SUSTAINABILITY IN COSMETICS: HOW REGULATIONS CAN PLAY A ROLE

Sustainability is something that can assume different faces and that can be approached by different points of view. The term sustainability is derived from the Latin word sustinere, that means to sustain. This etymology reflects the essence of sustainability, as it implies the idea of supporting something over time. To use an abused word during these last years, it could mean being resilient but at the same time taking care of the world around us. At a first glance, sustainability refers mainly to the environment but it can have different aspects that can be easily communicated by B2C producers while they are more difficult to define for producers of ingredients. But how can a B2B industry be sustainable? The B2B industry is more sustainable as one could think mainly for economic reasons. Water, energy, and waste are costs that must be kept under control and it is surely done in order to reduce costs. Cool water can be for example reused for multiple purposes after the first application and an evaporative tower can help in recovering fast all cooling water.

Sustainability begins with data that must be measured as we can’t improve any values we don’t know and after that economic and regulatory pressures do the rest. The raw materials issue is an emblematic example of the strong connection among regulations and sustainability. Many cosmetic raw materials can be found only outside of Europe. Everyone agrees that it is necessary to guarantee that the rights of local populations and the environment are respected. This can be done through local associations or certification schemes like RSPO for palm/palm kernel. Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation (the so called EUDR) is a first step in this direction but it also opens a lot of unanswered questions. The EUDR Regulation entered into force on 29th June 2023 and will become applicable as of 30 December 2024 and will apply to different commodities among which palm and palm kernel that are the main raw material used for the production of surfactants. During its developing process many meetings were held and industry and its association asked for modifications and simplifications such as the necessity to share the process with the countries involved, an easy to handle process able to involve the small holders, and the insertion of all derivatives. Nothing was accepted and the result will translate into higher cost for the European manufacturers and the presence on the market of derivatives at low cost coming from outside Europe and with no obligations about deforestation. Will the cosmetic industry be able to face this aspect and explain the whole thing to customers? A classical question is why it is not possible to use other raw materials. Starting from the idea that the petrochemical derivatives are not sustainable (even if LCA is more or less equivalent, different is the origin and so is the renewability) why is it so difficult to find other sources. We should keep in mind that palm oil supplies 40% of the world’s vegetable oil demand on just 6% of the land used for the production of all vegetable oils. Switching completely to coconut oil would only create pressure on this commodity and propose the same problems again. Another possibility would be to use residues from agriculture or food industry but would the cosmetic industry be ready to use derivatives that can have variability in behavior, odor and color? This is just a brief reflection on the complex word of sustainability. We could go on forever: are anhydrous products really more sustainable if surfactants are manufactured in water solution and dried in a second step? Is bioplastic more sustainable than plastic? What about paper?

Again, with no data handled in the same way every answer is possible. Another important force that will drive sustainability in the next future is ESPR, that means the Ecodesign for Sustainable Products Regulation which has entered into force on 18th July 2024, and prides on being the cornerstone of the Commission’s approach to more environmentally sustainable and circular products. The process will begin with a prioritization exercise, followed by publication of a working plan that sets out the products and measures to be addressed under the ESPR over a given time period. Development of product rules will then start through an Eco Design Forum. Even if cosmetics are not enclosed in the priority groups, detergents and lubricants are, and many molecules are in common. A digital product passport will be needed for finished products as well as for raw materials. Urban waste water framework directive (provisional agreement between European Parliament and Council) identified cosmetics as one of the main sources of micropollutants found in urban wastewater but again this will probably have an impact on raw materials used.

Last but not least, four member states decided to take action at EU level (April 2024) (1) promoting a policy framework transitioning the chemical industry from fossil to sustainable carbon feedstock complaining that only few biomass or CO2 are used in product manufacturing.

Again another proclamation. Again challenges. Again costs.

And again no real numbers from which to start a profitable discussion on sustainability.