Why measuring environmental impact is becoming unavoidable in cosmetics

Regulation, eco-design, consumers, competitiveness: the real issues

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The cosmetics industry accounts for between 0.5 and 1.5% of global greenhouse gas emissions (1). This is the only figure available, and it dates from 2020. Taken alone, it illustrates a broader reality, beyond carbon emissions: the environmental impact of cosmetic products remains poorly measured, and therefore difficult to grasp. Yet this situation stands in sharp contrast with the new challenges facing industry players. Regulation is tightening, consumers are making real trade-offs, and the risks tied to dependence on natural resources will increasingly weigh on value creation. 

This absence of measurement was once acceptable. In 2026, it no longer really is. It has become a gap in decision-making. The question is not so much about knowing a product’s impact, but understanding it and above all, managing it. 

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Measuring the environmental impact of a cosmetic product: what are we actually talking about?

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When it comes to environmental impact, confusion is common. 

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Measuring impact is not about determining whether a product is natural or clean. A natural raw material can, counter-intuitively, prove more impactful than a synthetic ingredient. Environmental impact cannot be assessed from the INCI list (International Nomenclature of Cosmetic Ingredients). Nor is it about calculating the carbon footprint of manufacturing plants, industrial operations account for only a fraction of total impact. And it is certainly not about declaring intentions or ticking a regulatory box. 

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Measuring the environmental footprint of a product means quantifying its multi-dimensional impacts on the environment across its entire lifecycle, from raw material extraction through to use and end of life. Life Cycle Assessment (LCA) is the reference method for quantifying these impacts. To this end, the European Commission has defined a reference framework: the Product Environmental Footprint (PEF), which covers 16 impact categories encompassing a product’s effects on climate change, air, soil, water, and human health.  

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Ultimately, a product can have a low carbon footprint while simultaneously having a high impact on biodiversity. A product with a high naturalness index may, in turn, display a considerable water footprint. This is precisely the kind of comprehensive, appropriately granular view that LCA makes possible.

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Measuring the environmental impact of a beauty product means moving from perception to objective, science-based information.  

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Why the cosmetics industry is particularly exposed 

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The very nature of cosmetic products makes measuring their environmental impact essential. In France, companies are classified by their NAF code, which identifies their primary activity. This code is not a choice, it is an official classification. Cosmetics and fragrance manufacturers fall under code 2042Z, which sits directly within the chemical industry category. 

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In cosmetics, virtually the entire product is the result of chemical processes. The formula, even if 100% natural, consists of a series of chemical reactions. All ingredients involved regardless of their origin (synthetic, natural, or biotech) undergo various transformations: extraction, distillation, emulsification, and more. At the same time, with 120 billion units produced each year, packaging is also predominantly chemistry-derived (2). In France, plastic remains the most widely used material, accounting for 51% of packaging weight (3). 

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But chemical transformation and its impact are not the only environmental challenges facing the cosmetics sector. Its extensive reliance on nature makes it a particularly exposed industry. 

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Water, first of all. It is indispensable to the industry throughout the product lifecycle. It is the key ingredient in many products: in emulsified formulas - creams, lotions, gels, shampoos - which represent the majority of the market, water heads the INCI list and can account for up to 80% of the composition. Beyond its role in formulas, water is also required for growing the increasingly prevalent natural ingredients in products, and for industrial manufacturing processes. Finally, it sits at the heart of use and end-of-life for a large number of products: rinse-off products lead to varying levels of water consumption by users and affect wastewater quality. 

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With the rise of naturalness, an increasingly significant share of ingredients now comes from natural resources. Their availability, quality, and sustainability depend on the state of ecosystems. They often come from long supply chains, with farming practices and impacts on biodiversity and soil varying considerably. 

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In light of these dependencies, the case for measurement becomes clear. 

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Cosmetics regulation: what PPWR and EMPCO will change  

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For those not yet using LCA, upcoming European regulations will change the game. Cosmetics are already among the most regulated products in Europe under the EU Cosmetics Regulation, which governs both ingredient assessment and good manufacturing practices. New legislation will also regulate different stages of the product lifecycle: packaging, end-of-life, and consumer communication. 

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Among them, in the near term, the Packaging and Packaging Waste Regulation (PPWR) will apply across all EU member states from 12 August 2026, establishing a framework for eco-designed packaging in Europe. It sets a packaging recyclability target for 2030, while introducing requirements on reduction and reuse. In September 2026, the EMPCO Directive will regulate marketing claims, which will henceforth need to be substantiated by evidence. On the formula and end-of-life side, the Urban Wastewater Treatment Directive (UWWTD), which entered into legal force on 1^st January 2025, represents a significant development. It is expected to require pharmaceutical and cosmetics manufacturers to fund 80% of the cost of removing micropollutants from wastewater. Its transposition into national law is underway. 

