Cosmetic manufacturers face a long, arduous journey in their quest to develop environmentally-preferable products. Here’s a roadmap to get going.
By Lambros Kromidas, M.S., Ph.D.
Vice President of Product Integrity
This is yet another article on the eco-friendly movement known as green. Last year, was a year that raised everyone’s awareness of green. It’s been discussed, talked about, or mentioned in all information media from word of mouth to TV, radio, newspapers, magazines, etc., on a daily basis.
In fact, Happi had at least one article or discussion point related to green in every single issue. That’s because our industry was (and is), very interested in this movement because there is plenty of money to be made.
However, as extensively as it’s covered, there is still some confusion among our industry, customers and consumers. As such, and since interest has not abated, there is still room for further discussion. This is a diffuse and vast subject matter and there is no way it can be covered in detail in just one or two articles. Hopefully this article will give you a general idea, above and beyond what you may already know, of what green is all about.
Hopefully, it will peak your interest, raise questions and galvanize you to action. But most of all, the article is intended to enlighten you in addressing this matter within your company, with your customers, consumers and the general public.
Because the topic is so vast, it will be covered in two articles. Part I topics include sustainability, natural, mineral, organic, biodegradable and certifications/seals. Although each of these elements will be covered in detail, it is important to note that it is possible to develop a green product without taking into account any of them.
Part II, to be published in April, will explain how pervasive the green phenomenon is and how some industries capitalize on it. In addition, the article will detail what some cosmetic companies are doing to become more green and how the rest can’t help but stay on the profitable road to green.
Shades of Green
Green as a concept is not clearly defined anywhere. But it is a concept, lifestyle and/or code of ideals whose essential elements are: sustainability, naturalness, wholesomeness (organic), environmentally-friendly, cruelty-free, safe for use or consumption, and economic vitality. The more of these elements a process or product meets, the greener it is.
For example, one company produces a biodegradable product, but the energy used to make it and transport it is not optimized (i.e., used too much or was petrochemical-based). The fact that this product is biodegradable—something perceived as good for the environment—means that the product is green, but it is a light shade of green.
However, if solar energy was used to make this biodegradable product—an environmentally friendly and sustainable source—then the product becomes a little greener or a medium shade of green. If we take it one step further and say that solar energy was used to make this biodegradable product and biogas energy is used to transport it, then we have a product that is a dark shade of green. So going green or developing a green product is not an all or nothing situation. It is a progressive phenomenon; a balancing act whose goal is to reach ever darker shades of green. In other words there is no such thing as a totally green product or process but only shades of green. To simplify this concept I developed the model shown in Figure 1.
My model, if you will, is an equilateral triangle lens that looks at the three essential elements of greenness:
1. Respecting living things;
2. Respecting the environment and
3. Economic development.
The shade of green that a product or process is, depends on the balance of these three essential elements. I use this model as a tool to view “greenness.”
Part II of this article will provide examples of this pervasive, global phenomenon. Green is more than just a trend.
Many use the term sustainability as though it is synonymous with green. It is not! Unlike green, sustainability is a practice that has been around for a long time and is therefore more clearly defined. It is but one of many elements of green. Sustainability’s goal is to achieve parallel care and respect for the ecosystem and the people.1 It was best defined by the Norwegian Prime Minister Gro Harlem Brundtland in his 1987 United Nations report when he stated that sustainability “meets the needs of the present without compromising the ability of future generations to meet their own needs.”2
| Fig. 1: Green Triangle
What is Natural?
Now let’s consider a couple of terms that our industry promotes, despite a lot of confusion surrounding them. What does it mean to be natural or organic? Let me tackle natural first. Imagine yourself in the fruit and vegetable aisle in the supermarket. I’m sure you are of the opinion that these goods are natural. I’m also sure you’ll agree that these goods were farmed. But I ask you, are farmed fruits and vegetables natural? Or are only their wild counterparts, cultivated without the aid of man, natural? Do you know what a wild watermelon, cauliflower, or corn look like or whether they are edible? What about you and your family who are about to purchase and eat some—are you considered natural creatures carrying out natural activities?
