When HBO released Not So Pretty on April 14, it was seen as a reignition of the clean cosmetics debate. Back in 2020, BeautyMatter founder Kelly Kovack spoke with Phyllis Ellis, director of the Toxic Beauty documentary about her deep dive into the Johnson & Johnson baby powder class-action lawsuit that linked the use of their talc powder to ovarian cancer. This case is also mentioned in Not So Pretty, which dedicates each episode of the four-part series to a sole product category: makeup, hair care, nail salon, and skincare. BeautyMatter summarized the episode content as below:
Episode 1: Makeup
Episode 2: Nails
Episode 3: Skin
Episode 4: Hair
Viewers were encouraged to use apps such as Detox Me, Skin Deep, and Clearya to ensure product safety, as well as encourage their Members of Congress to vote for the Safer Beauty Bill Package, a combination of four separate bills that would ban 11 chemicals including phthalates, parabens, mercury, formaldehyde, and Per- or poly-fluorinated alkyl substances (PFAS) (as has already been done in the EU, California, and Maryland), require the complete disclosure of flavor and fragrance ingredients, campaign for the health of women of color and salon workers, and advocate for supply chain transparency. The Crown Act, which is rallying against race-based hair discrimination, was also mentioned as important legislation to support. As of the latest figures, #notsopretty has over 19.6 million posts on TikTok.
BeautyMatter consulted with a host of experts to discuss the finer details of the series.
Point #1: A Lack of Regulation from the FDA
A key point of Not So Pretty was lax health and safety measures in the beauty industry, a seemingly “Wild West'' where products are released onto the market without proper safety assessment, or even worse, where brands are using dangerous chemicals with little afterthought as to how this could impact the health of consumers. Jen Novakovich, founder of The Eco Well, comments that the actions of a few brands cannot be indicative of all brands. “The documentary painted the industry as one player,” she notes.
Certainly the FDA has come under criticism for failing to ban formaldehyde-containing straightening treatments, an ingredient which is a classified carcinogen, altogether. Instead, OSHA (Occupational Safety and Health Administration) determined the allowable levels of formaldehyde in the salon air, with the FDA sending out warning letters to those who are found in violation of these regulations. In the case of plastic microbeads, the FDA took a more proactive stance, passing the Microbead-Free Waters Act, which bans them in wash-off products in 2015.
But how can these materials enter the market in the first place without any acknowledgement of their side effects? One reason might be the lack of a mass testing sample, which only hits full scale once a product has gone to market, as was the case with Kathon CG, an initial paraben replacement which was quickly pulled from shelves after adverse reactions. Gregg Renfrew, founder and Executive Chair of DTC clean beauty brand Beautycounter, states that long-overdue legislation is to blame: “The last regulation to pass around the safety of personal health products was in 1938. Since then, tens of thousands of new products and chemicals have been introduced on the market. Individual companies are left to determine what they deem to be safe, leading to inconsistency, discrepancy, and a confusing market for consumers to navigate.” She explains that the FDA’s lack of authority to implement more regulation is a key hurdle, and that Congress needs to pass more legislation in order to grant the association more ruling power.
While legislative change will be the ultimate fast track to change, in the meantime the responsibility lies in the hands of brands and industry figures. “It takes individual initiatives from companies like ours, working in partnership with scientists and advocates, to develop robust safety standards that lead to safer products because there is a lack of regulations that effectively create a baseline or level playing field for our industry,” Renfrew says. Beautycounter proposes a Blueprint for Clean consisting of 12 safety standards encompassing sustainable packaging, responsibly sourced ingredients, and more.
Note that natural doesn’t always mean safer. “Some ‘all natural’ products may include ingredients that are less tested and less proven to be safe and effective compared to some more synthetic ingredients,” board-certified dermatologist Dr. Hadley King tells BeautyMatter. “Sometimes the products may not contain preservatives that are as effective as more synthetic options, so that will shorten the shelf life. And keep in mind that ‘natural’ ingredients can have risks too—for example, essential oils are a common cause of allergic contact dermatitis. Chemicals may be a dirty word in the world of clean beauty, but that doesn't really hold up. Many plants, whether or not they are organically grown, contain substances that may be toxic or allergenic.” Take for example endocrine disruptors, the main focus of the third episode. Dr. King notes that ingredients such as soy, lavender, licorice, and tea tree oil have also been linked to the issue.
