The challenges of LCA in the cosmetics industry and what is changing today

Historical challenges now overcome by technology

‍

Before the Meadows report, conducted in 1972 by MIT researchers highlighting the finite nature of resources, the first multi-criteria study approximating a life cycle assessment (LCA) was carried out by Coca-Cola researchers in 1969. Their objective? To choose between glass and plastic for packaging, to assess whether to internalise or outsource bottle production, and to analyse its end of life. LCA would begin to develop in the late 1980s. Forty years on, a bespoke LCA of a cosmetic product costs several thousand euros and requires months of work. Scaled across a product portfolio, deployment on this basis is structurally out of reach. But this is not the only obstacle. The specific characteristics of the cosmetics sector itself make the exercise arduous. Why and what is changing today with the genuine possibility of industrialising LCAs?

‍

LCA of a cosmetic product: a more complex lifecycle than it appears

‍

A complete life cycle assessment measures the environmental impact of a product, from raw material extraction to end of life. As a standardised method, it is clear. In practice, however, when applied to cosmetic products, it comes up against the very nature of the product: formulas that can contain several dozen ingredients with diverse geographical origins, different chemical natures, and obtained or transformed through varied processes. Packaging can layer different materials. Refills and new formats (concentrate products, solid forms…) introduce further variables. The use phase, for its part, varies with consumer behaviour. End of life depends on local waste management infrastructure. At every stage, the cosmetics industry presents specific characteristics that complicate modelling, even before the question of environmental data arises.

‍

To understand in detail where these difficulties lie, one must follow the cosmetic product at each stage of its lifecycle.

‍

• Raw material extraction and production: raw materials encompass both the formula and primary, secondary and tertiary packaging — synthetic molecules, natural raw materials, biotechnology, plastic, aluminium, glass, cardboard… Their sheer number and the diversity of their nature, origins, and supply chains make this a determining factor in LCA complexity.
• Finished product manufacturing: this stage is driven by the chemical manufacturing processes for the formula, energy consumption and its source, process water, and industrial waste.
• Distribution: this covers transport and storage logistics. It can be extremely impactful for products whose components are shipped by air.

‍

• Use: for rinse-off products, this stage includes hot water consumption and its associated energy sometimes alongside other consumables such as make-up removal cotton pads. It accounts for a significant share of the impact of rinse-off products.
• End of life: this covers the treatment of primary packaging and other consumables associated with the product (such as make-up removal cotton pads), depending on local infrastructure (recycling, incineration, landfill), as well as wastewater treatment for rinse-off products.

‍

In the cosmetics sector, impact is predominantly concentrated at two stages of the cycle: upstream with raw materials and downstream at the product use stage. It is precisely here that activity and environmental data is most difficult to obtain and approximations most influential on results. This complexity makes comprehensive modelling difficult.

‍

Across this five-stage lifecycle, LCA methodology rests on 4 successive phases defined by international standards.

‍

ISO 14040/14044/14067 standards: a robust method but difficult to apply in cosmetics

‍

Conducting an LCA is an iterative process resting on 4 successive phases. Each of these phases brings its own challenges specific to the cosmetics industry.

‍

• Phase 1: goal and scope definition. Every LCA must draw the system boundaries — in other words, decide what the scope includes and what it does not. The ISO standard requires these boundaries to be clearly defined, but does not prescribe where to draw them for a given product. In cosmetics, the questions are numerous. How does one define the functionality of a product in order to compare results across different cosmetic products? The choice of functional unit is not neutral, and it becomes even more challenging to define correctly with new formats: concentrate products, solid formulations, refills… The allocation question adds further complexity. When a single process simultaneously generates several co-products, how should the impact be distributed between them?
• Phase 2: the lifecycle inventory. This is certainly the most demanding phase. It involves identifying and quantifying all input flows (raw materials, energy, water) and output flows (emissions, aqueous discharges) at each stage of the lifecycle. This is the activity data-generating phase. It is therefore here that the central problem arises, since the key data — primarily drawn from raw materials and use — is extremely difficult to obtain.
• Phase 3: Impact assessment. The inventoried flows are translated into environmental impacts using characterisation factors applied to the impact categories under study. These are the coefficients that convert a physical flow (grams of methane, litres of water…) into a quantified impact (kg CO₂ eq., m³ eq. of water). These factors are not universal: they vary depending on the environmental databases and characterisation method selected, which represents a certain source of variability between two studies.
• Phase 4: interpretation. Results are analysed to identify the main sources of impact (hotspots) and interpreted taking into account the uncertainties associated with the calculation and with the quality of the activity and environmental data. Optionally, areas for action and possible trade-offs may be proposed. This is the phase that transforms an LCA into a decision-support tool, provided the preceding data is sufficiently reliable and granular.

‍

The critical review, for its part, is referenced in the ISO standards. It is mandatory whenever the LCA is intended for public communication in a comparative context. An independent panel verifies that the methodology complies with standards, that the data is consistent, and that the conclusions are justified. This critical review helps ensure that upstream data quality is sufficient.

‍

The ISO standards provide a reference framework but do not specify the default assumptions to be made in the absence of data. To harmonise LCA practice, the European Commission recommended in 2021 the use of a reference framework: the Product Environmental Footprint (PEF).

