US elections are over, but debates continue. The International Federations of Societies of Cosmetic Chemists (IFSCC) produced its first webinar of 2021, but unlike typical online meetings, the IFSCC resolved to hold the event in a debate-like format.
 
The goal of “A Clean Beauty Debate” was to answer the question: does clean beauty make products more safe? Arguing in the affirmative was Dr. Nicole Acevedo, founder and CEO, Elavo Mundi Solutions, LLC. The opposing view was taken by Dr. Mojgan Moddaresi, managing director, Personal Care Regulatory Ltd. The debate, moderated by IFSCC Education Chair Perry Romanowski, attracted more than 1000 registrants.

Before the debate got underway, attendees took an online poll to see where they stood on the clean beauty issue by asking the question: Does clean beauty make cosmetics products more safe? A winner would be declared if the polling changed after the event. 
 
But prior to the debate, IFSCC Secretariat Marylynn Halland reviewed the benefits of IFSCC membership and noted that the number of national societies reached 50 with the recent addition of Nigeria. The Clean Beauty Debate was the 17th IFSCC webinar since the pandemic took hold in early 2020.
 
“Clean beauty is a growing trend in the cosmetics industry and an evolution of the natural beauty trend that started roughly in the 1990s,” observed Romanowski. “Clean beauty is now a common claim seen on numerous brands like Drunk Elephant or Juice Beauty, and even product distributors like Sephora or Credo Beauty have created their own clean beauty standards.”
 
Despite clean beauty’s popularity, Romanowski said he finds the trend frustrating because at its core, clean beauty makes inherent claims about product safety.
 
“But usually when you hear these talks, the experts are really product marketers who have no background in toxicology or ingredient safety,” said Romanowski. “They also tend to be cheerleaders for the topic, focusing on the benefits of clean beauty and not taking a skeptical look at it.”
 
Romanowski noted that beauty products are required to be safe, and then asked, “So if products are legally required to be safe, are clean beauty standards really providing any benefits to consumers?”  
 
Absolutely, insisted Acevedo, who noted that, in the past, consumer loyalty was centered around product performance and cost. Today, consumers are concerned about their health and the health of the planet. What is driving this push? According to Acevedo, it is a lack oversight. She said there are more than 12,500 chemicals approved for use in the global cosmetics industry, but the vast majority have not been assessed for safety by a publicly accountable agency or regulatory body. Furthermore, more than 1,300 ingredients are currently banned or restricted for use in cosmetics in the European Union. In Canada, there are more than 500 ingredients banned or restricted for use in cosmetics. In contrast, only 11 ingredients are currently banned for use in cosmetics in the US.
 
“I am by no means implying that the word 'chemical' is synonymous with harmful,” insisted Acevedo, but she noted that the EU regulations are more stringent than US standards. For example, in the EU all cosmetic ingredient data must include animal testing, toxicological profile, chemical structure and level of exposure. 
 

“There are very clear parameters in the EU and regulatory frameworks for both the management assessment and regulation of chemicals in our industry,” she said.
 
In contrast, Acevedo said the only US law that governs the more than $60 billion national cosmetics industry was passed in 1938 and no major reforms have been enacted since then. Furthermore, she said the law (Food, Drug & Cosmetic Act) does not provide the US Food and Drug Administration with the power to ask cosmetics companies for safety data, request safety tests or issue recalls of cosmetics found to be unsafe. While several cosmetics safety bills have been introduced in Congress in recent years, none have become the law of the land. Why is cosmetic safety important? Exposure, according to Acevedo.
 
“On average, US women use 12 personal care products a day, men use about six and teenage girls use 17 products a day,” she told attendees. “So this means we can be exposed to hundreds of chemicals over the course of our daily routine.”
 
According to Acevedo, numerous studies have been conducted on commonly used cosmetic chemicals and the studies have exposed the body burden of these chemicals on adults, children and newborns. These studies have showed the deleterious effects these chemicals can have, even at very small amounts, during critical windows of development.
 
Clean beauty was born in the 1990s, when US consumers began to seek “natural” and “organic” products in the food industry and began to address some ingredient concerns in personal care products. By 2004, the Campaign for Safe Cosmetics was formed. This umbrella coalition of NGOs was focused on perceived risks of chemicals used in cosmetics. A few years later, startups began banning some chemicals in their formulas and focusing on the “naturalness” of their products, explained Acevedo.
 
By 2013, Beautycounter emerged as one of the first brands to implement the principles of green chemistry to assess the safety of their products on human health and the environment. In 2015, Credo Beauty entered the market as a “clean beauty” retailer, which popularized the term. Today, many brands and retailers market themselves as “clean.”
 
“The challenge at this time is to ensure that the standards for clean beauty become more universally defined within our industry, so that consumers are clear as to the benefits of investing in it,” concluded Acevedo. “In its highest expression, clean beauty is an ideology that prioritizes human health safety, ethical sourcing, sustainable practices and transparency of process.”
 
