SUSTAINABILITY


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technical perspective, presenting limitations in stability, functionality, and aesthetics. It is important to consider the fundamental physiochemical properties and molecular interactions of specific ingredients within the base formulation.


Environmental fate The impact of personal care products extends beyond their use. Ingredients frequently enter wastewater and can be found in rivers and seas. Environmental harm is a key consideration, complicated by the fact more is being discovered about ingredients that previously thought benign. Intentionally added microplastics are already being phased out in Europe and per- and polyfluoroalkyl substances (PFAS) are now in the spotlight. The ability of a formulation to biodegrade, and the speed at which it happens, is a central consideration of sustainable design. On the face of it, naturally sourced ingredients would appear to have the advantage here. However, naturally sourced can mean many things: natural extracts are likely to biodegrade but modified natural ingredients may not. The situation becomes more even complex when naturally sourced ingredients are blended into a formulation and layered with synthetic ingredients. Clarity is needed on the biodegradability of full formulations, including the conditions and timeline under which biodegradation is achieved. An assessment matrix is a useful tool to


ensure all necessary factors are considered when interrogating ingredients’ sustainability credentials (Table 1).


Regulatory strategy: navigating volatile and inconsistent global regulations The regulatory landscape for sustainability is developing fast, bringing implications for products and their ingredients. Evolving, and often conflicting, regulatory requirements are at play in most supply chains. Various frameworks


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are also under development within government bodies and industry groups. The UN Environment Programme is


developing a green and sustainable chemistry framework which could provide a central pillar of chemicals regulation or good practice. Meanwhile, the European Commission’s safe and sustainable by design framework aims to encourage the commercialisation of new chemicals, optimisation or redesign of production processes, and reconsideration of existing substances. It is described as a holistic approach integrating “safety, circularity, energy efficiency and functionality of chemicals, materials, products, and processes throughout their life cycle and minimising the environmental footprint.” In the US, green and sustainable chemistry is the core focus. An example of engagement with this is Walmart’s Sustainable Chemistry Commitment, embracing the 12 Principles Of Green Chemistry and laying out what is expected from suppliers. The road to safer, cleaner, more sustainable


products relies on good information about the impact of those products and their constituents on human health and the environment. This is a potential minefield, requiring extensive knowledge across hundreds or even thousands of substances and processes, as well as tools to synthesise the data. Use of some substances has been declining


for years, often due to the introduction of regulations restricting their use. However, new matters can surface with little forewarning, requiring urgent attention. Plastics pollution is one such area. While


concern has been building for some time, recent regulations encouraging reuse are accelerating change, forcing innovation and the need for engagement. Regulatory restriction on intentionally added microplastics is affecting many personal care products. In the EU there is a timeline for the removal of these ingredients which can cover a wide range of functions such as opacification, rheology modification and emulsification.


Another critical area of focus is PFAS, so-


called ‘forever chemicals’, used in numerous applications and technologies across sectors. A new EU restriction for some PFAS types is imminent, and while requirements haven’t yet been fully defined, they need to be considered in product design.


Sustainability claims In addition to regulations that impact ingredients, personal care companies need to be aware of restrictions and requirements related to environmental claims. This is a volatile area, with authorities mounting efforts to address greenwashing and check claims’ authenticity. In March 2023, the European Commission


adopted a proposal for a Directive on Green Claims to address greenwashing and protect and empower consumers. The UK’s Competition and Markets Authority (CMA) has also announced its intention to scrutinise household products for potential greenwashing and is already enforcing its Green Claims Code. Meanwhile, in the US, ‘Green Guides’ for the use of environmental marketing claims are being updated to help companies avoid misleading statements. It is advisable to document the rationale for


sustainability-led design decisions and make certain that claims can be fully substantiated. This can also be advantageous when it comes to involvement in certification programmes like the US EPA’s Design for the Environment initiative.


Conclusion Evaluating and managing tensions between performance, ingredient science, and regulatory strategy is vital for the design and development of sustainable formulated products. This is not a linear process. It requires ongoing attention as sustainability parameters often conflict and may evolve due to wider changes such as regulatory developments. There are no perfect solutions, but with so much at stake it is worth striving for the best possible outcomes.


PC October 2024 PERSONAL CARE


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