Bloodstream absorption of topically applied ingredients is a known fact, but Dr. King notes there is “limited data about the absorption of most ingredients, and even more limited data about the effects and safety if they are absorbed. It may seem reasonable to avoid unnecessary exposure to synthetic pesticides, fertilizers and other non-organic substances, but ideally it is best to have data before condemning any ingredients.” She suggests label-reading diligence and research in order to avoid potentially harmful ingredients, although not all sources are created equal. “A lack of data sometimes seems to be enough for a more hazardous rating. The problem is that many studies are too small or there aren't enough of them, or they are inconclusive, or they aren't performed on humans,” she explains. “Dose is also important and that point is often ignored. The ‘better safe than sorry’ approach can lead to misplaced fear.”
For brand owners, losing customers due to disputed risks of certain ingredients (even if they benefit the formula) presents a bigger issue than defending their choice to use them to customers. One noticeable exception is The Ordinary’s recent “Everything Is Chemicals” campaign.
Point #2: Brands Launching Products and Keeping Them on the Market Despite Adverse Side Effects
In the cases of DevaCurl and Johnson & Johnson, Not So Pretty explains that the companies were made aware of the adverse reactions to their product but made no effort to change formulations. “The truth is, it was in the industry’s best interest for consumers to be left in the dark. The beauty industry has been built on secrets, and change is hard,” Renfrew says. But there are many actors willing to change their formulas or business structures in order to benefit the greater good.
The clean beauty movement has made huge strides in a short amount of time, with a niche product category expanding into an activist movement. “When we launched in 2013, the clean beauty movement was almost non-existent, but we’ve led the conversation to bring the beauty industry’s secrets into the forefront, working to advocate for more health-protective legislation, educate the consumer so that they can take a proactive and participatory approach, and formulate products that are safer for human and environmental health,” Renfrew states. “The clean beauty movement is no longer a thing of the future, but the here and now, and consumer demand will only continue to grow as awareness of the issues continue to rise.”
However, other product formulators have different opinions on the clean beauty movement. “I can’t say most formulators I work with are aligned with ‘clean’ marketing, largely and principally because it’s an entirely undefined term and as scientists, precision is everything to their work,” dermatologist Dr. Ranella Hirsch tells BeautyMatter. “Much of it represents a marked misinterpretation of the science, as with parabens, where a single study, one which the author herself has stated they have drawn to a conclusion that wasn’t intended, is the basis for a lot of bad information.”
Mia Davis, VP of Sustainability & Impact at Credo, former Head of Environment, Health & Safety at Beautycounter, and co-founder of Pact Collective, as well as consulting producer on the Not So Pretty series, defines clean beauty’s main pillars as “ingredient and materials safety, sustainability, ethics and transparency,” subject matter which naturally requires science and evidence to substantiate claims. She points to the Credo Clean Standard, which bans more than 2,700 ingredients, plus requests safety standard and product claim substantiation, as well as full disclosure of all fragrance ingredients from brands, as an industry leader on the matter. Many companies are now working to formulate their products according to this standard, with consumer searches for fragrance-free products growing 27.3% annually. Retailers such as Sephora and The Detox Market have also set their own clean beauty standards, although the regulations and standards differ from retailer to retailer. Here a united vision and standard across the entire industry would be the most effective catalyst for change.
For all parties involved, a case-by-case and ingredient-by-ingredient approach, underlined with exact interpretations of scientific studies, is the most solid basis to stand on.
Point #3: Cosmetic Products Are Causing Cancers and Other Dangerous Side Effects
Watching the individual cases of people who developed devastating side effects from using beauty products in Not So Pretty is undoubtedly a hard-hitting experience. When the only (seemingly) uniting factor among hundreds of consumers, regardless of age or background, is the use of a single product, as was the case with Johnson & Johnson and DevaCurl, can there be any other explanation?
Cancers and autoimmune reactions can be caused by multiple factors: exposure to pollution, pesticide-ridden foods, contaminated drinking water, hereditary risks, and more. How much of disease causation can be attributed to the cosmetics we use versus the things we ingest on a daily basis? Renowned physician Dr. Gabor Maté even goes so far as to state that chronic illnesses and cancers are actually the body’s response to emotional stress, outlined in When the Body Says No: The Cost of Hidden Stress.