She admitted that clean beauty is currently defined in a variety of ways by different brands—some focus on creating products that are “free of” potentially harmful and/or synthetic ingredients, while others focus more on ethical and/or sustainable sourcing ingredients.
 
She called for the evolution of “clean beauty” to:
 
• Take into account the most vulnerable populations when formulating ingredient strategies; 
• Optimize chemical management strategies for product safety, performance and sustainability; 
• Design products that present low human health hazards and are optimized for low environment impact throughout their lifecycle;
• Understand that transparency is critical to ensure customer trust and loyalty; and
• Work toward harmonization of “clean” standards throughout the value chain.
 
“There is a clear business case for clean beauty,” she concluded, noting that global sales of natural and organic beauty products are expected to double from $11 billion in 2016 to $21.8 billion in 2024.
 
Counterpoint
 
Moddaresi opened her presentation by noting that many brands use fear tactics to sell their products, comparing clean vs. dirty or safe vs. unsafe.
 
“Fear is the strongest emotion in human beings. As chemists, we all know that even air has heavy metals, what makes it toxic is the dose,” she explained. “I believe the ambiguity of ‘clean beauty’ is intentional.”
 
In contrast, Moddaresi reviewed the rigorous steps of scientific research: Observation leads to hypothesis and the hypothesis is tested based on scientific methods. A proven tested hypothesis becomes a theory and, with scientific evidence, it becomes a proven theory. 
 
“The theory can always be improved based on the scientific evidence,” she added.
 
In contrast, Moddaresi said the clean claim is a marketing technique rather than an actual scientific fact or even a proven theory. 
 
Taking a closer look at ingredients, she noted that skin is not a sieve and that the dose is very important to turning a hazard into a risk; Moddaresi pointed out that six liters of water can be lethal—not to mention as few as 13 shots of alcohol. In reviewing CMR ingredients (carcinogenic, mutagenic or toxic to reproduction), Moddaresi noted that humans encounter many CMR substances in low doses as part of normal daily life with no adverse effects.
 
“Clean beauty just picks one hypothesis, without looking at the evidence of the whole; parabens are a very good example of that,” she said. “We all know there are gaps in the science, but we must not fill these gaps with fear—that’s science fiction.”
 
Moddaresi insisted that science works; although it is not perfect and it can be misused.
 
“It is only a tool, but it is by far the best tool we have; self-correcting, ongoing and applicable to everything,” she added.
 
Finally, Moddaresi said science has two rules:
 
• First, there are no sacred truths; all assumptions must be critically examined.
• Second, whatever is inconsistent with the facts must be discarded or revised.
 
Romanowski asked Acevedo why groups such as the Cosmetic Ingredient Review (CIR) and the Scientific Committee on Consumer Safety (SCCS) aren’t enough to ensure product safety. Acevedo noted that CIR is an industry-backed organization with no outside oversight. In contrast, she called the SCCS a robust regulatory process.
 
“You have to think about what market we are talking about when you talk about ‘clean,’” reminded Acevedo. “I am talking about clean as it relates to the US market, because we have such a lack of Federal regulatory processes here to oversee our industry.”
 
Moddaresi noted that responsibility for safety falls on the brand owner—if a consumer has an issue with a product, lawsuits are sure to follow. She also noted that both the CIR and the SCCS are made up of scientists and toxicologists who have years of experience, and both take the same approach to ensuring safety.
 
“There is no difference in how they approach ingredient safety,” Moddaresi asserted.
 
Acevedo countered that the Toxic Substances Control Act (TSCA) in the US has only reviewed about 200 chemicals. In contrast, Europe’s REACH regulations requires manufacturers to upload their data and make it available to their platform.
 
“In the US, the onus is on the brands and consumers to make sure the product or ingredient is safe,” said Acevedo. “Those of us in the safer ingredient space rely on safety data from Europe.”
 
Despite Acevedo’s presentation, attendees weren’t convinced about the benefits of clean beauty. Prior to the debate, attendees were asked, “does clean beauty make products more safe?” Forty-nine percent said no, 27% said yes and 23% were unsure. After the debate, 62% said no, 22% said yes and 14% were unsure.
 
Attendees weren’t convinced about the benefits of clean beauty and neither was Romanowski.
 
“As far as clean beauty goes, I’m still not convinced that it is any more than a marketing gimmick,” he told Happi. “The thing that I find most telling is that despite the differences in regulatory climate, cosmetics in the US and EU are not significantly different.”
 
Following the debate, Romanowski said he was pleased with how the event went and was looking forward to the IFSCC tackling other “controversial” topics but from the perspective of industry scientists. Other topics under consideration include “cruelty free,” cosmetic regulation, blue light effects and environmental impact.

“I like the format as it keeps people engaged even while just tuning in online,” said Romanowski, who noted it enables IFSCC to provide programming for its members around the world.
 
“While in-person events are still highly desirable, the online meetings are much more accessible,” he said. “The online chats during the talks are great, too.”
 
The IFSCC’s next webinar will be held January 27. Dr. Mindy Goldstein will discuss “Understanding the INCI Nomenclature on Recombinant Proteins.” To register, visit www.ifscc.org.