Certifying 'Sustainability' - Positive Progress? Or a Participation Trophy?
Clearly misinformation frustrates me. The misinformation presented by the cosmetics industry on the topic of sustainability though takes the cake. At conferences intended for scientists, it seems often the takeaways are based around fallacies that make for good marketing rather than sound science. It’s a rare occasion when sustainability panel presentations actually include a scientist with a background in sustainability. This ends up causing distraction from legitimate issues, and prevention of progress that will actually make products more sustainable.
This post is a response to Amyris’ and Cosmetics Business' latest webinar on sustainable and clean ingredient sourcing. Below were the key take homes, this post will breakdown why I don't think they have any basis in reality.
The cosmetics industry is hardly regulated, this is why certifications are so important.
EcoCert & Cosmos are the best standards to legitimize sustainability claims.
Ingredient sourcing should focus on a removal of petroleum and GMO derived ingredients, with a focus on clean sourcing via nature, particularly from ‘organic’ certified agriculture.
Consumers reward brands who value sustainability by sourcing “clean.” (well, this one is a reality - my thoughts below)
Shout out to Dr Annika Pille and Jaana Ailus for reviewing this article prior to us posting! Thank you for your support with your feedback!
Thoughts on point 1, The cosmetics industry in the USA is hardly regulated, this is why certifications are so important.
This point was made by Indie Lee to describe her journey as a brand founder. The idea that the USA cosmetics industry is hardly regulated is a gross overstatement. While the North American regulatory framework is different from the EU, taking a more common sense approach rather than the prescriptive approach. The end implications for both markets are the same; it’s illegal to sell unsafe products. As an example, while the EU chooses to ban ingredients that have never and will never be used in cosmetics (such as rocket fuel), the USA doesn’t ban ingredients not being used - hence the huge difference in the number of banned ingredients. While the EU requires specific steps to be taken prior to launching a product onto the market, the USA uses an expectation that these steps will be done because that's what's required to substantiate safety. If you choose not to complete these steps (e.g. stability/PET/skin irritation testing) and have a consumer complaint where regulators come check on how you substantiated your products safety? Chances are that you're going to take a huge financial hit, there’s a good chance your business isn’t going to be able to survive. There are also areas where cosmetics are more strongly regulated in the USA market compared to other markets - for example, color additives and sunscreens.
Can USA regulations improve? They most certainly can (just like every market, including the EU). But the ways they can improve to support safer products isn’t going to be in the way that consumers expect they will. For example, requirements on specific steps to be taken prior to launching a new product - specifically with safety testing. While these steps are technically required in the USA, because they’re not spelled out, there are an astonishing amount of smaller brands not completing them (side note - smaller brands are often founded by people with no relevant expertise in the industry, often with bold claims about revolutionizing the whole market with their brand - this in general should be doubted). Regulation improvements in this way aren’t going to change anything for the bigger players in the industry - they are most certainly already doing their due diligence here. It wouldn’t make economic sense for their business not to. Considering the threat of a class action lawsuit - safety testing isn’t THAT expensive for them, especially compared to how a lawsuit can impact their reputation (disclaimer! Losing class action lawsuits doesn’t necessarily mean the company is guilty - jurors are generally not scientists, and outcomes sometimes go against what the body of scientific evidence says. Case in point, J&J’s baby powder. The body of evidence does not support the idea that their product increases risks for ovarian cancer. Pulling out of the North American market is more cutting their losses than anything - their talc baby powder is still alive and well in Europe). The real safety issues in the United States are with the smaller brands that don’t have the scientific teams to understand the current regulatory framework or what is required to substantiate safety. It will be these brands that these regulations will impact most.
Note, there are many small brands that do an excellent job complying with regulations and seeking out appropriate help. Part of the work I do as a consultant is curate brands for stores to ensure the products are meeting regulations. It’s truly horrifying how many small brands are doing incredibly sketchy things - zero preservative efficacy testing, putting unstable products onto the market that go moldy on the shelves, very obviously not listing the ingredients in their product formula. If you want to support small brands, my suggestion to you would be 1) familiarize yourself with labelling regulations. If brands can’t comply here, chances are they’re cutting corners elsewhere. 2) don’t be afraid to ask a brand how they’ve substantiated their products safety. No, choosing “all natural” ingredients isn’t a good answer here.