Table 1: Acceptable Processing Methods
Encapsulation Extraction, including solvent
Grinding Ion exchange
Let’s cut to the chase! If one assumes that “man” and his activities are not natural, then all the farmed fruits and vegetables are not natural. If we assume the opposite, then everything is natural. So, depending on your outlook, either everything is natural or…well, it is something else, something that you have defined to meet your needs. That is the cosmetic industry’s stand when it comes to natural cosmetic products. No two companies may agree on what makes a natural product. Why? Because not many know what these terms mean despite an increasing consumer awareness and interest in naturals and organics. As such, a lot of problems relate to definitions and perceptions of what actually is natural. Unlike organic foods, there is no U.S. or EU regulations for natural and organic cosmetics. But there are private standards of natural and organic cosmetics, as I will detail later. Anyway, as a result of varying perceptions, some conventional cosmetics are marketed as natural even though they only contain very little natural ingredients. So take the fact that there is no clear definition of what is and is not natural, compound that with no regulatory standards, and you have a very confused consumer base.4 Note that I emphasized natural ingredients. If one can clarify what is a natural ingredient, one would be able to formulate a natural cosmetic. Because of the heightened industry interest and lack of clear guidance, I made an attempt to address what is a natural ingredient and to perhaps galvanize our industry to action by publishing my views in a previous article in this very magazine back in December, 2004.5
More recently, Michael Indursky, chief marketing officer, Burt’s Bees, chaired a working group convened by the Natural Products Association (NPA) to create guidelines for what constitutes a natural product.6 Its aim is to make the concept of natural comprehensible to consumers and to develop a seal to identify natural products. It’s a great endeavor and very timely if they truly succeed. To learn more, readers are encouraged to go on the Burt’s Bees website (www.burtsbees.com).
I don’t know what this would mean to this endeavor since recently (November, 2007) the bleach manufacturer Clorox bought Burt’s Bees for a whopping $925 million.7 Not bad for a company whose income is about 20% of the purchase amount. But this only goes to show you that large companies are beginning to pick off small natural/organic producing firms to capitalize on the growth of this niche market, one that Clorox executives think is a consumer megatrend. They want to better the Clorox image by turning green and they hope Burt’s Bees will show them the way.8 Clorox is repositioning some of its products to be more eco-friendly. In December, the company introduced Green Works, a line of household cleaning products labeled as 99% natural.8 Anyway, even if Burt’s Bees and the NPA do not succeed in setting standards for the industry to address natural cosmetics, maybe Organic and Sustainable Industry Standards (OASIS) or some other, yet-to-be-formed industry group will succeed. OASIS is a new association formed by several U.S. companies in the natural and organic cosmetic sector.9 I’m glad to see that our industry is active in this respect but I hope it does not become so divided that it confounds the matter even more. What is needed is a harmonized set of standards for natural and organic cosmetic products that can be applied globally.
Nevertheless, the bottom line is that, to date, there is no legal definition of natural for drugs, cosmetics, fragrances or toiletries, nor for dietary supplements or most foods. The only governmental definition is that given by the U.S. Department of Agriculture (USDA) for meat and poultry. The USDA term applies only if the product is minimally processed and contains no artificial ingredients, coloring agents and chemical preservatives.10,11
As I stated in my previous article on this subject,5 because there is no legal definition for what is “natural,” defining it in a cosmetic sense is especially confusing. Some in the industry insist that anything refined is not natural. Most believe that anything synthetic or chemically-modified is absolutely not natural. Others argue that ingredients that are made synthetically to an exact counterpart in nature (nature-identical) can be considered natural. For example, coconut oil can be squeezed from the coconut, but it can also be made synthetically to the exact same qualities. The synthetic can be made more efficiently and is cheaper. As such, if one puts both processes under the green lens (Fig. 1) one may be surprised to find that although the synthetic coconut oil may not be natural it may be a greener product. So, in the development of greener products one must consider everything up to the point of putting the product on the store shelves. Getting back on the subject of natural ingredients, as I stated above, if one knows what makes a natural ingredient one can formulate a natural product. If we do not accept that everything is natural and assume anything man-made is not natural, then anything chemically synthesized or modified is not natural. This is the basis of International Fragrance Association (IFRA) definition based on the ISO standard 92325.12,13
That is, only substances isolated from natural sources by “purely physical means” (see Table I) are considered natural. Based on this ISO standard, synthetically reconstituted ingredients, synthetic nature-identical ingredients, and intentionally chemically modified natural raw ingredients are not natural ingredients.
