Clean Beauty are cosmetic products that do not contain a predefined set of cosmetic ingredients.
The lists of cosmetic ingredients that are not allowed in Clean Beauty products are determined by retailers of cosmetic products including:
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Clean At Sephora
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Conscious Beauty at Ulta
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Credo Clean
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Target Clean
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EWG Verified
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Whole Foods Premium
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Walmart’s Made Without List
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and others.
Who Determines Clean Beauty Standards?
Each retailer defines their own list of ingredients that are not allowed in cosmetic products to comply with their Clean Beauty criteria, but by-and-large the overlap of the “not-allowed” ingredients in these various retailer standards is 95%+.
Brands submit an application to the retailer to obtain that retailer’s Clean Beauty certification Seal. Clean Beauty products bearing the retailer’s Seal are generally curated into a Clean Beauty section of the retailer’s store and/or website making it easy for consumers to identify the products bearing the Clean Beauty Seal. The direct analogy is Organic produce at the supermarket.
Are Clean Beauty Products Regulated By The FDA?
Yes, Clean Beauty products must comply with all FDA regulations for product Safety Substantiation and are not exempt from any of the regulations that govern cosmetic products for human use.
Clean Beauty Defined
Simply put: Clean Beauty products are cosmetic products that do not contain a predefined set of ingredients as determined by retailers of cosmetic products. The exclusion of those predefined ingredients is the only difference between Clean Beauty cosmetic products and those that are not Clean Beauty compliant.
Are Clean Beauty Products More Safe Than Non-Clean Beauty Compliant Products?
No. All cosmetic products for human use, by FDA regulation, must be safe for consumer use and must undergo the requisite Safety Substantiation testing to prove safety. This includes passing Preservative Challenge Testing, Cosmetic Ingredient Toxicology Analysis and Skin Patch Testing (HRIPT).
The difference is that Clean Beauty products do not contain ingredients that some consumers have concerns about either for toxicology considerations, such as potential endocrine disruptors, and environmental/ecological concerns such as biodegradability and sustainability. Consumers may perceive products that do not contain these banned ingredients as “more safe” and/or more in line with their ethos.
Are Clean Beauty Products Less Safe Than Non-Clean Beauty Compliant Products?
No. All cosmetic products for human use, by FDA regulation, must be safe for consumer use and must undergo the requisite Safety Substantiation testing to prove safety.
The major complaint regarding the safety of Clean Beauty products generally revolves around preservatives used in cosmetic products. Most all Clean Beauty Standards prohibit the use of Parabens and Formaldehyde-donors as preservatives in Clean Beauty products. Some even prohibit the use of Phenoxyethanol. The argument is that this forces Brands to use preservatives that may not be as effective, not as well studied, and must be used in higher concentrations than the preservatives not allowed in Clean Beauty products.
This is a legitimate concern, particularly for Clean Beauty standards that do not allow Phenoxyethanol. However, remember that Clean Beauty products must pass Preservative Challenge Testing and Human Repeat Insult Patch Testing to prove they are safe for human use.
The More Safe / Less Safe Perception
Cosmetic product safety is a binary conclusion. The product is either safe for human use as determined by FDA regulated Safety Substantiation testing or it is not safe. All products that pass Safety Substantiation testing are safe for human use. So, More Safe or Less Safe are relative terms that cannot be measured objectively. Consumers may perceive that a product that does not contain Parabens, for instance, is more safe for them than a product that does contain Parabens. It’s really a consumer determination of what ingredients they desire to avoid putting on their skin.
Why Are Certain Ingredients Prohibited In Clean Beauty Products?
Ingredients not allowed in Clean Beauty products are generally due to concerns about toxicology, such as potential endocrine disruptors, irritancy and allergic potential and environmental/ecological concerns such as biodegradability and sustainability, or a combination of these factors.
Are Ingredients Not Allowed In Clean Beauty Allowed In Cosmetic Products?
Yes, all of the ingredients that are not allowed in Clean Beauty products can be used in cosmetic products. Some with use restrictions set by the FDA. Remember, the FDA does not approve ingredients for use in cosmetics. The FDA either sets use restrictions or bans ingredients from use in cosmetic products, but it does not approve ingredients.
This is another major point of contention regarding Clean Beauty. The creation of Black Lists of ingredients that are allowed to be used in cosmetic products, but are not allowed in Clean Beauty products if often portrayed as Fear Marketing to consumers. The argument is that the Black List ingredients are safe and the criteria for creating the Black Lists is not scientifically valid. There is some validity to this argument.
However, this argument fails to take into account consumer preferences and concerns, biodegradability and sustainability. And, it is assumed with scientific certainty that these ingredients are indeed safe for consumer use.
