As consumer demand for sustainable cosmetic products continues to grow, what are some of the emerging regulations or legislative initiatives at the national or international level that aim to promote sustainability and transparency in the cosmetics industry?
Customers demand have indeed impacts on regulations. There are some key regulatory developments in this field in the EU such as: Green deal and circular economy, aiming to make European zone carbon neutral by 2050. Furthermore, regulations like the EU’s packaging and waste regulation, also aims to deal with quantities of packaging waste that can cause problem for environment. Globally, ISO standards like ISO 16128 to promote transparency and harmonisation in labelling “natural” cosmetic ingredients.
On hierarchy of regulations, we have EU and UK cosmetic regulations that aim to support the ultimate transparently by emphasising on safety of finished products, emphasising on each ingredient’s safety and impurities. Hence, a safety assessment of a cosmetic product is not just a tick list of permitted and not permitted ingredients. It is also evaluating each ingredients’ source.
In our company, one of our objective during the last decade as a provider of regulatory services is to educate our client that a good and high-quality safety report can really support many additional and parallel regulations that may impact their products in national and international regulatory environment.
Eco-labelling schemes and sustainability certifications play a crucial role in guiding consumers towards more environmentally friendly products. Can you discuss the various eco-labelling and certification programs available for cosmetic products, their criteria, and the challenges or opportunities they present for manufacturers?
In my view, different Eco labelling can create chaos and can be confusing for consumers. There are many of them available on the market, for example:
Eco-cert, USDA organic or different organic certification on the markets is offering certificates for organic and natural cosmetics based on environmentally friendly practices, sustainable sourcing and use of biodegradable packaging. The process for gaining certifications can be time consuming and costly.
There are some eco labels like “cradle to cradle” that tries to target the life cycle of a product. This certification aims at leaving “a beneficial footprint for human society and the environment” through product design”.
There are some other eco labels like, The European Eco label, Scandinavian Nordic Swan, the German Blue Angel and the European Eco label. For achieving any of the logos, a product should attain certain criteria in their life cycle and their aims are generally communicating certain values from Business to consumers (B2C). However, the question here would be if having varieties of voluntary logos can facilitate moving the industry to more eco-friendly approach or leads to consumers’ confusions. In my view, varieties of available eco labelling can lead to the latter and may not have a great impact on products’ sustainability.
In terms of if they can present any opportunities for manufacturers, I believe certain certification like ISO 14025 will support evaluating manufacturing businesses to follow environmentally process in more details. Adopting internationally renowned standards like ISO 14025 provides a standardised framework for Environmental Products Declaration (EPDs). It also helps companies to minimise waste and contribute to wider sustainability goals.
With increasing focus on sustainability, there have been industry-wide initiatives and coalitions formed such as the RSPO to address various environmental and social issues. Could you highlight some of the significant industry-led sustainability initiatives that include the cosmetics sector and their potential impact on driving sustainable practices?
Responsible resourcing of ingredients has always been a subject of interest for our industry. Schemes like fair trade, CITE (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) and the Roundtable of Sustainable Palm Oil (RSPO) are examples of this matter.
RSPO was created by the global pressure on producers and user of palm oils via a consortium of several companies like the World Wildlife Fund, the Malaysian Palm Oil Association (MPOA), Unilever, AAK, and Migros. The amin aim of this consortium is to support the environment and wild life and ensure benefiting the small communities involved in harvesting the palm oil.
There are other industry led initiatives like “The responsible Mica initiative” which addresses the ethical sourcing of Mica to eliminate child labour and promoting social responsibilities. Another example that may include other industries is “1% for the planet” and some cosmetic companies commit donating 1% of their sales to their environmental causes.
Initiative like the above are not only important to support sustainability but also raises awareness of consumers on the topics.
Greenwashing, or the practice of making misleading or unsubstantiated environmental claims, has been a concern in the cosmetics industry. From a regulatory perspective, what measures or guidelines are in place to prevent greenwashing and ensure truthful and transparent communication about a product’s sustainability credentials?
Greenwashing is one of the major issues in our industry along with unsubstantiated claims. In the EU and UK cosmetic regulation, we do have a proper guideline regarding claims (article 20). Any claim, including environmentally friendly claims should follow the same rule and relevant guideline. The UK competition and markets authority (CMA) recently took action against misleading environmental claims and published a guideline, very similar to principle of Article 20 of the EU /UK cosmetic regulation, aiming at businesses profiting from unproven environmental claims. The EU commission is working towards a new legislation aiming to ban general environmental claims like “eco-friendly”, “environmental friendly” or “neutral due to offsetting carbon foot print” without being verified properly by backup data for the whole life cycle of a product.
