The cosmetics industry is dynamic, evolving as new and varied needs of industry, society, and most recently, the planet, conjoin to influence its next stage of evolution. A regulatory baseline and steadfast commitment of the cosmetics industry are to deliver safe products, and be in a position to support their safety to protect consumers. Nevertheless, during the past decade, there has been increasing scrutiny surrounding cosmetic ingredients – whether associated with consumer health or environmental impact. In particular, due to perceived health issues, the presence of certain substances, notably parabens, has become undesirable by some consumers. Consequently, to facilitate consumer communication, brands had turned to claims that emphasise the absence of these ingredients as a means either to differentiate or to maintain their products on the market. These so-called ‘free from’ claims align with a perception of improved product safety and has been linked to marketing trends such as 'clean beauty'. Although one may view these trends as disruptive, the issue is that they can erode public trust in perfectly legal and safe products, leading to the rapid and persistent denigration of certain substances through fast-track mediums like social media.

With the scrutiny of petrochemical substances, concepts like 'clean' and 'green beauty' have grown. Over the past ten to fifteen years, there has been rising consumer interest in natural products, and although consumer expectations of natural are often multifactorial, a common denominator has been perceived ‘hazard avoidance’.

A problem with such a reductionist, market-driven approach is that it is non-discriminatory and can eventually impact all products irrespective of formulation. Indeed, it is evident that all products must be safe by law, but whether the formulation is natural, conventional, or anywhere in-between, to deliver a wide range of product categories, a broad palette of cosmetic ingredients is necessary. To this extent, self-imposed retailer ‘black lists’, or consumer or NGO pressure to remove substances from formulations, risks reducing the availability of products in a certain category.

Taking the example of natural and organic cosmetics, where only two mineral UV-filters are approved (titanium dioxide and zinc oxide), what we find is that non-regulatory ‘black list’ restrictions only run contrary to safety provisions in law, but also limit consumers’ access to protective sun care products that align with their demands for natural and sustainable products in general. Ultimately, unjustifiable disruption or restrictive approaches to safe ingredient use without suitable alternatives risk sowing further consumer confusion and distrust.

Outside of the safety sphere, the overarching challenge disrupting the cosmetics industry is sustainability. Changes consumer trends, in conjunction with growing regulatory and investor requirements, are demanding companies put in-place strategies to ensure products are placed on the market that are not only safe but sustainable by design. Most notably in Europe, the combined influence of policies associated with substantiation of Green Claims (1, 2) and those impacting chemical legislation (EU Chemical Strategy for Sustainability (3) has potentially far-reaching influence upon future ingredient selection. To this extent, an end-to-end holistic approach across the supply chain is expected, which will be especially true when considering the expected need to substantiate a product’s environmental claims via third-party certification.

When it comes to ingredients, although the precise revision of the EU Cosmetics Regulation (4) remains unknown, it appears that the extension of the scope of the generic approach to risk management to endocrine disruptors is expected – meaning that endocrine disruptors will be managed in the same way as CMRs at present. Three other points appear to be much more controversial, namely: the extension of this same approach to Cat.1 Respiratory sensitisers and Specific Target Organ Toxicity - Repeated Exposure (STOT-RE); the introduction of the Mixture Assessment Factor (MAF) ( to take account of the combination effects of chemical substances in products from various consumer product sectors; and the principle of essential use, which would mean that a dangerous substance could only be exempted from the ban if it were deemed essential for society, whereas the current system allows this exemption when the substance is assessed as safe for human health. The degree of disruption remains to be seen, but in a worst-case scenario, such changes could restrict the palette of available ingredients and require re-evaluation and re-formulation of to-date safe products.