I also stated in my previous article,5 more important than what our industry thinks is what consumers think of natural products. Most (≥75%) believe that natural products contain at least 90% natural ingredients and are made without chemical additives and are pure and wholesome. Also, the majority (86%) of consumers believe that natural products are safe. Of course what consumers believe and what’s reality are two different things. Just because something is natural or organic does not mean it is safer for consumers or the environment. Indeed in many instances the opposite is true. This is something that again one needs to put under the green lens (Fig. 1) if the aim is to develop a green rather than natural or organic product.
Bottom line: cosmetics, toiletries and fragrances are not regulated by the USDA but by the Food and Drug Administration. The FDA and the EU’s Cosmetics Directive have no specific regulations regarding the claim natural. Furthermore, unlike organic claims, there are no state regulations regarding the claim natural. California is the only state that regulates organic claims for all products, including cosmetics. “Natural” claims are regulated just like any other claim. They must be truthful and not misleading.
Why produce natural cosmetic products? Because, even if one does not consider keeping pace with the competition, new chemical scares and unverified or unsubstantiated claims about health benefits of natural and organic products will continue to drive sales growth. Furthermore, gains will continue to be fueled by the green movement.
Just a word about chemical scares: On Nov. 13, 2007, the Organic Monitor (www.organicmonitor.com, a green tracking website) reported that 89% of UK consumers are concerned about toxic chemicals, especially preservatives and surfactants. As such, consumer attempts to avoid negatively publicized chemicals is driving the UK market for natural cosmetic products.14
Are Minerals Natural?
Many in our industry indirectly position their products—powders for example—as natural by claiming they contain natural minerals which are good for you for one reason or another. So let’s define a mineral. There is much confusion about whether a mineral can be of synthetic origin. What I gather by looking at numerous sources is that a mineral is an element or chemical compound with a distinct chemical formula that does not change, that is normally crystalline (has an ordered atomic structure) and has been formed as a result of geological processes. That is, a mineral is not artificially made and therefore natural.15,16,17,18 That’s the geologic definition of a mineral. There are also biologic, economic, legal, as well as a U.S. government definitions.17 All these definitions have one common theme, that a mineral is naturally sourced. Products made of 100% minerals are natural but not if they contain iron oxides, titanium dioxide, bismuth oxychloride, zinc oxide, etc. as minerals. These ingredients although made from natural starting material (atoms) are synthetic (man-made) and therefore not natural. Of the iron oxides, only hematite is natural but one cannot use it as a colorant because it does not meet Code of Federal Regulations (CFR) criteria.
What is Organic?
Let’s go back to that fruit and vegetable aisle in the supermarket. Although I’ve raised doubts about whether fruits and vegetables can be considered natural, there is no doubt that they can all be farmed organically. The National Organic Program (NOP) is the regulatory body overseeing organics and was created in 1990 by the Organic Food Protection Act of the USDA. The NOP defines organic food as produced by farmers who emphasize the use of renewable resources and the conservation of soil and water to enhance environmental quality for future generations. Organic meat, poultry, eggs and dairy products come from animals that are given no antibiotics or growth hormones. Organic food is produced without using most conventional pesticides; fertilizers made with synthetic ingredients or sewage sludge; bioengineering; or ionizing radiation.
