a home setting without standardized efficacy testing and controlled manufacturing conditions, there is no guarantee of adequate SPF value, sun protection, sanitizing capacity, etc. In the best case, these products are a total waste of your money. In the worst case they can cause injury and harm — think sunburns, food poisoning, or covid transmission. Sorry Etsy sellers of all—natural sunscreens, but my advice to consumers is: Choose "homemade" when it comes to your pie, but run for the door when you see this label on a sunscreen or a hand sanitizer.
Choose "homemade" when it comes to your pie, not your cosmetics.
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To conclude, proper and science—based formulation, development, and testing of cosmetic products is imperative to ensure a product is safe and efficacious. This includes proper:
Package compatibility testing
Efficacy testing for claims and product performance
Yes, this is a lot! And it requires expertise and knowledge of cosmetic chemistry and industry regulations, as well as established relationships with manufacturers, raw material suppliers, and testing centers.
You may think that if a cosmetic product is on the market it must be safe. But while FDA regulates cosmetics, they do not require any product or ingredient safety testing to be performed or safety data to be submitted to them (the only exception are color additives and OTC products, which do require FDA approval). More about that here. Hence, it is brands' responsibility to ensure their products are properly tested and safe. And this includes any company or individual who manufacture or market cosmetics.
Many small, all—natural, homemade brands unfortunately fall short here, as they often don't have the know—how and the resources to conduct all proper testing. Even though this is usually not due to malicious intentions of the brand, it is an important criteria to take into account when shopping all—natural.
Proper, standardized formulation, testing, and manufacturing of cosmetic products is imperative to ensure they are safe and efficacious. Many small, all—natural, homemade brands don't have the know—how or resources to conduct proper testing.
MISSING OUT ON PERFORMANCE
Brand dedication to all—natural ingredients can also be very self—limiting, especially when formulating high performing, innovative products.
Number of available naturally—derived ingredients is much smaller (approximately 10 times smaller) than number of available synthetic or lab—made ingredients. So the choice is more limited by default. This is the reason why all—natural products can sometimes give inferior sensorial experience and performance compared to conventional products. It is simply more difficult to formulate and achieve certain product attributes with only natural ingredients.
More importantly, there are many completely safe and even more sustainable synthetic ingredients that have some pretty impressive safety and performance profiles. Hundreds of material scientists and innovative raw material suppliers work diligently to bring us these novel ingredients. There are companies like Geltor, which produces high—performing biodesigned cosmetic ingredients, Ginkgo BioWorks, which uses fermentation to make more sustainable fragrance ingredients, and many others.
In addition, many naturally occurring ingredients can now be synthesized in a lab. This means that often we can produce identical ingredient to the one found in nature but in a more efficient, sustainable way. One example is menthol, an ingredient with a huge demand that cannot be met with menthol naturally—derived from mint plant. Hence, BASF and Symrise produce synthetic menthol which is nature identical, but obtained through sophisticated, more sustainable processes that result in higher yields and lower carbon dioxide emissions.
Lastly, many synthetic ingredients are derived from natural sources, but because they are synthesized in a lab and not plucked directly from a plant, they are technically synthetics, albeit naturally—derived.
By insisting on all—natural ingredients only, we eliminate many useful, safe, high performing, and sustainable lab—made materials.
Good For Me Or For The Environment?
Supporters of all—natural beauty often feel strongly that natural ingredients are better and healthier for our skin and also more sustainable and ethical for the environment. While there are many beautiful natural ingredients that are highly effective, safe, and sustainable, there is no denying that growing some natural ingredients for cosmetic use can be very bad for the environment.
Take the example of essential oils. For 1 ounce of rose oil, 625 pounds of rose petals are needed! This is insanely low yield. Essential oils are a resource intensive product, from the amount of land used to grow the plant to the amount of water and energy used to process the plant and get the final ingredient. And some essential oils like sandalwood and rosewood are also on the threatened species list. As Anjanette DeCarlo, an environmental scientist, told The New Yorker: “If the demand keeps up without proper controls, we risk causing an ecological crash of a rare and endangered ecosystem.”
Another example is squalene oil, skin identical ingredient and cosmetic superstar. It used to be extracted from shark livers but due to ethical and environmental issues today we produce squalane (squalene's cousin) in a lab, through fermentation from sugar beets. Win for our skin and win for the poor sharks.
In summary, earth's resources are finite and overexploiting them comes with grave consequences. As Perry Romanowski, of Chemist Corner noted:
"Ethical dilemma of using scarce farm land for growing cosmetic crops instead of food, the increased cost of the products, or the large land footprint needed to make tiny amounts of natural ingredients, and you’re left with the question of whether natural cosmetics are actually ethical."
As we see, the belief that all—natural is always better is flawed. And at the same time, the pressing need for more responsible and evolved cosmetic industry standards that demand safe ingredients and products is here to stay. So, as always the solution is somewhere in the middle.
We need to shift focus from whether ingredients are natural or synthetic and focus instead on using only ingredients that are high—performing, truly sustainable, and most importantly, confirmed to be safe for relevant applications.
And to clarify, safe ingredient means that there are no science—based safety concerns at any concentration used in cosmetic formulas, for any relevant exposure routes (mostly skin absorption and inhalation) while also taking into account additive exposure through multiple and realistic product use.
This makes rethinking and defining what clean beauty is ever more important. If we can collectively agree on definitions and set criteria behind these terms, it would benefit all. Brands would be more transparent, honest, and science—based, hence earning consumer's trust. Cosmetic formulators would have clear, science—based set of expectations and criteria to help them do their job without frustration. And this would also reduce consumer's misinformation and panic caused by fear—mongering marketing strategies and dishonest use of ill—defined marketing terms and claims. More on this in our next post on What Is Clean Beauty?
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