Thoughts on point 2 - EcoCert/Cosmos are the best standards to legitimize sustainability claims.
First, what does an EcoCert/Cosmos certification entail? Here's what their website says.
EcoCert/Cosmos’s core tenants:
environmentally friendly production and processing processes respecting also human health, development of the concept of green chemicals
responsible use of natural resources
respect of biodiversity
absence of petrochemical ingredient ( except for authorized preservatives): parabens, phenoxyethanol, perfumes and synthetic colorants
absence of GMO
recyclable packaging
For certification, you have two options:
COSMOS Natural - All the ingredients are from natural origin except a restrictive approved ingredients list (including preservatives) authorized in small quantities.
On average, Ecocert certified products contain 99% ingredients of natural origin.
COSMOS Organic - 95% minimum of the plants it contains are organic, At least 20% of organic ingredients are present in the total formula (10% for rinse-off products).
There are a few things I quite like about EcoCert/Cosmos. I like that they check in on manufacturing carbon footprint reductions. I also like their requirements for better supply chain management, and their packaging stipulations as well. When it comes to sustainability, this is obviously really important. With that said I strongly disagree with the rest of it. To start their no-no list (parabens, phenoxyethanol, perfumes and synthetic colorants); each has strong empirical data (especially compared to some of their “clean” alternatives) to support safety, including for the environment, as used in cosmetics.
I completely disagree with their stance on ‘GMOs’ - there is an overwhelming amount of scientific support for genetic engineering. Their ability to reduce the environmental impacts of agriculture + enhance the agricultural products we produce (better nutrient quality is potentially lifesaving depending on the nutrient and market - better longevity of produce - less food waste, etc). They are certainly not a panacea. But they are an important tool in the farmer’s (and ingredient innovator’s) toolkit to produce food/materials more sustainably. EcoCert/Cosmos’ certification looks to take this tool away with no evidence to support their beliefs. Looking at the impacts these certifications have, and the ideologies they perpetuate - “organic good, gmos bad” - These beliefs have an impact that reaches far beyond the cosmetics industry (e.g. impoverished farmers and communities by preventing them from accessing literally lifesaving resources). It’s hard to not feel that these stipulations are beliefs that come from privilege and ignorance. Genetically engineered organisms have been used for many ingredient innovations in cosmetics with well demonstrated safety data and environmental impact reductions. For example with Genomatica’s Butylene Glycol which uses a GE biocatalyst (not found in the end product) in the fermentation of sugar, they have demonstrated a 50% carbon footprint reduction when compared to the traditional production of butylene glycol. Unfortunately, because of their use of that GE biocatalyst, they would not be approved by EcoCert/Cosmos. It was a similar story for DuPont’s Propanediol - originally OK in EcoCert, but not anymore with Cosmos. If the goal is to move the needle on sustainability these certifications should challenge the public’s concepts of these complex technologies, but instead they seem to leverage the fear of the unknown to appeal to a broader audience. Marketing 101.
Moving on from GMOs, the emphasis on “natural” and especially “organic” needs some strong consideration. We know that to reduce the environmental impact of agriculture, we need to use as little land as we can. Today, agriculture is the biggest driver for biodiversity loss. Moreover, practices that require more land demonstrably may have, on top of a larger impact on biodiversity, higher CO2 emissions compared to other agricultural styles, thanks to deforestation. For e.g., organic peas farmed in Sweden have roughly a 50% higher climate impact than conventionally farmed peas, or for Swedish winter wheat, closer to 70%. Not to say ‘natural’ and/or ‘organic’ materials can’t be the ‘eco’ option - it’s just complex, and it depends on a lot of different factors. For example, in the cosmetic industry, are we allocating land solely to produce a cosmetic ingredient? Should we really prioritize using land exclusively for the cosmetics industry? Or is the ingredient derived from by-products of other industries? Say, for example those GMO crops that may actually have a lesser environmental impact to begin with?