“They blamed makeup on mesothelioma but they never actually gave any insight into that person’s environment. Asbestos in homes is a really big issue, was there contamination there? The way it portrayed it in the docu series made it seem that all of these cases were for sure due to cosmetics,” Novakovich commeted on a recent Instagram Live with cosmetic chemist Esther Olu and Michelle Wong of Lab Muffin. “A lot of this is fear tactics. It is feeding into a lot of conspiracy thinking going on right now,” Olu adds.
Medical reports presented another part of Not So Pretty’s case against cosmetics safety, but these reports were not disclosed in full, and the documentary didn’t dive into the complete medical history of every mentioned case. Nonetheless, for many consumers, the thought of the beauty products they use potentially causing cancer creates a strong sway towards natural and “free from” marketed products.
Point #4: The Regulation on Banned Ingredients Is Stricter in the EU (1,300) than the US (11)
The vast discrepancy between the quantity of prohibited product ingredients in the US versus the EU is concerning, but what are the nuances behind the numbers? Firstly, some of the ingredients listed are radioactive materials or federally banned mercury, so brands are unlikely to use them in the first place. The main instances of contamination with mercury are seen on the gray market with adulterated products. Secondly, for companies wanting to sell globally, creating a universal SKU which covers all safety regulations, whether from the US or EU, is the most efficient use of time and resources. Brands are therefore unlikely to create different products for different markets, and therefore would be adhering to stricter regulations to begin with. “I wouldn’t agree that regulations are lacking; different places utilize different systems, and one isn’t inherently safer than the other,” Dr. Hirsch states.
In regards to the EU’s vastly longer list, culprits could be the EU’s REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulation that inventories any chemicals that have adequate evidence as being a carcinogen, mutagen, or reproductive toxicants (shortened as CMR), as well as the precautionary principle, which bans any ingredient as soon as there is any evidence, not causality, that there are adverse side effects. This equates to a lower threshold when it comes to ingredient banning in the EU compared to the US. For example, lilial, which was banned for being a CMR, was seen as not posing a threat if used in a singular product, but rather if used on a daily basis with multiple products which would result in crossing the safety threshold.
As another example, parabens have been largely avoided amongst consumers and the industry due to their potential link to endocrine disruption and cancers. But not all classes of parabens were problematic: methylparaben for example, was not banned. Isopropylparaben, isobutylparaben, phenylparaben, benzylparaben, and pentylparaben were. Furthermore, parabens are also found naturally in certain fruits like blueberries, and are used as a preservative in foods such as confectionaries and dried meats. If one forgoes preservatives altogether, the product can expire far too quickly (resulting in excess waste) or grow mold and bacteria, which is far more damaging to health.
PFAS are the latest ingredients getting a sharper look under the microscope. A study recently found higher levels of the materials in longwearing and waterproof cosmetic products, although these materials can also be found in packaging, non-stick cookware, and water sources. A 2018 study states that “in the most conservative scenario a risk cannot be completely ruled out if several cosmetic products containing PFAS are used at the same time—this very conservative scenario is, however, not considered to be particularly realistic.” Davis proclaims that “cheaper formulas or longer lasting products cannot possibly make up for the impacts and long-term costs associated with the public health disaster that is PFAS-contaminated drinking water and breast milk. The makers of PFAS are externalizing those costs, and society and the planet are paying for them.” In an ideal scenario, PFAS would be removed from all sources, not just beauty products.
On the subject of cost, affluence and access rarely gets discussed in the context of sustainable and clean cosmetics. On average, most products created without preservatives and other disputed ingredients are in the mid to high-end price range. Will someone struggling to make ends meet be able to pay double the price to avoid certain ingredients? Probably not. Can the brands lower their prices to accommodate these consumers while also avoiding a profit loss? Unlikely. Race is also an undeniable factor in the universe of hazardous cosmetics.
