VINCENZO PAOLO MARIA RIALDI

Managing Director and Technical Director, Vevy Europe S.p.A., Italy

Cosmetic ingredients play a crucial role in the overall success of the entire supply chain. As a matter of fact, safety, stability, functionality and even the sustainability of the finished product largely depend on them.

During its development, each ingredient is the subject of complex research, development production and regulatory verification processes, all steps that are necessary to make it feasible and usable.

The scientific and regulatory attention that the cosmetic ingredient fully deserves is achieved above all via a correct communication between the participants in the entire supply chain.

Every actor in the cosmetics supply chain can and must therefore contribute to ensuring that high levels of harmony, participation and satisfaction are safeguarded throughout the entire process.

Within the sectors that depend on chemistry - cosmetics is certainly one of these - the evaluation of sustainability is based on few, essential concepts:

• Irrespective of its origin, every single substance is a chemical and must be managed as such;
• Everyone has the responsibility to analyze and mitigate the environmental impacts caused by their activities, independently of their extent and the effects they may have;
• It is necessary to consider and calculate all relevant impacts relating to the whole life of a substance or product, from extraction to recycling or disposal, through treatment, production, storage, distribution and use;
• Impacts must be calculated following official, recognized and shared methods, so that the data obtained are consistent and comparable;
• Sustainability is a supply chain issue: one non-virtuous actor can nullify the virtuous behavior of all the others;
• The governmental institutions also have precise duties and play a decisive role: they can create adequate infrastructures and impose the taking of relevant measures based on realistic scenarios.

As an example, let’s consider preparing a simple cup of tea. An infusion of vegetal origin in hot water impacts at least, the energy demand to heat the water, the disposal of the chopped leaves of tea and perhaps of the teabag, the detergent for the washing of the cups and spoons, that add to the production, the processing and the transportation across the oceans of tea that usually originates in India, China or Africa, all the way to our homes. [1] [2]

This simple example allows us to envision the impact of an industrial-level production of tea aimed for large-scale distribution.

This is why the twelve principles of Green Chemistry, which mainly concern the design and the improvement of chemical transformations, cannot be applied while forgetting the nine principles of Green Engineering, which are related to industrial processes and installations, each of them applicable by relevance. These principles are universally codified and are shown in the diagram below. [3]

In fact, at least eight of these principles are involved in our cup of tea, in addition to the four common to all activities.

Cosmetic products are made of ingredients and the components of every ingredient can be of different origins: vegetable, animal, mineral, synthetic and combinations thereof. As far as sustainability is concerned, their origin should be clearly stated. Indeed, even if it is easy to believe that substances of natural origin are more sustainable than those of other origins, this is not necessarily the case.

And let us point out that «Natural» and «Sustainable» are far from being synonyms. «Naturalness» in cosmetics is a very well-defined word whose quantitative value can be calculated according to the ISO 16128 Guidelines [4] [5] which clearly and unequivocally define how to calculate the naturality level of a substance and therefore of cosmetic ingredients and products. It should be pointed out that an ISO standard results from the work of a team of specialized experts and establishes criteria that must be accepted and applied. The concept of «Sustainable», on the other hand, finds its origin in the principles of Industrial Ecology, and specifically those of Green Chemistry and Green Engineering. These principles recommend a very precise path towards virtuous behavior in all steps of a supply chain that is related to chemistry.

The European Federation for Cosmetic Ingredients (EFfCI) has published a specific guide, the «IEQMS - Industrial Ecology Quality Management System» [6] [7] which proposes an original and concrete approach to this topic, with the positioning of the aforementioned principles as established by the ISO Annex SL and therefore on the Deming Cycle, so that an any kind of organization can easily integrate them into its Quality Management System.

It can happen that a substance with a high percentage of naturality is far less sustainable than a substance whose percentage of naturality is equal to or close to zero. Thus, it is not the naturality of a substance that determines how sustainable it is; the level of sustainability of a substance must be assessed through all its impacts throughout its life cycle, which should be calculated before drawing conclusions. The Life Cycle Assessment (LCA) allows to calculate the seven canonical impacts, namely primary energy, carbon footprint, thinning of the stratospheric ozone layer, (aquatic) acidification, (aquatic) eutrophication, photochemical smog and solid waste. [11] [12] [13]

These seven quantities, to which an eighth, namely the water footprint, should be added, are calculated during the Life Cycle Assessment with their respective weight factors.

In addition to the well-known ISO 14000 series [9], the international Responsible Care program also allows one to obtain data, analyze and evaluate the situation in the Health, Safety and Environment (HSE) areas of an activity. [10] According to the Responsible Care official data, companies that apply this program are on average safer and have less impact than the others.

Claims in this field cannot therefore be based only on good intentions, much less on data obtained with unofficial methods.

As of today, worldwide, there are more than four hundred and fifty voluntary environmental labels (more than two hundred of these in the EU alone). Such labels contain claims that are often poorly defined and poorly explained or not explained at all. These claims are often based on non-comparable methods for measuring and evaluating environmental impacts. This creates confusion in the mind of producers and consumers.

A good initiative from the European Commission is that of the upcoming publication of a new Directive «on substantiating green claims», which adds to the already large array of regulations for the consumer protection, according to which companies will have the obligation to justify their claims using established methods to determine the environmental footprint of products and organizations along the entire value chain, from the extraction of raw materials to the end of the life cycle. This can be done using the fourteen impact categories provided, where applicable. [8]

The Life Cycle Assessment (LCA) includes seven, five of which, highlighted with an asterisk below, are included in the fourteen established [14] [15] [16] [17]:

1. Carbon footprint *;
2. Ozone depletion *;
3. Human toxicity - cancer effects;
4. Human toxicity - non-cancer effects;
5. Particulate matter/respiratory inorganics;
6. Ionizing radiation;
7. Photochemical ozone formation *;
8. Acidification *;
9. Eutrophication - terrestrial;
10. Eutrophication - aquatic *;
11. Ecotoxicity - freshwater aquatic;
12. Land use;
13. Resource depletion - water;
14. Resource depletion - mineral and fossil fuel.

The impacts caused by «primary energy» and «solid waste» are only present in the Life Cycle Assessment and are not mentioned here because they are considered obvious.

These impact categories will be applicable based on relevance: for example, for the production of cosmetics, the production of tonnes of CO₂ equivalent (tCO₂e) will not be as important as the toxicological aspects and parameters relating to the water footprint.

It is very likely that the whole world will align with this initiative since it has the advantage of improving the traditional LCA by making the evaluation process more complete and more specific. This is a fundamental step to supporting the «green transition» as it will force industrial companies to address all related issues in a serious and structured way.
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The European Parliament and the European Commission aim to the implementation of additional measures to guarantee effective protection of consumer rights in the context of Artificial Intelligence and automated decision-making systems. These initiatives are intended to protect the consumer from unfair commercial practices, guaranteeing thus greater transparency and ensuring that only high-quality, non-discriminatory data is used in automated decision-making systems. [18]

The cosmetic ingredient, precisely because of its centrality in the supply chain, is fully included in all these considerations and if on the one hand it is logical that it is the subject of the most disparate requests for data, is very often the subject of extravagant, non-pertinent or unfounded requests.

Sustainability data requests should therefore only be based on official calculation criteria, thus encouraging a genuine communication flow.

For this reason, the Sustainability Report developed with official criteria [19], in addition to being an excellent periodic exercise for those who draw it up, is a significant aid for the correct communication of how much an organization really works in terms of sustainability and contributes to verifying the actual spaces of improvement.