The regulatory landscape: upcycling in beauty & personal care

Published: 23-Oct-2023

With upcycling ingredients on the rise, there's a need for clear definitions, the importance of trustworthy environmental claims, and the evolving landscape of circular economy practices

Author: The Upcycled Beauty Company

Upcycling, or the process of transforming discarded or waste materials into higher-value products, has gained substantial traction over the last years as brands and consumers alike seek to reduce their ecological footprint and promote circular economy practices. As this movement continues to gain momentum, stakeholders within the beauty and personal care industry must navigate a complex regulatory landscape that encompasses a multitude of considerations, from labelling requirements to broader environmental impact assessments. In this blog post we will delve into the challenges and opportunities that lie at the intersection of upcycling innovation, compliance and conscientious consumerism.

Seeking clarity in brands' environmental commitments

According to the Sustainable Beauty Coalition, a survey of 23.000 beauty shoppers found almost half are looking for more information and clarity on brands' values and commitments to the environment.1 This sentiment is further corroborated by the findings of Provenance, a global leader in sustainability communications technology, which has shown that 79% of beauty shoppers have doubts about the trustworthiness of sustainability claims, highlighting the issues of greenwashing and unverified environmental claims within personal care.2

But there are little to no legal definitions of sustainability within cosmetics, so this is an area where broad statements and misleading claims can be made with minimal to no legal or reputational consequence.3

There is also no legal or industry-wide accepted definition of an upcycled cosmetic ingredient or an upcycled cosmetic finished product.

The regulatory landscape: upcycling in beauty & personal care

Upcycling certification and industry collaboration

Currently, personal care raw material manufacturers can use the Upcycled Certified™ standard created by the Upcycled Food Association (UFA) to help verify their upcycled sustainability claims.4 In 2020, the established definition of an "upcycled food" was determined by a team of experts from Harvard Law School, Drexel University, World Wildlife Fund, Natural Resources Defense Council, ReFED, and others for use in policy, research, and more:

"Upcycled foods use ingredients that otherwise would not have gone to human consumption, are procured and produced using verifiable supply chains, and have a positive impact on the environment."

The Upcycled Beauty Company is a member of the UFA, and they "Upcycle Certify" their Full Circle ingredients as this is the current gold standard for authenticating upcycled cosmetic (and food) raw materials, preventing greenwashing claims. However, because it is possible that cosmetic raw materials can be upcycled from other sources than food, such as forestry by-products, there is a gap in the scheme. With this in mind, they are collaborating with industry and beyond to find a collective understanding and definition more appropriate to upcycling in personal care for both raw materials and finished consumer products.

The regulatory landscape: upcycling in beauty & personal care

The evolution of upcycling in the beauty industry

If we look at the history of personal care, upcycling, by definition, is not a new concept. Raw materials like lanolin, collagen and glycerine are all by-products from other industries. however, over the last decade the industry has moved away from synthetic and animal-derived products replaced by an ever-growing demand for natural, plant-based materials. Most recently, as concerns over sustainability have increased, the interest in sustainable sourcing and provenance has also increased, one method of which is upcycling. The personal care industry has come full circle.

This drive towards upcycling and circularity is not only being pulled by consumer demand, but is being pushed by changing legislation as well.

In November 2022, the European Commission adopted the new Corporate Sustainability Reporting Directive (CSRD), which requires 50.000 European companies to report on their resource use and circular economy performance as of 2025. A recent analysis of 400 companies by Circle Economy and World Benchmarking Alliance, found only 22% of corporate sustainability reports include at least one of the quantitative indicators on circular economy performance that is required by the new CSRD. This means that companies need to start now, in 2023, to identify their circular economy related opportunities and risks, develop circular strategies and start collecting data.5

Implementing the practice of upcycling

Looking to the future, we can assume that these types of sustainability reporting directives will be expanded to more and more business regardless of industry and size, requiring circular economy practices to be adopted more widely across beauty and personal care as well.

For personal care, upcycling and circular processes can be implemented through various means. We can obtain ingredients from sustainable and ethical sources that reduce waste, such as using by-products from other industries — this could be from forestry, food and drink. Working with upcycled material sources lowers the carbon footprint, water footprint and land use impacts compared to that of a raw material derived from a primary resource.

But already, many questions are posed with regards to certain cosmetic ingredients and if they can be defined as upcycled or not. For example:

  • Can ingredients produced via valorisation be classed as truly upcycled?
  • Bovine or fish derived collagen are often manufactured from by-products from the food industry, but based on the environmental impacts of intensive farming and fishing, there are other environmental and moral issues to be considered here too.
  • Can a legacy cosmetic ingredient be newly declared as upcycled after years already on the market? Or is this another form of greenwashing — just jumping on the latest sustainability trend to boost sales?

Perhaps all of these examples could lead to viable upcycled cosmetic ingredients, as long as the sourcing and supply chain are validated and demonstrate a positive environmental impact. Moving forward, an important part of the upcycled beauty movement will be the need to clarify upcycled cosmetic definitions, standards and regulations — preferably on a united and global basis. Working to an approved and widely adopted standard will help to limit the use of generic sustainability claims surrounding upcycling, ingredient provenance, sourcing transparency and circular economy principles within beauty and personal care.

With over 340 upcycled ingredients to choose from, Covalo offers a plethora of options for your next project. So, which one will perfectly match your vision? It's time to get creative and explore the endless possibilities!


1. Sustainable Beauty Coalition (2022) Planet Positive Beauty Guide. Available Online. Accessed 29.08.23
2. Provenance (2022) Skin Deep Beauty Report. Available Online. Accessed 29.08.23
3. The Recursive (2022) How NOT to Greenwash: A Step-by-Step Guide for Business Owners and Communicators. Available Online. Accessed 29.08.23
4. Upcycled Food Association. The Standard. Available Online. Accessed 29.08.23
5. Circle Economy (2023) New Legislation Coming, But Only 22% Of Companies Ready To Report Quantitatively On Circular Economy. Available Online. Accessed 29.08.23
6. Mansel-Pleydell, S. (2023) Circularity is your survival strategy in the low growth era.

Relevant companies

You may also like