Researchers and regulators want to crack clean beauty

This article is part of our Vogue Business membership package. To enjoy unlimited access to our weekly Sustainability Edit, which contains Member-only reporting and analysis, sign up for membership here. “Clean beauty” has been trending for years now, but efforts to reach a truly clean industry — and define what that means — are lagging far behind. With investment in a few key areas, that could change, according to a new report shared with Vogue Business. ‘The Need for Safer Chemistry in Beauty: Opportunities for Innovation’, published today by venture capital fund Safer Made, calls for chemical and material innovation in the $500 billion global beauty and personal care product industry, with a focus on preservatives, silicones, fragrances, plastic packaging, sunscreens and insect repellents — six key areas that stand in the way of consumer expectations for “clean” or “natural” products matching the reality of what the market actually offers. While the market has moved away from some concerning chemicals in recent years, such as triclosan and triclocarban and petroleum-based surfactants, many others remain, including silicones, phthalates and formaldehyde or formaldehyde-releasing chemicals, with consequences for both human health and the environment. In some cases, brands could easily be doing more to improve formulations, but in others, safe alternatives are not widely known or available yet. From hidden health risks in scented products — because of the use of concerning substances and a lack of data and transparency in the fragrance market — to the use of liquid plastics and chemical preservatives in products that brands claim are natural, the beauty industry has a number of significant weak spots to address if it ever wants to deliver on the promise of clean. The report focuses not just on the innovation gaps, the authors say, but also on solutions already being developed and opportunities that brands, retailers and investors can tap into to accelerate the industry’s transition to a safe and sustainable future. “It’s wonderful that we’re moving away from chemicals known to cause cancer or linked to reproductive harm,” says Mia Davis, sustainability and safety expert, former VP of sustainability and impact at Credo Beauty and an author of the report. “But, so many chemicals are unassessed for safety or have other problems. We still find ourselves playing whack-a-mole — and even when you have a strong standard, there isn’t really a playbook for how chemists or folks in R&D would go about finding that material and taking all of this into account.” The Safer Made report aims to help retailers and investors make more informed decisions around topics such as preservatives, chemical innovation and other ingredients. “Our goal is always to draw more attention, and hopefully more dollars and effort, into the space,” says Martin Mulvihill, general partner at Safer Made and co-author of the report. Regulations in the works Clean beauty has become a point of confusion for customers, many of whom are attracted to the premise but unclear on what it actually means — largely because it has no real definition. Sephora’s ‘Clean at Sephora’ label was hit with a lawsuit after a customer claimed that a “significant” percentage of products under it contained synthetics. Sephora said in response that it only considers specific ingredients when defining its “clean” selection. A lack of clear standards and regulations has made this an industry-wide problem, but there is also a push for change. The EU is revising the Cosmetic Products Regulation section of the EU chemicals strategy for sustainability, with some expectation it will lead to “radical” change for the sector, and it already has perhaps the world’s most ambitious framework, known as Reach (registration, evaluation, authorisation and restriction of chemicals) for chemical regulation generally (although the revisions underway there have health and environment advocates on guard, with leaked drafts suggesting a potential backtracking on restricting certain substances). In the US, the Food and Drug Administration (FDA) this week proposed a ban on hair straightening products that contain formaldehyde (or ingredients that release formaldehyde, a common trick of chemistry and formulation that enables formaldehyde to be present in final products but not listed on product labels), a category of products marketed heavily to and disproportionately used by Black women. The Modernization of Cosmetics Regulation Act of 2022 (MoCRA), which will start to take effect on 29 December, will expand the FDA’s authority to regulate the safety of beauty and personal care products; it enables the agency to issue mandatory recalls of products deemed unsafe and to require companies to disclose to the FDA — although not to consumers — fragrance ingredients that are common allergens, among other provisions. MoCRA, while significant, is also widely considered to be a set of bare minimum steps in an industry that needs drastic change. However, even without more sweeping regulations in the US, some experts believe that between stricter regulations in other