COSMOS Approval & Beauty Ingredients

Dear Valerie: COSMOS promotes sustainability and green chemistry, so why might a conventionally synthesized ingredient like glycolic acid be COSMOS approved while the same molecule produced through precision fermentation is not?

—MOLECULE MIFFED

Dear Molecule, 

While I am not an expert in the specific qualification pathways for COSMOS-approved ingredients, I am frequently perplexed by the regulatory decisions made by third-party standards organizations. They routinely create arbitrary, inflexible standards that fail to adapt to modern technological advances, even when those advances are demonstrably safer for the consumer and better for the environment.

I once found myself in a compliance dispute with a prominent certifying organization that prohibited formaldehyde donors, including glyoxal, in applicant products. The disagreement was not over the whether glyoxal was dangerous, but rather over a glaring loophole in the organization’s decision-making framework.

Many quick-dispersing, cold process grades of hydroxyethylcellulose are manufactured using glyoxal as a processing aid. Because processing aids are generally not required to appear on cosmetic ingredient declarations in the US or Canada, the organization grants seals of approval to products using these glyoxal-containing grades. However, if a brand discloses glyoxal on the label to satisfy stricter EU labeling mandates, they were summarily barred from anointing their products with the seal. Same material, different standards! When pointed out, the organization was unable to grasp this inherent flaw in their system. I gave up, leaving inadvertent omission to continue to be rewarded.

This same structural blind spot is well illustrated by the COSMOS-standard’s treatment of glycolic acid. Traditionally, glycolic acid is manufactured via the carbonylation of formaldehyde with carbon monoxide, or by the hydrolysis of glycolonitrile (derived from formaldehyde and hydrogen cyanide). Both pathways are rooted in natural gas chemistry, and both processes may leave undesirable impurities in the final product. Some glycolic acids are purported to be bio-based but still use synthetic chemistry to get to the end product. While glycolic acid has been isolated from plants, plants don’t exactly yield meaningful quantities.

How do molecules from synthetic routes get approved in an organic and natural standard? COSMOS-standards do recognize certain synthetic chemistries, like hydrolysis, that allow certain versions of glycolic acid to be approved.

Conversely, glycolic acid can be produced via precision fermentation. This method yields a chemically identical molecule, save for the complete absence of impurities found in conventional glycolic acid. However, because the process utilizes genetically modified micro-organisms for fermentation, the resulting high-purity ingredient is automatically disqualified from COSMOS approval.

This is a striking contradiction, given the COSMOS Standard was explicitly developed to create a harmonized framework to drive sustainable development across the entire beauty industry. While not all synthetic chemistry is inherently bad, sometimes biotech-based can be better for the environment, or consumers.

Unfortunately, I’m not sure what assistance I can offer to overcome the blind spots certifying organizations have in an ever-evolving industry. It’s a big battle! Gather your evidence, rally the troops, and keep fighting the good fight.

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Valerie George

[email protected]

Valerie George is a cosmetic chemist, science communicator, educator, leader, and avid proponent of transparency in the beauty industry. She works on the latest research in hair color and hair care at her company, Simply Formulas, and is the co-host of The Beauty Brains podcast. You can find her on Instagram at @cosmetic_chemist or showcasing her favorite ingredients to small brands and home formulators at simply-ingredients.com