After much ado, the USDA is allowing NOP-approved agents to use its seal on cosmetic products if indeed that product meets all NOP requirements. Much ado because at first the NOP did not want to have anything to do with cosmetics. In April, 2005, it issued a statement that personal care products can’t be NOP certified and thus the USDA seal is not permitted on such products. The USDA had no objections to private certification or using ingredients certified to NOP standards. Claiming organic content percent on the primary display panel was fine. In June, 2005, Dr. Bronner’s Magic Soap and the Organic Consumers Association (OCA) sued the USDA over the right to use the seal. The OCA is a nonprofit consumer advocacy organization working to make organic agriculture the dominant form of food and fiber production. Soon after (August, 2005) the USDA sent a memo to the NOP-authorized certifying agents, to allow cosmetics and personal care products meeting NOP standards to carry the seal.20,21,22
On Aug. 6, 2007, Nature’s Gate launched the first USDA-sealed organic lotion. Rainwater Organics is made of 95% organic content, excluding water and salts. It is manufactured in a facility that operates according to the USDA’s organic rules. Note that in order to obtain the seal, the formula must meet the requirements and all operations of manufacturing must follow certain rules. These rules regulate receiving, warehousing, mixing, filling, cleaning, sanitization, etc. Further to its organic content, the packaging for this line is made of 25% recycled plastic. It also has two additional seals—cruelty free and vegan.23
As already noted, California, via the California Organic Products Act (COPA) of 2003, is the only state that specifically regulates organic claims in all consumer products including cosmetics.27,28 Cosmetic products sold in California that claim, “certified organic” and or “made with organic ingredients,” must be made with at least 70%, certified organic ingredients as defined by the NOP. There is no restriction on the other 30% of ingredients. However, as per NOP requirements in Figure 2, the USDA Organic Seal cannot be obtained for anything less than 95% organic ingredients—not even in California.
In the EU, there are no specific regulations regarding the labeling of organic cosmetic products. On June 28, 2007 the EU published specific organic regulations that deal strictly with food and feed, but with no reference to cosmetic products. In regards to processed food, at least 95% of its agricultural origin ingredients by weight must be organic.29 As a consequence, last Fall, some prominent European companies in the business of producing natural and or organic cosmetics got together to form Na True.30 Na True is currently composed of Weleda, Dr. Hauschka, Santeverde, Primavera and Logona. The group’s aim is to represent the interests of the natural/organic cosmetic industry.
A claim that is beginning to appear on cosmetic products and is strongly associated with being green, is “biodegradation.” As the name implies, it is the degradation of substances to simpler byproducts (Figure 3)31 due to the action of living organisms, in particular microorganisms. In this breakdown pathway, the monomers may be more toxic and thus less environmentally friendly than the polymers. Also note that the ultimate by-products, carbon dioxide (CO2) and methane (CH4), are considered greenhouse gases.
The biodegradable claim on cosmetics is not specifically regulated in the U.S. or EU except by the Federal Trade Commission (FTC).32 The FTC requires that all the organic (i.e., carbon-based) matter in a product is biodegradable. Inorganic matter is not considered. Therefore, you cannot make a biodegradable claim on an all inorganic formula. However, other environment friendly claims may be made.
There are multiple guidelines to determine biodegradation depending on which agency’s or organization’s guidelines one uses, material to be tested and type of biodegradation one is interested in.29,33
Certifications & Seals
There are numerous recognized green based certificates and seals that companies may apply for depending on the product and what it is they want to convey about their product. Table II shows the most recognized seals in the U.S. and EU. Certification is a process based management system whose aim is to protect the integrity of the product by defining standards, practices and material. Seal principles cover the entire production and distribution process—from field to shelf. Getting a seal or logo for the most part (if not self-made), is a third party verification or accreditation that your product meets a certain set of principles. Some seals have stricter criteria to follow than others. Still, there is an overlap and it is possible to obtain more than one of the seals shown above on a given product.
1. http://en.wikipedia.org/wiki/sustainability (as retrieved 8/30/07).
2. United Nations, 1987, “Report of the World Commission on Environment and Development.” General Assembly Resolution 42/187, Dec. 11, 1987 (http://www.un.org/documents/ ga/res/42/ ares42-187.htm).
3. http://en.wikipedia.org/wiki/sustainability (as retrieved 8/30/07).
4. Organic Consumers Association, 2006, Natural cosmetic boom in EU, though debate continues over which brands are actually organic, press release. NPIcenter, Mississauga, ON, Canada, Sept. 19 (http://www.organicconsumers.org/articles/article_2499.cfm, retrieved 8/16/07).