As sustainability standards and regulations continue to evolve, what are the key areas or aspects of cosmetic product development, manufacturing, and marketing that regulatory bodies or certification organizations are likely to focus on in the near future to further enhance sustainability within the industry?
As sustainability standards and regulation evolve, the regulatory bodies are likely to focus on issues around Packaging waste, evaluating ingredients’ safety based on their bioavailability and their impact on the environment rather just its intrinsic safety of the ingredients.
The recent example of this regulation is restricting concentration of cycopentasiloxane in rinse off products due to bioavailability concern rather than just its safety in cosmetic products.
Packaging waste regulation is another hot topic in this area. By end of 2024, EU countries should ensure that producer responsibility schemes are established for all packaging. The Directive also sets the following specific targets for recycling.
Below table is an example of
One of the drawbacks of the directive is establishing individual packaging waste logo. The presence of different logos on products’ labels can create confusion among consumers and undermine the regulation’s primary goal of effectively informing consumers.
The EU Directive 94/62/EC aims to harmonise national measures on management of packaging waste. Directive (EU) 2018/852 which is the latest amendment of Directive 94/62/EC has measures to prevent production of packaging waste and promote reuse, recycling and recovering packaging waste.
In our role as the responsible person at Personal care regulatory, we have always tried to educate our clients and provide the latest available guideline to ensure products’ safety and compliance on the market.
References and notes
Experts
MARK SMITH
Director General, NATRUE AISBL, the International Natural and Organic Cosmetics Association
MOJGAN MODDARESI
Managing director, Personal Care Regulatory Ltd, Chemcomply founder
DIPTI VAIDYANATHAN
Market Transformation Manager, Europe - RSPO
LEE MANN
Head of Community Fair Trade and Sustainable Sourcing, The Body Shop
JENNIFER SHEPHERD
Senior Buyer Communit, The Body Shop
EMILY HOLDEN
Sustainability Relations Advisor, The Body Shop
BARBARA OLIOSO
Director, The Green Chemist Consultancy
Panelists
LISETTE TOWNSEND
Global Director Business Development
& Marketing, Personal Care, AAK
RENATA OKI
Head of Personal Care Market Development EMEA
BASF Personal Care and Nutrition GmbH
AMANDINE WERLE
Marketing Specialist, Lucas Meyer Cosmetics by Clariant
TIMM SEIDEL
Senior Sustainability Manager, Chemisches Laboratorium Dr. Kurt Richter (CLR Berlin) GmbH
ANGELINA GOSSEN
Technical Marketing Manager, Croda GmbH
CAMILLA GRIGNANI
Marketing Specialist - Etichub srl
(Academic Spin-off – University of Pavia)
MALTE SIETZEN
Head of R&D and Quality Management, Evident Ingredients GmbH
CAROLE GHERARDI
Market Segment Lead, Personal Care, Health & Biosciences, IFF
FRANK DUNLAP
Director of EHS, KensingSolutions
ROSSANA COLOMBO
Technical Manager Personal Care, Lamberti
MATHILDE ALLEGRE
Global Sustainability Manager,
Lubrizol Life Science
BIANCA MCCARTHY
Global Marketing Manager, Lipotec™
Active ingredients, Lubrizol Life Science
EMINA BESIC GYENGE
Senior R&D Manager Hair Care Cosmetic Actives and Sustainability expert, RAHN AG - RAHN Cosmetic Actives
ELISA ALTIERI
Market Manager Personal care, ROELMI HPC
MARINE PASQUIER
Market & Digital Manager - Beauty Care at Seppic
LUCIE BAILLY
CSR Manager, SILAB
GAELLE BATHANY
Vice President Global Marketing & Sustainability, Symrise
THOR-ERIK NYSETH
Sales and Marketing Director, Unger Fabrikker AS
ÒSCAR EXPÓSITO
CEO, CSO and co-founder, Vytrus Biotech S.A.
ELISABETTA MERLO
Regulatory Affairs, Zschimmer & Schwarz Italiana
References and notes
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1115
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401760
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022L2464
- https://eur-lex.europa.eu/eli/reg/2024/1781/oj
- https://data.consilium.europa.eu/doc/document/ST-7859-2024-INIT/en/pdf
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202400825
- https://www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-substantiating-green-claims
- https://environment.ec.europa.eu/strategy/chemicals-strategy_en
- https://data.consilium.europa.eu/doc/document/ST-16721-2023-REV-1/en/pdf