‍

The PEF and its indicators: why carbon alone is not enough

‍

Environmental impact measurement is often equated with measuring greenhouse gas emissions. Yet the environmental impact of a product or service extends far beyond this. This is all the more true for cosmetic products. Given the nature of the sector, a product can show a satisfactory carbon footprint and a very poor water footprint, for example. In the interest of standardising the impact categories retained, the PEF method has defined 16 impact categories to be studied.

‍

These 16 categories can be grouped into 5 major themes:

‍

• Climate: climate change (kg CO₂ eq.), energy consumption (MJ), use of fossil resources. These categories cut across the entire lifecycle, particularly wherever energy consumption is required.

‍

• Water: water consumption (m³ eq.), freshwater and marine aquatic eutrophication, aquatic ecotoxicity. These categories are particularly critical in cosmetics. Water is simultaneously the main ingredient in many products, a resource during the manufacturing and use phases, and is directly impacted at the end of life of rinse-off products.

‍

• Soil and biodiversity: land use, land transformation, terrestrial eutrophication. These categories highlight in particular the impact of natural ingredient supply chains, an increasingly prominent challenge in current cosmetics environmental approaches.

‍

• Air and human health: fine particles, carcinogenic and non-carcinogenic human toxicity, ozone layer, ionising radiation, photochemical ozone formation. These categories are amplified depending on the composition of the cosmetic product and the presence of aerosol.

‍

• Mineral and metallic resources: an important category for evaluating certain packaging types and make-up ingredients.

‍

These 16 categories illustrate the diversity of challenges to be considered. A major question then arises: where, in theory, does the data needed to feed the analysis comprehensively reside? To identify it, one must trace the value chain in its entirety.

‍

The cosmetics products value chain and the data puzzle

‍

The value chain of a beauty product involves more actors the higher the number of raw materials. The role of these actors is critical, since the bulk of impacts lies in companies’ indirect emissions (scope 3 as defined by the GHG Protocol) — unlike other industries where impact is more concentrated in emissions under the company’s direct control (scopes 1 and 2).

‍

The diversity of ingredient origins compounds the problem: a natural raw material can present different impacts depending on the country of production, agricultural practices, and extraction method. The same ingredient can also be obtained through very different processes. Glycerine is the perfect illustration. Listed under the same INCI name ((International Nomenclature of Cosmetic Ingredients) (Glycerin), it can be derived from the saponification of vegetable oil, synthesised from propylene (a petrochemical derivative), or produced by microbial fermentation. Three origins, three different environmental impact profiles. Aggregating these three realities into a single average figure dilutes the precision of an eco-design approach.

‍

Clearly, activity data is central. The calculation method, however robust, is inoperative without it. This essential information should theoretically be provided by suppliers. The reality is quite different. Access to this data is often an obstacle course.

‍

The root cause: a long and fragmented value chain. Between a brand and a producer based in Madagascar, there are sometimes several intermediaries. At each link, data exists but does not necessarily reach the brand. The reasons are multiple:

• Commercial confidentiality: a supplier that shares its production data also exposes its costs, processes, and margins.
• The absence of internal processes at each actor’s level: measuring one’s own footprint requires tools that many of them do not possess.
• The dilution of information. An ingredient can pass through several suppliers, several countries, and several continents before being used. Traceability then becomes a complex exercise.

Faced with this difficulty in obtaining activity data, LCA specialists formulate assumptions based on methodological or sector-specific reference documents.

To convert activity data into impact, LCA practitioners turn to reference environmental databases: Ecoinvent, ADEME’s Base Empreinte or Agribalyse, the EF database… In cosmetics, this approach is complicated to implement. The majority of COSING ingredients (approximately 30,000 cosmetic substances) have no existing inventories in these generalist databases, and therefore no environmental impact.

This double barrier - product complexity and difficulty of data access - partly explains why, despite its robustness, LCA has not yet transformed practices at scale in the cosmetics sector.

‍

The industrialisation of cosmetic LCA: now a reality

‍

The challenge is therefore not methodological, but operational, and raises a fundamental question: how to produce reliable result data on ingredients absent from reference databases, at scale and at limited cost?

‍

This is precisely the barrier that Fairglow has removed. The cosmetic LCA platform has reconstructed, through retrosynthesis, the missing environmental data for the 30,000 COSING ingredients — constituting the first proprietary database specialised in cosmetics at this scale, certified by Bureau Veritas against ISO 14040/14044/14067 standards. The platform covers the entire product lifecycle: formula, packaging, manufacturing, distribution, use and end of life, in a so-called cradle-to-grave approach. Fully compliant with the PEF framework, yet entirely configurable.

‍

The result: genuine management of environmental performance and real-time trade-off analysis. An R&D Director can compare the environmental impact of two formulations or two products before validating a development or responding to regulatory and consumer requirements. Finally, it represents a competitive advantage within the value chain. All major groups have already begun their journey. Tomorrow, they will demand the same transparency from their suppliers and contract manufacturers. 

‍

‍

LCA is not a new methodology. It is standardized and proven. If its deployment in cosmetics has remained limited, it is both because of its operational constraints — product complexity, fragmentation of the value chain, difficulty of data access — and because it did not fit into corporate decision-making logic. Lacking scalability across a product portfolio and given its cost, it has long been perceived as a one-off exercise. What is changing today is the capacity to remove these constraints.

The question is no longer whether measurement is possible or too approximate. It is now a matter of who equips themselves with the means to make it a management and decision-making tool rather than an isolated exercise or a compliance formality.

‍