Sometimes choosing “synthetic” is the more environmentally friendly option. Look no further than the vitamins used in cosmetics. You would need A LOT of plants to produce l-ascorbic acid for the industry. So to make things more viable, we produce it synthetically. Another example - menthol, synthetic production produces far less greenhouse gas pollution than it’s natural counterpart. The Symrise synthetic menthol production process generates 8 kg CO2 per kg of yield, whereas natural menthol production generates 50-100 kg of CO2 per kg. Instead of using loads of land for agriculture, we can produce these materials in a lab. Alternatively, you could look at synthetic fragrances, a no-no ingredient with EcoCert/Cosmos, compared to essential oils. Many essential oils are hugely resource intensive (e.g. it takes about 10,000 lbs or rose to produce roughly 1lb of essential oil), and in many cases, a synthetic fragrance will be far less impactful to the environment. I’m also not sure about the stance on petroleum derived ingredients in general… But more on that in a bit.
While well-intentioned, I’m personally of the view that this certification/standard is counterproductive and ends up leading to more confusion on the topic of “sustainability.” Based on the scientific evidence we have on many of the points above, I think that EcoCert/Cosmos ultimately slows or prevents real progress that will allow our industry to actually move forward. Unfortunately, I know this isn’t a comfortable conclusion. Most people want a stamp of approval to make them feel good about their purchases, I don’t think the industry has a single good “eco” standard (much the same as other industries - look no further than the “eco” H&M clothing). Each one that I’ve reviewed is fraught with the above fallacies entrenched in their certification practices. Also, just like fast fashion, there is “fast beauty,” and green/natural companies are no better at this; launching new products each season, tons of skus, and limited edition skincare… the list goes on.
Thoughts on point 3 - Ingredient sourcing should focus on a removal of petroleum and GMO derived ingredients, with a focus on clean sourcing via nature, particularly from ‘organic’ certified agriculture.
I’ve already looked at GMOs and natural ingredient sourcing, so in this section, I’ll focus on petroleum derived ingredients. Yes, these ingredients are derived from the oil sector. There is no question, we need to move away from burning fossil fuels for energy production. But the most important consideration here is there’s no petroleum sourcing with the intent of making cosmetic ingredients. The ingredients are developed from by-products the oil sector is creating anyway. From a sustainability perspective, the reuse of a waste material from the oil sector may prevent harvesting and/or production of other materials, and might actually have a lower environmental impact - for now at least. As long as the oil sector continues to fuel our society, these by-products will exist, with or without the cosmetics industry using them. This doesn’t mean oil production is sustainable - we obviously need to find other ways of producing ‘greener’ energy. But we also shouldn’t fall into the trap of perceived sustainability.
This is an incredibly complex topic, but if you think using land for the sole purpose of producing cosmetic ingredients is more sustainable, I would question that. Also, don’t be disillusioned into thinking that petroleum isn’t used to produce natural ingredients - from tractors to trucks to the extraction and refinement processes. Making something useful from a field is going to need a lot of energy, and today, unfortunately gas is the easiest way of producing that energy.
Finally, Vaseline/petrolatum is considered an OTC drug in the US - it’s the gold standard occlusive, not likely to cause skin reactions even for the most sensitive skin. It has great skin protection/supporting benefits, especially for people who have various skin conditions, and it’s affordable. There’s a reason dermatologists so frequently recommend it, or products with petrolatum. With this fear mongering towards petroleum derived ingredients, there’s the potential of people going against their doctor's recommendations for skin protection, using Cosmos certified balms with essential oils on damaged skin that may exacerbate their skin conditions. And to make this gold standard product? Again, it’s produced from by-products of the petroleum industry. To reiterate - there is no petroleum sourcing with the intent of producing cosmetic ingredients.
Thoughts on point 4 - Consumers reward brands who value sustainability by sourcing “clean.”
This is why consumer education and better science communication is crucial. Consumers want to support sustainable practices, of that there is no doubt, but right now, there’s so much mixed messaging as to what will actually have improved sustainability. This should be a call to more scientists in the cosmetics industry to get involved with science communication online.
This also means that there should also be a responsibility for brands. If a brand is invested in trying to make their products more sustainable, and is making sustainability claims, they should make serious efforts to substantiate these claims and try and evaluate their efforts in an objective way. All too often though this work is not reflected back in boosted sales and a simple sticker or certificate they can pay for is a far more effective return on investment.
Uncomfortable side note - We can’t just flick a switch and be sustainable. ‘Sustainable’ is a moving target. We can only strive to be more sustainable. As we know better, we can continue to do better.
