Cosmetic Formulations: Beyond Clean Beauty, the Environmental Challenge

Measuring the environmental impact of cosmetic formulas: the new challenge of eco-design

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Nearly ten years ago, the first cosmetic ingredient-decoding apps for consumers began appearing across Europe. The clean beauty era was dawning, with formula composition becoming the second most important purchasing criterion, right after price (1). Formulation guidelines were then overhauled from the ground up to meet new consumer expectations, particularly around ingredients controversial for health reasons. Today, environmental impact is becoming a key issue, scientific, regulatory, consumer-driven, and commercial all at once. A second cycle is opening. And the tools are changing. Formulation guidelines define what is excluded. It does not measure the overall environmental impact of what remains. Moving from an exclusion logic to a measurement approach: that is the challenge the industry is beginning to address.

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Reducing the impact of formulas: an evolution in several phases

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To understand what the era now unfolding requires, it is worth revisiting what formulation guidelines have built. 

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They first emerged in the 1990s. The European cosmetic regulation did not yet exist, and the most forward-thinking brands began drawing up specifications that included internal exclusion and restriction lists. The goal: to anticipate future ingredient restrictions and avoid costly emergency reformulations. Compliance with the European cosmetic regulation — which ultimately came into force in 2013 — and the anticipation of its decisions remain, even today, a significant driver of charter guidelines.

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In 2004, the mood shifted. The publication of a British study detecting traces of parabens in human breast tumours triggered an unprecedented crisis of confidence. For the first time, an ingredient began disappearing from formulation guidelines under consumer pressure. From 2017 onwards, cosmetic ingredient-decoding apps amplified the phenomenon. They exposed the INCI list to millions of people, flagging ingredients considered controversial primarily on health grounds. The pressure on brands became unprecedented. Most players revised their guidelines to respond to customers rejecting certain substances. Consumers were no longer asking for limits; they were demanding outright exclusions.

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Nearly ten years on, guidelines have been revised, yet environmentally impactful ingredients remain largely overlooked in these specifications. Some are nonetheless under increasing scrutiny: PEGs are frequently banned, along with the most controversial surfactants and substances of very high concern under European regulation — primarily vPvBs (very persistent, very bioaccumulative) and PBTs (persistent, bioaccumulative and toxic). Exceptions exist. Palm oil, for which RSPO-certified sourcing has become a standard requirement, illustrates how certain ingredients with significant environmental and social concerns have entered formulation guidelines under pressure from media coverage and NGOs. But these remain isolated cases, focused on a small number of highly publicised ingredients.

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Some players, particularly large groups, are pursuing more advanced work. Biodegradability is an area the industry is actively addressing, while aquatic ecotoxicity has become a specific focus, particularly for sun care products. These companies are also tackling water-related issues by reformulating products to reduce water content, improve rinseability, or develop formats that require less water during use.But these approaches operate through isolated criteria; they do not measure the overall environmental impact of a formula. And yet, the formula itself accounts for a significant share of a cosmetic product’s environmental footprint. This is precisely where the new levers of eco-design lie.

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Regulation often determines the actions taken. To understand why, it is worth examining what the regulatory framework targets — and what it is not designed to cover.

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What the European regulation targets  and what it does measure

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Europe has a regulatory framework unique in the world for assessing the safety of cosmetic ingredients. It is built on three complementary regulations whose interactions form a coherent system.

• CLP, the Regulation on the Classification, Labelling and Packaging of chemical substances, forms the foundation. It defines the intrinsic hazards of each substance: carcinogenicity, reproductive toxicity, aquatic toxicity, and certain properties related to persistence and bioaccumulation. CLP assigns the hazard statements — the H classifications — that serve as the reference point for the other two regulations.
• REACH builds on these classifications to regulate the placing of chemical substances on the market. It can restrict or prohibit their use depending, among other factors, on intended applications and volumes. Its mechanism is cross-sectoral and applies across all industries, including cosmetics.
• The European Cosmetics Regulation (EC) No 1223/2009 provides the sector-specific framework. It incorporates REACH and CLP decisions into its annexes — banned substances, restricted substances, and others — and relies on the Scientific Committee on Consumer Safety (SCCS) to assess ingredient safety under real conditions of use: product type, concentration, and frequency of application.

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This triptych does not operate according to a simple top-down logic. It is grounded in risk assessment, not merely hazard assessment. Hazard is the intrinsic property of a substance. Risk is that hazard measured against actual exposure: the dose, the conditions of use, the frequency of application.

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The system performs well in relation to the objectives it has been assigned. It guarantees the safety of cosmetic ingredients to a standard unmatched anywhere in the world. It incorporates environmental dimensions - aquatic toxicity, persistence, bioaccumulation - through CLP classifications and REACH’s PBT criteria.

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But it has one limitation: it does not allow for an assessment of the overall environmental footprint of an ingredient. Two ingredients approved without restriction can have radically different impacts on water consumption, land use, or climate change. The regulatory framework answers the question: is this ingredient safe? It does not answer the question: is this ingredient preferable from a broader environmental standpoint? That is not its purpose — and that is precisely where impact measurement takes over.

