Contributed by Jorgen Gade Hyldgaard ApS, