32 NATURALS


pose a health or environmental risk, then the precautionary principle will be applied, and it will not be allowed. For this reason, the following are not allowed: Nanomaterials, Genetically modified organisms (GMOs), Gamma and X-ray irradiation.


l The users of this Standard are expected to comply with all relevant legislations. E.g. in Europe, Regulation on cosmetic products (EC 1223/2009) requiring cosmetic safety for human health, Regulation on claims in cosmetic products (EU 655/2013) requiring truthful, not misleading and substantiated claims. For organic products, an important


regulatory text is [EU] 2018/848 on organic production and labelling of organic products in its section 28: “As organic plant production is based on nourishing the plants primarily through the soil ecosystem, plants should be produced on and in living soil in connection with the subsoil and bedrock. Consequently, hydroponic production should not be allowed, nor growing plants in containers, bags or beds where the roots are not in contact with the living soil”.12 Brands and retailers can extend the


basic meaning for their products, and Natural beauty can encompass various considerations (Table 1).


Clean beauty At its core, Clean Beauty is about safety for human health. Cosmetic product safety for human health is a must around the world and manufacturers are responsible for ensuring the safety of their products. Despite the lack of regulatory harmonization, it is a clear requirement, e.g.: l USA: The Food, Drug & Cosmetic Act (1938) prohibits the marketing of adulterated cosmetics. A cosmetic is considered adulterated if: “It bears or contains any poisonous or deleterious substance which may render it injurious to users under the conditions of use”.13


The


FD&C Act requires that every cosmetic product and its individual ingredients be substantiated as safe for the intended use. The FDA leaves the safety testing methods up to the discretion of the cosmetic company but provide guidance.14


Table 2: Clean Beauty focus and extended considerations Focus


And...


Absence of: harmful to the health ingredients, controversial ingredients, harsh ingredients, allergens, endocrine-disrupting chemicals, potential carcinogens (No-No ingredient lists, no “nasties”)


Safety for human health in conditions of use


Absence of synthetic preservatives Self-preserving cosmetics Skin microbiome friendly products Provide expected Efficacy and sensorial properties Substantiated claims (science-based evidence)


Simplified formulas, removing unnecessary ingredients: doing more with less Biocompatibility with the skin Cruelty-free / Not tested on animals Label transparency Manufacturing quality standards (e.g. GMP) Gluten-free


have undergone an expert safety assessment. It includes essential data about toxicological profile, microbiological quality, compatibility between contents and container, and shelf-life.11 Even though safety is a must with


regulatory requirements, there is no common confirmed definition of clean beauty, and brands and retailers have extended “cleanliness” to other related considerations, in particular heightened concerns about safety with what is considered controversial or potentially harmful to people health ingredients. This particularly resonated in times of the COVID-19 pandemic:17


I consider “clean” beauty a niche market instead of a necessary standard? It is increasingly hard to argue with a precautionary approach to safer cosmetics when protection from the coronavirus is entirely predicated on precaution. COVID-19 reinforces the fact there is so much we do not know - and may never know - about health and the human body. It reminds us that science is not static, and standards need to change when science does (remember when we were not supposed to wear masks?)”18


. For the FDA, shelf-life is part of


the safety requirement. Largely unchanged since 1938, a bill, Safe Cosmetics and Personal Care Products Act has been introduced in 2019 that would require companies to make sure their products are safe for consumers before they hit the market.15


l EU: Regulation 1223/2009 requires that: “A cosmetic product made available on the market shall be safe for human health when used under normal or reasonably foreseeable conditions of use”.16


To demonstrate compliance, a cosmetic must PERSONAL CARE NORTH AMERICA


This must be felt by a large number of consumers as during the pandemic, sales of clean beauty prestige products grew by 11% when other high-end cosmetics plunged by 14% (NPD Group research). The clean beauty movement has been embraced over the years by both brands and retailers with a similar extended focus19 few: BeautyCounter,20 Co.,22


Goop,21 Sephora,23 Detox Market,26


Target,24 Follain,27


, and to name only a The Honest


Credo Beauty,25 . Each proponent has


developed their own short list of ‘bad’ ingredients, the majority falling into 3 major categories:28


general agreement seems to imply that a clean beauty product has been developed with a heightened sense of safety for consumers, and avoiding the use of some


growing concerns with endocrine-disrupting chemicals,29-31


irritants or allergens, general and potential carcinogens. The


“bad actor” materials as well as unnecessary ingredients (Table 2).32


“How can


Green beauty At its core, green beauty is about sustainability. It is a must for a continuously growing number of consumers and for Naturality. It can be simply defined as the evaluation of the future impact of cosmetic products presently developed, and not only the products but also the way they are being produced with ingredients which must be traced. Typically, green is related to environmentally-friendly marketing claims and, in the US, general guidelines for the use of such marketing claims have been published by the FTC.33


Although


the two words are often used interchangeably, sustainability takes the notion of green to the next level.34


Sustainability is a multi-dimensional


consideration in the entire product life cycle. It encompasses not only the environmental, but also the social and economic aspects, i.e. the 3 pillars, for a positive impact on society.35


It has a


holistic approach on product life cycle: starting with sourcing and extraction of ingredients, then formulation and manufacturing of finished products, packaging, distribution and finally ending with consumer use and post-consumer phase.36


progress in all areas,37


Being a sustainable brand is a work in up and down the supply


chain, from vendors to brands. The collective consciousness on sustainability is rising and faster than most would have expected during the COVID-19 pandemic:38,39


“While the


COVID-19 crisis has drastically changed the current state of our world, its future remains in the balance making beauty brand’s efforts to be more sustainable all the more critical. The need to treat each other and the planet with kindness is now”.40


With the growing


knowledge and awareness from consumers about sustainability issues, they are demanding from the industry to address their expectations for sustainable beauty products and be accountable for their product design and practices. The pressure to move in the direction of more sustainable patterns of


October 2020


Clean Beauty


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