A critical look at the 'clean' beauty movement
I hear so much noise around the topic of ‘clean’ beauty at present, in industry and beyond. From what I’ve observed, instead of listening to science, we’re accepting fallacies as facts. We’re increasingly confused about who reliable relevant experts are, about what sustainability means, and about product safety. This ‘clean’ movement is perpetuating a lot of self blame and fear onto the consumer. If you feel offended by this post, before chastising me for my tone, I urge you to question why you feel offended.
What do people mean when they say “clean beauty”?
‘Clean’ beauty is a marketing phrase that doesn’t have a set definition. When companies use this claim, typically they’re coming at it with the assumption that ‘clean’ products or ingredients will be better for you and better for the environment. Now, products that have less of an environmental impact need to be of the upmost importance, there’s no argument there. Sustainability matters, and so does product safety. However, the ideas presented within this movement are often so detached from reality, that, upon a bit more analysis, it’s pretty easy to spot. But first.
“These products are going to be safer for you”
The reality is, it’s illegal to sell unsafe products. While regulations around the world differ, in the developed world, this remains a constant. There are checks and balances in place to ensure your products will be safe. For example, ingredients must be rigorously safety tested. For potentially problematic ingredients, aggregate exposure at maximal consumer usage is taken into account when regulatory limits are set. E.g. Across the many products a consumer may use throughout the day, the potential for an accumulation of said ingredient between all the different products used (tested as if every product used has the problem ingredient at the highest allowed %). Moreover, limits set will be FAR below %s required to have a toxicological effect. Prior to launching finished products onto the market, manufacturers also must take steps to substantiate safety - through things like stability, challenge and skin patch testing.
When you look at various “clean’ standards” - Clean at Sephora, EWG SkinDeep Database, Think Dirty, Made Safe, etc - you’ll notice a trend. If the chemical sounds scary, or has already been fear-mongered, instead of looking at the body of evidence, they will seek out obscure, often dated, studies that support their agenda. E.g. small samples with poor methodology, studies where the ingredient is used in a way not relevant to cosmetics (e.g. ingested or injected at a higher level), or unreplicated outlier studies. I.e. cherry picking data to support an agenda - a red flag for pseudoscience. On the flip side ‘Natural’ ingredients will get a pass no matter the relevant safety data or allergenic potential. To add, they ignore the basic toxicology principle that the dose makes the poison. Anything can be a toxicant when used at a certain level or in a certain way. For example, you need water to live, but you can die from over hydration, you can also drown. It's the way the substance is used that will present the risk (hazard does not = risk). For example, your risk for drowning will be pretty low when you're drinking a cup of water. Same thing goes, and is generally ignored by these standards, for cosmetic product formulations.
An example of shady referencing via the EWG. When I first reviewed their methylparaben entry in my post A Case Against the EWG a few years ago, to support their claims around estrogenicity, they included the 2004 Darbre study; 20 individuals used, no control, only correlative results - a preliminary study that prompted a lot more research. Since then, there have probably been around 1000 studies published on the topic, and time and time again, research demonstrates safety. The body of evidence pertaining to parabens *as used in cosmetics* demonstrates safety. THAT’S the study they choose? In their references, they also included the Opinion on Parabens (2011) from the Scientific Committee on Consumer Safety (take-home, parabens as used in cosmetics are not demonstrated to be estrogenic in humans) - it appears they didn’t actually read as their take-homes were very different from the study’s conclusions. After publishing the post, I’ve noticed them change their references twice for this claim. Now they no longer use that 2004 study, seemingly after being called out on it, and landed on a review published in 2010, still a decade ago. They still include that SCCS opinion, and also the CIR Safety Assessment (which had similar take homes as the SCCS opinion, concluding that parabens, as found in cosmetics, aren’t estrogenic in humans) but only in sections where it fits with their dialogue.
Can regulations for cosmetics improve? Of course they can - and we should always be trying to do better (which will come by informing such decisions with scientific evidence). A common claim I hear in the ‘clean’ movement is that cosmetics aren’t regulated. That is patently false. But more on that in a bit.
Underlying this movement is an insidious culture of self blame. People feel enormous guilt when something bad happens to them or someone they know, e.g gets cancer or another sickness. There’s a perception that you can significantly impact these things by “positive energy” and “buying clean”, that becomes a bit of a feedback loop. Fear sells. Unfortunately, and I know this is a little uncomfortable to hear for many, a lot of these outcomes are out of your control.
For more on this, check out the #BeautyScience panel we did on the topic of Clean Beauty, featuring dermopathologist and dermatologist Dr Aegean Chan, pharmacist and cosmetic scientist Dr Anke Ginzburg and organic chemist Dr Michelle Wong.
“These products will be better for the environment.”
Here I find these statements are generally founded by assumptions and fallacies. For example, if it’s natural or, and especially, organic, there’s an assumption that it will be more “sustainable.”
Sustainable - lots of ways to look at this word, from more scientific via the Natural Step, to maybe easier to understand, via the Brundtland Commission. Ultimately it’s about doing things in a way that will be viable into the future if things continue as they are, environmentally, socially and economically.
Reality - being “natural” or “organic” tells us nothing about an ingredients safety or sustainability. Producing these ingredients can be hugely resource intensive. An easy example here is many essential oils. In the case of rose essential oil, to produce a single pound, you’d need in the ball park of 10,000lbs of plant material. With our growing demand for aromatherapy, how could this ever be “sustainable”? 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., for organic peas farmed in Sweden, they have roughly a 50% higher climate impact than conventionally farmed peas, or for Swedish winter wheat, closer to 70%. Here, I’m not saying ‘natural’ and/or ‘organic’ materials are never the ‘eco’ option - it’s just complex, and it depends on a lot of different factors. For example, are we allocating land solely to produce a cosmetic ingredient? Or is the ingredient derived from by-products of other industries?
