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The End of Restricted Lists: Beauty Brands Shift to Safer Chemistry Practices

Published November 26, 2024
Published November 26, 2024
Fulvio Ciccolo via Unsplash

Consumer safety is top of mind for beauty brands as they navigate evolving regulations and a push for clean, transparent formulations. In response to consumer demand for safer and more sustainable products, the Know Better, Do Better (KBDB) Collaborative was formed, bringing together industry leaders like Sephora, Ulta Beauty, The Honest Company, and Credo Beauty. Partnering with ChemFORWARD, the group analyzed 8,500 beauty and personal care products to enhance ingredient hazard transparency and promote safer chemistry. The report found that while 70% of ingredients are well-characterized for safety, 30% remain uncharacterized or flagged as high hazard. It also identified ten frequently used chemicals of concern that should be prioritized for elimination, noting that safer alternatives are available for these substances.

“This report shows that beauty and safety can—and must—go hand in hand,” says Stacy Glass, co-founder and Executive Director of ChemFORWARD. “With the power of shared data and collaboration, the beauty industry is on the cusp of a transformation that prioritizes human health and environmental responsibility.”

Established in 2023 and managed by ChemFORWARD, the KBDB Collaborative is a group of beauty industry leaders across the supply chain, including the retailers Sephora, Ulta , and Credo Beauty; companies Beautycounter and The Honest Company; ingredient suppliers Inolex and Dow; and the nonprofit Environmental Defense Fund. By coming together, the KBDB Collaborative aims to address chemical safety as an industry-wide problem and prove that “while the number of chemicals to be assessed might be daunting for a single company, the task [is], in fact, manageable if it was shared.” The group seeks to establish a clear standard for safer chemistry for improved consumer health and environmental sustainability in the $100 billion personal care sector.

"Using safer ingredients isn’t just about doing the right thing—it’s a must for the cosmetics industry,” says Christina Ross, Director of Science and Policy at Credo Beauty. “Real change starts with getting the science right—and rigorous hazard assessments and ingredient transparency are essential baseline scientific practices to drive our industry forward. By prioritizing safer ingredients and committing to higher standards, we can collectively drive innovation, build trust, and set a new norm.”

The biggest findings from the report include the following:

1. The report established that 70% of the ingredients in the analyzed dataset are well-characterized, meaning their potential hazards are understood. This serves as a baseline or “metric zero” for the industry.

2. Despite analyzing over 8,500 products with nearly 318,000 ingredients, the report identified only 2,279 unique ingredients. Focusing on core high-frequency ingredients streamlined ChemFORWARD’s assessment and characterization process.

3. The report identified 45 chemicals with known high hazards they believe should be prioritized for elimination. It also highlighted safer functional alternatives for these chemicals and encouraged a shift towards safer options.

4. To fully understand their human and environmental impacts, the complete characterization of all ingredients through chemical hazard assessments is needed. The report suggests strategies such as prioritizing high-frequency data gaps and engaging suppliers in trade name-specific assessments.

5. Collaboration is a powerful force that can help facilitate the transition to safer chemistry. Shared data and resources have enabled the filling of critical data gaps and reduced costs, showcasing the tangible benefits of collective action.

A Closer Look

The Beauty & Personal Care Ingredient Intelligence Report emphasized the need to assess uncharacterized ingredients, which comprise 30% of all reported ingredients and appear in many products, revealing key data gaps. According to Glass, one of the biggest barriers preventing the characterization of this remaining 30% is a lack of funds and participation from other beauty brands. Increased investment in comprehensive chemical hazard assessments (CHAs) and data sharing among brands would benefit the entire industry.

“If more companies participate, the work can happen faster and more cost-effectively,” she tells BeautyMatter. “The data-sharing model is an excellent example of how ‘many hands make light work.’”

Glass admits that it’s unlikely to achieve 100% characterization since the beauty industry is constantly evolving, with new ingredients emerging constantly, requiring continuous assessment and characterization. She also resists the notion that a “history of safe use” is sufficient safety substantiation for any ingredient—even “natural” ingredients.

“While a history of safe use is valuable when assessing specific hazard endpoints, it fails to adequately address some of the critical long-term, low-dose, and environmental concerns in completing a comprehensive chemical hazard assessment,” says Glass. “All synthetic and naturally derived/botanical chemicals should be subject to the same assessment criteria.”

Major retailers like Sephora, Ulta, and Credo Beauty play a pivotal role in advancing safer chemistry in beauty products. Their involvement in the KBDB Collective supports a shared database, making high-quality data accessible to all brands, big and small. Glass adds that some retailers have encouraged their brands to conduct their own ingredient assessments and leverage the shared data, benefiting from the groundwork laid by larger companies.