“Since the inception of this industry, people of color have been told that they are not the standard of beautiful, and that they need to use powders, lacquers, fragrances, lighteners and straighteners to be more beautiful, and more ‘acceptable’ to mainstream, white-dominated society. This is a toxic message, with toxic chemistry—and we know that those chemicals are getting into bodies of color at even higher rates than white bodies,” Davis comments. “In the last few years, we’ve seen a growing awareness and resistance to these practices, led by environmental health organizations, some leading brands, and of course, people of color pushing companies from within and as customers. I am optimistic that we're seeing overdue change here.” She also agrees that accessibility is another core factor needing change. “Not everyone can shop at Credo, for example—and our brand partners need help moving the supply chain too. That is why we need to pass state and federal policies that are more protective of workers, customers and the environment,” Davis adds. “The Safer Beauty Bill Package is how we start to really make change here. I challenge the largest companies—those with the most resources and customers—to raise the bar and to assess their ingredients for safety and sustainability, and make cleaner products available to all.”
Another point on ingredients was the loophole of the Parfum listing on the INCI list, which can include thousands of undisclosed and potentially harmful ingredients, according to the series. It is meant to protect the fragrance formula from competitors, but could it be a workaround for companies looking to hide unsavory chemicals? Letting consumers know exactly what is inside their products is undoubtedly important, but disclosing all ingredients could present a challenge for packaging manufacturers given that most fragrances are made up of 30 to 50 ingredients on average. Furthermore, creating a beauty product with no allergen potential whatsoever would severely limit the industry’s production. It’s akin to banning peanuts from all food products because of the allergen potential for a certain demographic.
If every single chemical in a product were disclosed, it would make for intensely long ingredient lists that consumers may or may not read. But it’s also important that consumers be able to spot potential allergens in their products if they indeed have a reaction to them. And while institutions like International Fragrance Association (IFRA) work on maintaining the accuracy and relevancy of such lists, what is the fitting level of discernment when it comes to banning potential allergens?
As it stands, there is a strong lack of trust in the beauty industry. Cases like Johnson & Johnson or DevaCurl aren’t helping the matter, but there have also been few voices willing to comment on the counterargument to clean beauty, given the impassioned nature of the subject and the strong weight of fear in consumers’ minds. “We all want to use products that don’t kill us, most people care about the environment. There are a lot of chemicals that aren’t well regulated, but the documentary puts it all on beauty. Stopping beauty products is not going to stop climate change,” Wong states. In terms of plastic waste, the medical or food industries also play a part. The beauty industry creates 120 billion units of plastic packaging annually, but by comparison COVID test kits resulted in 2,600 tons of waste, while takeout lunches in the UK created 11 billion items of plastic packaging waste. In short, many industries have a part to play in our health and the health of the environment, although this doesn’t alleviate the responsibility of each from making changes for the better.
Davis is campaigning for immediate and widespread action. “Let's not waste time debating terms like ‘clean’ and ‘sustainable,’ or sowing doubt in the minds of customers, which might lead them back to thinking that maybe conventional—with its continued reliance on old-school chemistry and unsustainable packaging—is the way to go,” she proclaims. “Instead, start taking a bite of the problems in a real, meaningful way. There are so many things we can work on, and it's better than the status quo, which is totally unsustainable. We don't have time for generating more debate or creating misconceptions. Let's get to work!” For consumers, that also means voting with their dollars, as she notes that “supporting brands that are committed to safety, sustainability, transparency, and equity is a strong signal to the market, and helps the good brands to keep doing what they're doing.”
For Renfrew, continuous and joint efforts from brands and consumers are also an important pillar in getting the necessary legislative changes made. “We started the Counteract Coalition to unite industry forces, we’ve mobilized our community to send thousands of emails, texts, and arrange meetings with their local representatives, and we’ve already contributed to the passage of 10 better beauty laws since we started in 2013, including two federal laws, and 8 state laws,” Renfrew proudly explains. “We are encouraged to see so many others supporting the movement and shining a light on this important topic so that we can continue creating better and safer products for all. We know that we cannot create long-lasting, impactful change in the industry alone.” For Beautycounter, this means collaborating with the Science Advisory Council, which specializes in medicine and public health policy, as well as the company’s own Counteract Coalition, a collective of beauty businesses dedicated to passing more health-protective laws.
The subject of safe cosmetics is an emotionally charged, highly divisive debate that requires unity if it is to be successful. Regardless of one’s stance, transparency remains paramount, and there is undoubtedly change ahead—the only question is, in what direction?
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