Some food for thought on the impacts of consumerism; The overwhelming evidence demonstrates that globally, growing consumption has diminished or cancelled out any gains brought about by product innovation aimed at reducing environmental impacts. Of course, this is a huge topic. With how we measure economic success, the GDP, at the heart of it. At the end of the day, for the average person - if you want to reduce your impact on the environment with your cosmetics, I would personally suggest buying only what you need and what you’ll actually use, try to reduce your purchasing in general ("I trashed all my unsustainable products" shouldn't be a trending YT video topic). For all the “clean” and “green” brands that have SO MANY different skus to sell you, encouraging that idea that you need a bunch of different products in your day to day routine, it encourages the FOMO that many of us feel about skin care products.
During the presentation I asked the question: “does sourcing natural and organic ingredients by having a transparent supply chain and ethical treatment of workers mean the ingredients will be sustainable?” Their answer - of course. Here they made the point that, while the environmental impacts were important, the social impacts are equally important.
When you think about sustainability, ultimately it’s about doing things in a way that will be viable into the future if things continue as they are, with respect to the economy, our society and the environment (the three pillars of sustainability). For more detail on sustainability,I highly recommend looking at the UN SDG goals, as well as the Natural Step Theory. The answer I was given here is in reference to the overlapping circles model of sustainability, which acknowledges the intersection of the economy, society and environment. However, this model implies that the economy and/or society can exist independent of the environment - in other words, the parts of those circles that don’t overlap with the environment can exist on their own (They can’t. The environment can though).
A better model for sustainability is the three-nested-dependencies model, which reflects the co-dependent reality. Without food, fresh air, clean water, natural resources, fertile soil, etc - re, the environment, society and economy cannot survive.
Yes, social impacts of industry are extremely important. We should be constantly striving to produce in a more ethical way. But social impacts just can’t be as important as our impacts on the environment. First we need to figure out what are the steps needed to reduce our environmental impacts - which we can only arrive at with unbiased scientific substantiation. Second, we need to figure out how to move forward with this knowledge, with lower environmental impacts, in a more ethical and transparent way. Put bluntly - if the environment is fucked, so is our society and economy. We can still survive as a species, just as long as our environment remains viable.
Conclusion
Ultimately, when we’re talking about the sustainability of ingredients, “synthetic” or “natural”, it’s a case by case basis. Striving to be more sustainable is something I’m very passionate about. If we want to do better here, we have to inform our decisions with evidence. Instead of making assumptions, we need substantiation. And then there’s the elephant in the room - the easiest way to have a more ‘sustainable’ skincare routine? Buy less, use less, waste less. To avoid writing a novel (if I haven’t already), I’ll end this post here and leave you with a few relevant e-panels, videos and podcasts we’ve done on the subject to bring, hopefully, a bit more clarity..
Here’s our latest sustainability e-panel, featuring Dr Micheal Fevola, from the ingredient innovation perspective, Nick Gilbert, from the perspective of the fragrance sector, Laura Markley, from the perspective of a plastic pollution researcher, Dr Mariana Royyer, from the perspective of a bioextraction expert, and Liah Yoo, from the brand founder perspective.
Here’s a panel discussion we did on agricultural sustainability, featuring Dr Rene Van Acker, dean of the Ontario Agricultural College at the University of Guelph, and Dr Kevin Folta, Horticultural Researcher at the University of Florida.
Here’s a video featuring Dr Michelle Wong, Dr Aegean Chan, Lalita Iyer, Charlotte Palermino, Dr Anke Ginzburg, Dr Cyrille Laurent, and James Welsh, asking the question - is “clean” beauty pseudoscience?
Here’s a panel I did with Dr Anke Ginzburg, Caroline Hirons, Dr Anjali Mahto and James Welsh on misinformation in beauty, and how not to be a part of the problem.
References:
Opinion on Parabens (2011) from the Scientific Committee on Consumer Safety
Opinion on Phenoxyethanol (2016) from the Scientific Committee on Consumer Safety
2019 CIR Safety Assessment on Parabens
FDA Cosmetics Guidance & Regulation
Health Canada Safety of Cosmetic Ingredients
Technical report 126 Cosmetics ECETOC