“We believe that data is an enabler. Without robust chemical hazard data, when a chemical goes to market, all value chain members are vulnerable to the impacts of uncharacterized chemicals.”
By Heather McKenney, science and safer chemistry lead, ChemFORWARD

Safer Alternatives to High-Hazard Chemicals

The report identified 45 chemicals with known high hazards or emerging chemical classes of concern that should be prioritized for elimination. Among the ten most common high-hazard chemicals were cyclopentasiloxane (D5), found in 18% of the products as an emollient or solvent, and butylated hydroxytoluene (BHT), present in 14% of the products as an antioxidant/preservative. These chemicals pose high or emerging risks to human health and the environment, particularly as carcinogenic, mutagenic, and reproductive toxicants (CMR) or persistent, bioaccumulative, and toxic (PBT) substances. Safer functional alternatives exist for all ten high hazard high-frequency chemicals, but it’s not as simple as swapping out one ingredient for another.

“While identifying appropriate functional alternatives is best suited for cosmetic formulators who balance efficacy, stability, and other key parameters, this report highlights that potentially safer functional alternatives can be prioritized as substitutes for higher-hazard chemicals,” Heather McKenney, ChemFORWARD’s science and safer chemistry lead tells BeautyMatter.

The report uses cyclopentasiloxane as an example, which is often cited as an emollient that improves the dry time of cosmetics. Reviewing other ingredients tagged as emollients on ChemFORWARD provides insight into safer, potential functional alternatives that also impart quick-drying benefits, such as isododecane and heptyl undecylenate. This, the organization argues, is the power of shared data.

“Characterizing the thousands of chemicals used in beauty and personal care would be daunting for a single player, but the shared repository increases the consistency of the data, lowers the cost per user, and provides formal mechanisms for resolving differences in interpretation and incorporating new data as it emerges,” says McKenney. “A well-managed, shared data set is an asset for the entire industry.”

How ChemFORWARD’s Shared Data Platform Works

The shared ChemFORWARD platform helps improve hazard transparency by providing users with flexible and portable “Hazard Band” scores, ranging from A (lowest hazard) to F (highest hazard). These scores can simply communicate the level of hazard associated with a chemical up and down the supply chain, enabling speedy decision making during formulation and substitution.

“Maintaining high-quality, trusted data is a key tenet of the ChemFORWARD repository, and we accomplish this through our continuous improvement protocols,” says McKenney. “We work with qualified assessor firms that own and maintain the data, and all chemical hazard assessments (CHAs) are peer-reviewed by an independent toxicology expert. We also have a technical challenge process whereby third parties can challenge an endpoint interpretation and submit new data that was not available at the time of assessment. Finally, we have processes to evaluate the validity of CHAs over five years old or for chemicals subject to regulatory status changes.”

ChemFORWARD has several data quality measures to ensure that its comprehensive chemical hazard assessments are robust, credible, and consistent. In addition to the steps outlined above, the organization maintains a policy for reviewing, incorporating, and protecting confidential business information, which allows the company to receive private, unpublished data—typically from suppliers—to contribute to the assessment. Additionally, ChemFORWARD works closely with various stakeholder groups, including industry, NGOs, regulators, and academia, to understand perspectives, challenges, and priorities across the value chain and avoid siloing its work.

“We believe that data is an enabler,” says McKenney. “Without robust chemical hazard data, when a chemical goes to market, all value chain members are vulnerable to the impacts of uncharacterized chemicals.”

Establishing premarket human and environmental hazard data guidelines or minimum requirements enables the market to move swiftly toward safer alternatives. Restricted substance lists (like Drunk Elephant’s "Suspicious 6" or Credo’s “Dirty List) are just the starting point in the journey to safer chemistry. Today’s consumers are looking for more detailed information on product ingredients. However, since these lists don't identify safer alternatives, they can sometimes lead to "regrettable substitutions," where a restricted chemical is replaced by another with similar or even higher hazards.

“When we encounter a high-hazard chemical and specific function for which there don’t seem to be obvious safer alternatives, that calls for innovation,” says McKenney. “Chemical suppliers are important in collaborating to help fill emerging market needs.”

What’s Next In the Shift Toward Safer Ingredients

Given the increasing consumer demand for transparency, McKenney expects consumer behavior to trend away from restricted substance lists and toward radical safety transparency, which provides complete visibility into what is known and not known about the hazards associated with each ingredient in the product.

ChemFORWARD urges beauty brands to adopt a measurable, actionable approach to safer chemistry by incorporating the report's findings into their long-term strategies and establishing a baseline.

“[Beauty brands] can run their ingredient intelligence report, understand what is known and not known across their product offering, and then set clear goals for eliminating chemicals of concern, filling data gaps, and increasing the amount of verified safer chemistry being used,” says Glass.

If beauty brands want to accelerate their progress, they can join the Know Better, Do Better Collaborative and work closely with suppliers and other stakeholders to implement safer practices. Additionally, proactive ingredient assessments are key to ensuring competitiveness in a health-conscious market.

“Beauty brands should continuously assess and improve ingredient safety profiles,” says Glass. “By embracing the principles of hazard transparency, collaboration, and data-driven decision making, beauty brands can navigate the evolving landscape of ingredient safety and meet the growing demands of health-conscious consumers.”

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