markets, increased consumer demand for and awareness of clean products, as well as growing momentum for more sustainable consumer goods generally, the industry doesn’t have much choice but to adapt. Some companies may move faster than others, but the direction of travel overall seems fairly clear. Though lagging now, beauty can lead the way While industries from food to packaging to textiles also need innovation in clean chemistry, Mulvihill says that beauty is a good — and common — starting point for green chemistry companies to prove and commercialise their technology. “It tends to be a good early market to go into, and so we have seen more investors and more startups interested in learning more about how the beauty space works,” he says. That’s mainly because consumer demand for clean beauty is clear, and the barrier to entry is lower from a business perspective. Beauty brands need smaller sample quantities of an ingredient to test it, and smaller order quantities when formulating, compared with textile or packaging companies, for example, lowering the burden for smaller startups that are still scaling production. Companies can formulate and evaluate new ingredients with just a few hundred grams, says Mulvihill, and order quantities for a small launch are less than one tonne or, for some active ingredients, as small as a few kilograms. When MoCRA goes into effect at the end of this year, it is expected to improve basic safety in the US market by focusing on transparency and requiring brands to know their supply chains better than they have needed to before. It will require manufacturers to ensure cosmetics products are safe and to maintain records that demonstrate “adequate substantiation” of claims about safety and will mandate clearer labelling about allergenic ingredients, among other things. “With this being the first update of real significance to the legislation in about 85 years (cosmetics regulation has really not changed in the [US] since 1938), the new requirements will be significant to most companies,” says Victor Mencarelli, director of global regulatory affairs at Bare Minerals, Buxom and Laura Mercier parent company Orveon Global. As of mid-October, the industry was preparing for the FDA’s data portal, Cosmetics Direct, to open so that brands can begin logging product submissions and facility recommendations. The FDA says that once it begins accepting data, users can submit information, formatted according to its Structured Product Labeling (SPL) implementation guide, for cosmetic product facility registrations and product listings mandated by MoCRA. Cosmetics Direct will be an “authoring tool”, according to the FDA, “that contains user friendly data entry forms, performs initial validations, creates and saves the SPL submission, and submits the SPL to FDA for internal processing”. Overall, the regulation is forcing companies to increase their due diligence. “We are presently working within different departments in Orveon to try to ensure we understand what information is already available, what information we think we might need in the future and then trying to determine a path forward for managing the gathering, storing and searchability of the data for the future,” says Mencarelli. At the same time, this could open up expansion markets for US brands, since MoCRA could help to align standards or streamline registration processes with those that exist in China and Europe. Smaller brands in particular may struggle to comply if they don’t have staff or contractors who are well-versed in the new regulations — but, he adds, “One mitigation to this significant challenge will be if the FDA were to recognise as equivalent the EU regulations with regard to such issues as the product safety assessment or acceptable testing methods. Again, this turns MoCRA into a potential worldwide equaliser for the US industry if it is an option to move in this direction.” Even so, health experts say MoCRA is just the beginning, and the Safer Made report emphasises how much work there still is to do — particularly in the US, where chemical regulations have been notoriously lax and where the focus on safety has been centred on short-term health impacts but largely ignored longer-term issues that only develop over time and with continued use of a product, which is where the vast majority of health concerns associated with beauty products tend to arise. “With MoCRA, there is a new safety substantiation piece. What we’re proposing in the report, and what we’re envisioning for this industry, will go beyond what MoCRA would ever regulate,” says co-author Davis. “It’s an important step forward, but it’s still the floor, and we’re advocating more for the ceiling. We’re saying, let’s have more data and more thoughtful innovation so that we’re really driving safer, greener chemistry from the get-go.” Comments, questions or feedback? Email us at feedback@voguebusiness.com. More from this author: Why are fashion’s sustainability promises so hard to spot during fashion month? Peta’s runway protests put spotlight on fashion's love for leather The problem with fashion’s sustainability awards

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