5. Kromidas, L. 2004. Making natural claims for personal care products. Happi 41(12):55-59.
6. Laus, Molly. May 28, 2007. Burt’s Bees & Natural Products Association to develop standard for naturals. The Rose Sheets, page 3.
7. Financial News. Dec. 2007. Clorox acquires Burt’s Bees. Happi, 44(12):112.
8. Story, L. Jan. 6, 2008. Can Burt’s Bees turn Clorox green? Sunday Business, The New York Times.
9. Trade Talk, 2008. OASIS to set organic health and beauty standards. Cosmetics & Toiletries, 123(1):10.
10. Hibbert, R.G. Nov. 22, 1982. United States Department of Agriculture, Policy Memo 055. Subject: natural claims (http://www.fsis.usda. gov/regulations/labeling_policies/index.asp).
11. Food Safety and Inspection Service. August 2003. Meat and poultry labeling terms. United States Department of Agriculture, Consumer Education and Information (http://www.fsis.usda. gov/oa/pubs/lablterm.htm).
12. Matthias, V. Dec. 5, 2005. Statement on the claim “natural” status as related to fragrance ingredients and compounds. IFRA Information Letter 737.
13. ISO 9235, 1997. International Standard. Aromatic natural raw materials – vocabulary (http://www.iso.org/iso/en/cataloguelistpage.cataloguelist).
14. Bird, Katie. Nov. 13, 2007. Chemical concerns drives UK naturals market. Cosmetics design-europe.com (http://www.cosmeticsdesign-europe.com/news, as retrieved on 11/13/07).
15. http://webmineral.com/Mineral_Definition.shtml (retrieved 7/2/07).
16. http://muskingum.edu/~ericlaw/pd_ courses/geo1101/minerals/topics/minDefinition.html (retrieved 7/2/07).
17. http://academic.brookly.cuny.edu/geology /leveson/core/linksa/mineral_def.html (retrieved 7/2/07).
18. http://www.uky.edu/KGS/rocksmn/ definition.htm (retrieved 7/2/07).
19. National Organic Program: www.ams.usda. gov/nop/Consumers/brochure.html (retrieved 8/29/70).
20. Robinson, B.C. (Deputy Administrator, Transportation and Marketing Programs, Agricultural Marketing Service). Aug. 23, 2005. Certification of agricultural products that meet NOP standards.Memorandum to all USDA accredited certifying agents.
21. The Star-Ledger. Aug. 25, 2005.
22. CTFA News. Sept. 12, 2005.
23. Global Cosmetic Industry.Market News. Aug. 6, 2007. Natural company launching first USDA-sealed organic lotion (retrieved on-line, 8/9/07).
24. Mathews, I. 2007. More cosmetics are going green. Happi, 44(11):54-56.
25. Grayson S., 2007.Origins wins the organics race to department stores. Happi, 44(12):50-51.
26. Macchio, R. (Sr. Vice President, Global R&D Chief Scientific Officer at Coty Inc.) 2007. Personal communication.
27. Steinberg, D. June 20, 2007, Natural ingredients in cosmetics.IntertechPira Workshop. Washington DC, USA.
28. California Health and Safety Code, Article 7, The California Organic Products Act of 2003, Division 104, Part 5.
29. Official Journal of the European Union, 20.7.2007 EN L 189/ 1-23. Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products and repealing (EEC) No 2092/91.
30. Bird, K.December, 2007. Natural cosmetics lobby group formed. Cosmetics, design-europe.com (retrieved 12/18/07).
31. De Wilde, B.Organic Waste Systems (OWS). 2007. Personal communication.
32. Federal Trade Commission. Facts for consumers.Sorting out ‘Green’ advertising claims (http://www.ftc.gov/bcp/edu/pubs/consumer/general/gen02.shtm).
33. Code of Federal Regulations. Title 7: Agriculture, Part 2902 – Guidelines for designating biobased products for Federal procurement, Subpart A – General.
35. Organic Consumers Association. September 19, 2006. Natural cosmetics boom in EU, though debate continues over which brands are actually organic. press release, NPIcenter, Mississauga, ON, Canada.