Regulation in the Cosmetics Industry: Controlling our Diet for Food-Based Cosmetics

You are what you eat, or in the case for “clean” cosmetics, you are what you put on your body. But the original saying might still be apt, as more and more it seems like “superfoods’’ and naturally-derived ingredients have become a key selling point for beauty products and brands, especially from newer, smaller companies looking to compete with big beauty brands. Amongst Lush’s bestsellers, you’ll find shower gels infused with rose, lemon, and vanilla and bath bombs infused with lemongrass, avocado, and extra virgin olive oil. Gwyneth Paltrow has even gone so far as to eat fries dipped in her skincare company Goop’s skin cream to show that her beauty products are made with only food-grade ingredients. “Clean” cosmetics clearly have a big and growing audience. On major beauty retailer Sephora’s skincare bestsellers page, there’s an award-winning cleanser packed with kale, spinach, and green tea and a lip mask packed with an assortment of berries.

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However, just as loosely as “organic” crops are associated with health and sustainability, the benefits of these “natural” ingredients in cosmetics for our health and the planet’s health have thus far lacked any scientific backing. Unlike with food and agriculture, there is little to no regulation on the cosmetics industry; marketing is not regulated by the Federal Trade Commission nor is safety regulated by the Food and Drug Administration beyond the approximately 30 chemicals it has banned from being used in beauty products — a meager number compared to the more than 1,300 chemicals banned in the European Union. The nonprofit Environmental Working Group has tried to step in as a watchdog on the safety and efficacy front, pooling information on chemicals from toxicity and regulatory databases and providing ratings from 1 to 10, with 10 corresponding to ingredients with the greatest concern. I took a look at the list of 75 ingredients that Briogeo, a hair care company, uses in its products and found that only ten had a score of 1, while two had a score above 5 and 49 had a score of 0, meaning there was limited data available on its safety. Furthermore, in their best-selling product, Don’t Despair, Repair!™, only one of those ingredients with an EWG score of 1 even shows up in the first ten ingredients listed — ingredients are listed in order of predominance, with the ingredients used in the greatest amount first. Altogether, that makes it hard for me to take Briogeo’s word that their “clean care” and “healthy hair” promises also guarantee our personal well-being. But many critiques can be made about EWG scores, including the fact that lack of data on a chemical doesn’t equate it to poison, and an EWG score of 1 or 10 doesn’t automatically mean that an ingredient is safe or toxic, respectively, because the “dose makes the poison,” for both synthetic and natural ingredients.

Surprisingly, with the rise of consumer demand for “natural” and “safe” products, Vox reported that big beauty companies that are being forced to reformulate products have been trying to lobby the federal government for more funding and regulatory power to the FDA to test and oversee chemical safety and usage in cosmetics. They argue, and rightly so in some cases, that synthetic chemicals can be just as safe — at the right dosage, that is — and efficacious as their natural counterparts. That kale packed in the Superfood Cleanser I mentioned earlier, it definitely wasn’t just blended and strained. The most common extraction method for , the antioxidant on the product’s ingredient list, from kale is in boiling aqueous methanol, which can pose hazardous working conditions due to methanol toxicity.

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In the cosmetic industry’s rapid race to reinvent products with natural formulations, less attention has been paid to make transparent the environmental impacts of these products and new supply chains, from the sourcing of raw materials to their processing and the control of emissions and waste. One major highlight on sustainability that I found was Lush’s journey to remove and replace palm oil from their products. Granted, these strides by Lush were only taken after they received heavy push back by the public, and they have yet to remove it entirely from their products. They provide a great article explaining why palm oil is unsustainable, mentioning that while there are examples out there of good growing practices that incorporate palm, industrialization of the crop has led to massive deforestation and human rights abuses. Even “sustainable palm oil,” as certified by the Roundtable on Sustainable Palm Oil, is rife with controversy, as producers and processors can become RSPO members without having their operations accredited.

Remember Briogeo’s Don’t Despair, Repair!™ product I mentioned earlier? I tried to look up information on the environmental impacts of sourcing 1,3-propanediol from corn, the fifth ingredient on its list and the first with an EWG score of 1, and happily stumbled upon the European Commission’s page of environmental factsheets. For 1,3-propanediol, it provides a life cycle assessment, pointing out the environmental impacts associated with all stages of the chemical’s life: an environmental assessment, supplying numbers for its impact on things like climate change, ecotoxicity, land use, and a chart illustrating production chains (from both synthetic and natural sources). But the factsheets do leave much to be desired for a true comparison to determine what source of 1,3-propanediol is the most renewable. Here again is where funding for and intervention by a regulatory body to rigorously test chemicals and hold companies accountable in the US would benefit consumers and our planet, and even corporations (though possibly to the detriment of small businesses that have arisen from the “clean” cosmetics demand).

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For consumers increasingly concerned with safety and sustainability, the rise of cosmetics made from more natural and renewable sources reflects their power and influence. Now, it might be time for consumers to put that same pressure on the federal government. Several bipartisan proposals have been drafted by Congress, some even, like the Personal Care Products Safety Act, since 2015. But none have been passed with any tangible changes. While the EWG has been accused of fear mongering and misleading consumers on the safety of naturally-derived ingredients, the silver lining is that they have empowered consumers to demand transparency, safe products, and social and environmental justice from cosmetics companies.


Written by Kathleen Chen, PhD candidate at UCLA & guest author for Helikon



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Helikon Consulting

Scientific consulting in alternative proteins — plant-based proteins, cellular agriculture, and cell-based meat