But, let’s look at recent regulations limiting the use of Retinol and Kojic Acid in cosmetic products. Retinol is perhaps the most studied of all cosmetic ingredients. Based on new toxicology studies, the EU has proposed restricting the percentage of Retinol allowed in cosmetic products. The same with Kojic Acid. It cannot be included in a cosmetic product in excess of 1% based on new toxicology data. As the toxicological sciences advance, we may well find that other commonly used cosmetic ingredients are not as safe or environmentally benign as once believed.
Clean Beauty For The Consumer
The demand for Clean Beauty products is a consumer-driven phenomenon. Consumers have every right to determine what cosmetic ingredients they apply to their skin and which ones they want to avoid. Clean Beauty is a response to that consumer demand.
How Do I Know If A Product Is Truly Clean Beauty?
Clean Beauty is not a category of cosmetic products defined by the FDA. It is a marketing term to signal to consumers that the product does not contain a pre-determined set of ingredients that they might find objectionable.
Any Brand can claim that their products are Clean Beauty. Consumers are advised to purchase products bearing a Clean Beauty Seal from one of the major retailers.
Are Clean Beauty Products More Effective?
Not necessarily. The effectiveness of a cosmetic product is determined by the combination of ingredients used in the product.
Are Clean Beauty Products Less Effective?
Not necessarily. Again, it all depends on the combination of ingredients used in the product.
Clean Beauty products can be every bit as effective as cosmetic products that are not Clean Beauty compliant. If you look at the Black List ingredients in most Clean Beauty standards, very few of those ingredients are actually cosmetic actives that have an effect on the appearance of the skin. Clean Beauty standards allow the use of both naturally-derived and synthetic ingredients including Growth Factors and Biomimetic Peptides. You really aren’t sacrificing anything in the way of effective cosmetic ingredients by adhering to Clean Beauty standards.
Is Clean Beauty A Scam?
Hardly, Clean Beauty products are regulated by the FDA, just like all other cosmetic products. Clean Beauty products must pass Safety Substantiation testing. Clean Beauty products must adhere to FDA labeling rules. Clean Beauty products clearly state what ingredients are in the product and that they don’t contain any of the Black List ingredients. Clean Beauty products can be just as effective as non-compliant products. So, what exactly is the scam? There isn’t one.
Most of the proponents declaring that Clean Beauty Is A Scam generate income talking about cosmetic products, not creating them. And, if your economic lifeblood is talking about cosmetics and your income is dependent on eyeballs and advertisement, what’s the most valuable thing to you to generate views and build an audience: Controversy. Hence the headlines screaming “Clean Beauty Is A Scam.” Oprah’s O Magazine featured an article about how confusing Clean Beauty was. They commissioned an author of children’s books to write the article. Enough said.
What’s The Real Controversy With Clean Beauty?
The real controversy with Clean Beauty is that is confers an “unfair competitive advantage” to Clean Beauty brands. Unfair Competitive Advantage is an economic term that means a Brand has a competitive advantage that cannot be matched by its competitors. Clean Beauty’s unfair competitive advantage relative to non-compliant cosmetic products is that Clean Beauty products compete against a smaller set of competitors. Clean Beauty products bear a Seal validating that they are compliant signaling to consumers that they do not contain ingredients consumers may find objectionable. Clean Beauty products are sold in curated sections of retailers stores and websites and are relatively easy for consumers to identify in a saturated cosmetics market.
Clean Beauty Is A Formulating Philosophy
In conclusion, I have been formulating Clean Beauty products well before there was even a term Clean Beauty or Clean Beauty standards. I have formulated over 600 cosmetic products, all Clean Beauty compliant. Some of the products I have developed have won awards such as the Oprah MenOpause Award and Best Of awards. I have never once used an ingredient on any of the Clean Beauty Black Lists. The Black List ingredients are simply not necessary to create great cosmetic products. My clients demand Clean Beauty compliant products as do their consumers. Clean Beauty has steadily captured a large share of the cosmetics market and it continues to grow.
But, Clean Beauty is no longer a differentiator in cosmetic products, it’s table stakes. Consumers are now demanding Clean de facto and have evolved beyond Clean to Cleanical and Conscious Beauty, looking for product performance, clinically-proven results, pushing the industry forward.
The demand for Clean awakened the industry’s consciousness. Over the past few years, developers of cosmetics ingredients have released a plethora of botanically-derived, ferments, and biotech ingredients as alternatives to the Black List ingredients. In retrospect, Clean Beauty has been a driver of innovation in the cosmetics industry.