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Forthcoming regulatory developments confirm the need to begin genuinely measuring the environmental impact of products in their entirety, formulas included. Packaging has been under sustained scrutiny for many years. Driven by the AGEC law in France and the forthcoming European PPWR regulation, major players have set precise circularity targets: light weighting, material selection, recyclability, refill development. Consortia have been formed to drive greater circularity. La Belle Boucle, which promotes return schemes for cosmetic packaging, and Pharma Recharge, which develops bulk dispensing in pharmacies, are operational examples of this.

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Packaging has led the way. Formulas are the next perimeter that regulation will constrain. The rollout of environmental labelling for cosmetics in France will be based on life cycle assessment. The EMPCO directive, for its part, will require documentation of any environmental claim. The Digital Product Passport, under the ESPR regulation on the eco-design of sustainable consumer products in Europe, will require ingredient-level environmental traceability, product by product.

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The 5 key challenges of LCA for a formula

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Life cycle assessment lies at the heart of the challenges ahead. Conducting an LCA of a cosmetic product means confronting a series of methodological issues that make the exercise relatively complex and difficult to arbitrate.

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The first is the number of ingredients. A skincare cream contains an average of 30 to 50. A fragrance can mobilise several hundred. Each has its own environmental impact profile, its origin, its variabilities. The life cycle inventory must cover all of these flows for each ingredient. This represents a considerable workload, which increases with the complexity of the formula.

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The second challenge is intra-ingredient variability. The same INCI name can cover very different environmental realities depending on the supplier, the geographic origin, and the manufacturing process. Two glycerins listed under the same INCI name — one derived from the saponification of vegetable oils, the other synthesised from propylene — do not share the same impact profile on climate change, water consumption, or land use. Yet they appear under the same designation in the INCI list.

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The third challenge concerns rinse-off products. The impact during the use phase depends directly on consumer behaviour: rinsing duration, water temperature, frequency of use, energy mix… These parameters vary by country, culture, and season. They are decisive in calculating the footprint of a shampoo or a shower gel.

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The fourth challenge is posed by new formats. Products designed to be reconstituted — concentrates, solids, dilutable formats — redistribute impacts across the life cycle. Water, which often accounts for the bulk of the weight in a traditional formula, is no longer integrated into the product but added at the point of use. This is a genuine eco-design approach that lightens transport, reduces packaging, and eliminates a significant share of the logistical footprint. But it raises a fundamental methodological question: how to compare products with equivalent functionality. Ensuring that ingredients serve a similar function is not an obstacle to these formats, but it is one of the challenges that a formula LCA must know how to address.

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The fifth challenge is data — and it is the most critical. In a rigorous LCA, the ideal data are those held by suppliers about their own processes: water consumption, energy used, emissions generated, precise origin of raw materials. If this data were available, the exercise would be straightforward. In reality, it is very difficult to obtain: the cosmetic value chain is long and fragmented. Suppliers do not share their production data ; whether for reasons of commercial confidentiality, absence of internal measurement processes, or simply because no one has yet asked them in a structured way.

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Faced with this difficulty in obtaining activity data, LCA specialists make assumptions based on methodological or sector reference documents. To convert activity data into environmental impacts, they rely on reference databases: Ecoinvent, the ADEME Base Empreinte or Agribalyse, the EF database, among others. In the cosmetics sector, this exercise runs up against a major obstacle: virtually all of the substances listed in COSING — nearly 30,000 ingredients — are absent from these general databases and therefore lack any modelled environmental impact data. The practitioner then resorts to proxies. These approximations are insufficient for guiding eco-design decisions at the formula level or for defending environmental claims under EMPCO.

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This double lock — inaccessible supplier data and gaps in environmental databases — has long made formula LCA impractical at portfolio scale. This is precisely the barrier that Fairglow has broken down, by reconstructing through retrosynthesis the environmental profile of substances listed in COSING. What was previously impossible is now achievable: a reliable and granular LCA across an entire formula and at the scale of a full product portfolio.

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Guideline or LCA: two tools, a common approach for the cosmetics industry

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‍Formulation guidelines remain indispensable. They establish a framework, exclude the most concerning substances, and ensure overall consistency. They operate according to a logic of safety and compliance. But their approach remains binary: an ingredient is either approved, banned, or restricted. They do not allow for the real-time assessment of a formula’s overall environmental impact, nor do they enable meaningful comparisons between alternative formulations.

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‍Measurement introduces a different logic. It does not replace formulation guidelines; it complements them. It makes it possible to assess a formula across its entire life cycle, compare multiple options, and make decisions based on objective data across all 16 impact categories of the Product Environmental Footprint (PEF).

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For R&D teams, this fundamentally changes the nature of decision-making. When reformulation is required for regulatory, technical, or strategic reasons, measurement makes it possible to assess the environmental impact of different options and identify the one that best balances product performance and environmental performance. For sustainability teams, it provides a way to document decisions, demonstrate continuous improvement trajectories, and respond to growing expectations around evidence and transparency.

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This complementarity works in both directions. If measurement reveals that an ingredient has a particularly unfavourable environmental profile — in terms of water, soil, or climate impacts — nothing prevents its integration into formulation guidelines as a criterion for exclusion or restriction. LCA therefore becomes a tool for enriching the guidelines themselves. The two approaches do not oppose one another; they reinforce each other.

The guidelines define the framework. Measurement makes it possible to navigate within it — and ultimately evolve it.

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(1) Statista study – 2019

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