Though “clean” and “conscious” beauty may once have occupied a niche segment of the market, “free of” lists, mission statements, and certification seals are not just one of the industry’s hottest trends. These ingredient policies are also an opportunity for brands to define and differentiate themselves in an increasingly crowded marketplace.
Broadly speaking, an ingredient policy is a list of restricted ingredients as defined by a cosmetics brand or retailer. Though an ingredient policy is likely to include many of these “free of” claims, it may also include attributes such as “organic,” “vegan,” or “sustainably sourced”.
In the United States and in many other countries, there are no regulations pertaining to “clean” or “conscious” beauty. However, the FTC does require all claims and marketing to be truthful and substantiated, or they are considered false advertising.
Because ingredient policies and their related claims are not subject to a long legal review and approval process, they can change and quickly adapt to emerging consumer trends.
Ingredient policies can be established to restrict the use of raw materials and substances in a variety of ways. In some cases, a policy will restrict individual ingredients explicitly. For example, toluene is frequently listed on ingredient policies as prohibited due to the risks high concentrations of its vapors can pose to pregnant users, including organ system, developmental, and reproductive toxicity.
Ingredient policies can also place restrictions on groups or classes of ingredients. Phthalates are a group of ingredients commonly found on ingredient policies because scientific studies suggest that they can cause developmental and reproductive toxicity, as well as endocrine disruption.However, it is important to note that phthalates are not currently banned in the European Union in fragrances, and as reviewed by the US National Toxicology Program, or NTP, have been found to have a minimal to negligible risk due to exposure.
Ensuring a formulation is free of a particular ingredient group is challenging, as all members of that group must be defined to be avoided during formulation. The cosmetics industry maintains a library of all substances used in cosmetic products and their official International Nomenclature Cosmetic Ingredient (INCI) names.
This defined set of ingredients combined with research and an understanding of their chemical properties can be used to create these ingredient groups. In some cases, such as with parabens, this is a relatively easy task as each ingredient has “paraben” in the name. For other groups, such as ethoxylated substances, a deeper understanding of chemical properties is required to define that group.
In addition to restricting the INCIs that may be used in a formulation, ingredient policies can also place restrictions at the raw material level. Attributes such as “vegan” or “nanomaterial free” can’t be definitely determined by reviewing a formulation’s INCI composition.
Instead, they require an examination of the raw material supplier documentation. For example, beeswax can be both naturally and synthetically derived. If an ingredient policy requires all formulas to be vegan and the formula in question contains beeswax, verifying its source is critical to ensure compliance.
Ingredient Policy Screening
Understanding which ingredient policy requirements are substance-based versus raw material-based is important for effective ingredient policy screening. Substance level requirements allow an individual to simply verify the presence of a particular ingredient or group to determine compliance.
If requirements are raw material-based, then clearly defined supplier documentation for each raw material is needed. If an ingredient policy requires raw materials to have a certain attribute, such as gluten free or vegan, knowing to request the correct documentation from suppliers that will verify these claims will help streamline the ingredient policy screening process.
But collecting documentation is only the start. Specialized compliance software with screening logic powered by an organised repository of raw material, substance, and attribute data allows manufacturers to screen formulas against various ingredient policies.
Without such an automated tool, screening every raw material in a formula against the growing number of ingredient policy standards would be a tedious, manual process that is prone to error and puts the manufacturer at risk for costly delays.
What to Consider When Establishing an Ingredient Policy
The first step to establish an ingredient policy is to consider what your brand’s values are. A brand might select ingredients for restriction for a variety of reasons, from suspected reproductive harm to known environmental impact. Understanding this reasoning is key, as it allows the brand to both define their values and act ahead of the market to restrict additional ingredients when new studies show potential health or environmental hazard.
Next, the brand needs to understand what well-researched scientific studies actually say about each ingredient or raw material, and if the reason for its use or restriction aligns with the company's values. Is the formula free of a particular ingredient or raw material because of sustainability concerns?
Or is it because of a popular perception that it is not safe to use? These are factors that must be carefully considered when developing an ingredient policy.
Brands and manufacturers should also have a plan for how to ensure that their formulas meet the standards of their own ingredient policies, or those of the retailers they hope to partner with. Part of the challenge of implementing an ingredient policy is how to verify that formulas comply with it.
Tools that can screen a formula for ingredient policy compliance can make this easier. Like all cosmetics claims, it is up to the brand or manufacturer to source, screen, and keep substantiation documentation on their ingredients and raw materials.
Keeping Up with a Moving Target
Beauty and consumer trends change quickly, while the issues and values consumers care about evolve over time. With that in mind, it is crucial for cosmetics companies to develop a road map that includes the ingredient policy-related issues they can address now as well as those they can set goals for addressing in the future, and with the agility to respond to new requirements in between. As new formulas are developed and new ingredient policies are introduced, screening early will allow formulation to progress with fewer errors and delays.
Another step that brands can take is to start educating their marketing, research and development, manufacturing, and other teams about their ingredient policy and what the documentation standards are. Sharing goals helps align everyone to the company’s values.
Ingredient policies present brands an opportunity to share their values of ingredient transparency, consumer safety, sustainability, and environmental awareness with consumers. Careful consideration should be taken when deciding whether or not to develop an internal ingredient policy or adhering to policies set by retailers. It is also important to ensure that ingredient policy standards can be validated, and to have a plan for how to develop new products that align with policy changes over time.
Technical solutions, such as raw material and attribute data repositories and screening tools, can help reduce the risk of errors and allow formulas to be screened early and often in the development process. These considerations are all key to achievable, effective ingredient policies.