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, where synthetic production produces far less green house gas pollution than it’s natural counterpart. E.g. The Symrise synthetic menthol production process generates 8kg CO2 per kg of yield, whereas the natural menthol production generates 50-100 kg CO2. Instead of using a lot of land for agriculture, we can produce these materials in a lab. And we’re not even talking about the exciting innovation happening in the biotech space.
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… but 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 (regardless of if the products are “clean” or not… and also, if a product has a shorter shelf life due to a less robust preservative system, the product waste there should probably be factored in).
Something that is often ignored within this movement is the progress happening across the whole industry. Because personal care is generally deemed as superficial and less important, there has long been external pressure on the industry to push us to do better. As a result, compared to other industries, we are often leading the way, and there are so many examples to highlight this. For example, despite the fact that we are only minor users of palm, especially compared to the food sector, we have led the charge to support the Roundtable on Sustainable Palm Oil. Similarly with mica, the Responsible Mica Initiative. With the regulatory changes to eliminate animal testing, we have developed high quality in-vitro tests to substantiate product safety instead, that will now be there for other industries to adopt. We’ve developed technology to help us better monitor our supply chains, and so much innovation in the biotech arena - which along side ingredients derived from other industry by-products, I personally see as a frontier for ‘greener’ products. This is something that makes me proud to be a member of the cosmetics sector. There’s obviously a lot more work to be done, but however your company is positioned in the marketplace, by default, we all need to be working to be more sustainable.
Here’s a video I did exploring the topic “Does Natural = Green?”
Here’s a podcast featuring Laura Market from Waste Free PhD, plastic researcher, on the topic of “sustainable” packaging - an immensely complex topic that is often over simplified.
Here’s our latest ‘Green Beauty’ panel discussion from Los Angeles, featuring Dennis Abbeduto, Perry Romanowski, Kenna Whitnell, Damien Periman and Laura Markley.
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.
Sorry but Yes, your cosmetic products are regulated.
As mentioned, there are a lot of misconceptions in the “clean” movement around regulations. Here are the top three myths I commonly hear.
The cosmetics industry isn’t regulated. In fact, there are a lot of regulations to comply with for all the different parties in the industry. E.g. ingredients have to be demonstrated to be safe & must adhere to specific purity standards. While regulations are different around the world, what's constant - it's illegal to sell unsafe products. Can regulations improve? Certainly. But that doesn’t mean they’re nonexistent.
Regulations in the USA haven’t changed since 1938. While the framework hasn’t changed, regulations are updated regularly. I find this claim particularly egregious because it’s just lazy. Look it up on the FDA website and see for yourself.
The EU has banned 1300+ of chemicals while the USA has only banned 11. Therefore USA products are unsafe! While the EU is more prescriptive with their regulations, the USA takes a more common sense approach - these aren’t ingredients companies would want to use anyway (e.g. rocket fuel), why ban them? Have you looked at ingredient lists of brands sold in the EU vs USA? You’ll notice - they’re generally more or less the same (aside from the listed allergens, something I would prefer to see in the USA as well).
Here’s a podcast featuring Nicholas Georges, Senior Director of Scientific and International Affairs for the Household & Commercial Products Association (HCPA) on upcoming USA Cosmetic Regulation Changes - we also covered the above points.
Improvements I would like to see in North America - required testing (stability, challenge and skin testing). While important to ensure safety, it’s not a set requirement here. There are a number of brands not doing the appropriate tests before they hit the market (they’re expensive). The safety concerns for products isn’t with the big guys, as is commonly fearmongered. It’s with the smaller brands that don’t have the scientific teams to ensure they’re taking all the right steps who are falling through the regulatory cracks (I am not saying “don’t support small brands” there’s a lot of excellent reasons to do so). Something that irks me - fear mongering marketing from brands that aren’t doing their due diligence to ensure their products are safe... or even compliant with regulations. The amount of mislabeled products I see from #cleanbeauty brands is alarming. If they can’t list their ingredients correctly, I can’t imagine they know how to substantiate safety.
Final thoughts…
In saying all of this, I’m not saying it’s wrong to make natural products, or have a brand that would fit in with the “clean” beauty stipulations. Especially with the misinformed marketplace we have today, it is very reasonable for a brand to e.g. opt not to use parabens. This is what consumers are looking for, and at the end of the day, brands have a business to run. But when you label your brand as “clean”, you imply to consumers that other products are “dirty”. This denigrating marketing strategy trains people not to trust science, encourages conspiratorial thinking around regulations, and it betrays trust across the whole industry. There are lots of examples of indie brands that would fit in with this movement but don’t make these claims, and even take an active stance combating misinformation - For example Stubborn Cosmetics, Jordan Samuel Skincare, Cheekbone Beauty. I would personally love to see more of this, rather than the constant flow of unethical and inaccurate fear marketing. To avoid writing a novel, I’ll end this post here, and leave you with a few more podcasts and e-panels in and around this topic.
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.
Here’s an interview I did on the podcast with Dr Christopher Labos about Talc Safety
Here’s an interview featuring Jonathan Jarry around what makes ‘good evidence’
Here’s an interview featuring regulatory toxicologist Dr Mojgan Moddaresio about Cosmetic Product Safety