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In France, the public environmental labelling scheme already piloted in the textile sector is being developed for cosmetics, based on LCA. The decrees making this labelling mandatory have not yet been published. At European level, the Ecodesign for Sustainable Products Regulation (ESPR) will introduce the Digital Product Passport (DPP). While the timeline for cosmetics has not yet been finalised, it will require brands to provide reliable, traceable, and up-to-date environmental data for each product.  

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While the requirements under these various texts are often perceived as constraints, they anticipate the industrial rules of tomorrow : a world where environmental and economic performance will be linked, measured, disclosed, and embedded in purchasing, sourcing, and reporting decisions. 

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Regulation is progressively transforming environmental performance into an economic variable.

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Sustainable cosmetics: what consumers really want  

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In this changing world, what do consumers really want? Surveys regularly show that they claim to pay attention to environmental aspects. But for a long time there has been a documented gap between stated intentions and actual purchasing behaviour. 

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A study published in April 2025 by Amazon and researchers from the University of Southern California offers a new perspective. It analyses sales data for nearly 100,000 products in the United States and Europe to determine the impact of the Climate Pledge Friendly programme  designed to help customers identify the most sustainable products. To qualify, products must be certified by trusted third parties selected by Amazon, and are then identified by a small leaf badge. 

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The study compares a product’s sales performance before and after joining the CPF programme. The results are unequivocal. Badge-labelled products show undeniable growth. In the United States:  +12.5% in sales value, and +4.4% in units shipped. In Europe — UK, Germany, France, Italy, Spain — results are even stronger: + 15.5% in sales value. 

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The study highlights two further important findings. Consumable products, including cosmetics, outperform: + 24.7% in sales value — nearly double the average across all categories combined. The effect is even stronger for lower-profile products. For a mid-sized or small cosmetics brand that lacks the visibility of a major group, making environmental performance visible and credible is a particularly powerful driver of discovery and growth.

The conclusion is unambiguous. A product’s sustainable performance, certified through a reference methodology, translates into revenue growth. 

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Consumers now expect proof. This is certainly one of the explanations for the success of Amazon’s programme. More broadly, measurement enables what generic claims cannot: precise messages backed by evidence. Verified data, grounded in a recognised methodology. 

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Without this measurement, a brand is today exposed to reputational risk. Tomorrow, to legal liability.

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Measuring to manage: a business imperative for the cosmetics industry 

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In the face of new risks for the cosmetics sector, CSR challenges are evolving, moving out of the sphere of responsibility and into economic reality. Measuring the environmental impact of cosmetic products to manage them is measuring the ROI of your actions. Measurement tools are becoming genuine management instruments, enabling the CSR or R&D Director to position themselves as a true business partner. 

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In this context of growing regulatory and consumer pressure, measurement enables eco-design to be steered with real data, for both formulas and packaging. On the formula side, knowing the actual impact of an ingredient changes the nature of trade-off decisions. Some substitutions simultaneously reduce impact and costs. Measurement can also reveal that an ingredient perceived as virtuous is actually highly impactful on another parameter. It enables the documentation of a continuous improvement trajectory. 

On the regulatory side, the UWWTD on micropollutant removal could eventually introduce an eco-modulation and extended producer responsibility (EPR) system based on the polluter-pays principle. The same applies to packaging: the PPWR regulation will be based on eco-modulation. The least recyclable packaging will be subject to higher financial contributions. The environmental performance of packaging is becoming a direct economic variable. Here again, measuring and transforming upstream is less costly than last-minute compliance. 

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Beyond eco-design, measurement also enables real-time evaluation of innovations. It provides an objective basis for assessing actual gains and contributions. 

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Measurement also contributes to better supply risk management. The double materiality matrix produced by FEBEA on behalf of its members confirms this: resources are identified as the most significant issue for the industry. Nature-dependence is no longer a mere environmental parameter — it is becoming a business risk. The impact of certain ingredients on climate change or their pressure on biodiversity makes them more exposed than others in an increasingly uncertain geopolitical context. 

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Finally, measurement is taking on a new role in the value chain. Today, all major groups have begun at least a partial approach to measuring the environmental impact of their products. Tomorrow, they will demand the same from their suppliers and will require precise data. For a contract manufacturer or ingredient supplier, adopting this approach already signals a competitive advantage — before it becomes a market requirement. 

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The environmental impact of cosmetic products remains imperfectly measured today. Not only because of technical constraints now resolved by advanced tools, but above all because the importance of this measurement has not always been fully appreciated. That situation is changing. Nature-related risks are growing, regulation is tightening, consumers are making real choices, financial stakes are emerging, and value chain expectations are shifting. Behind measurement lies, above all, access to information that enables anticipation, management, and decisive action — while being able to demonstrate ROI. Measurement is no longer a reporting exercise but a decision-making exercise. The question is no longer why to measure, but how to take action. 

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1. Etude Quantis - Make-up the future 2020
2. FEBEA
3. FEBEA

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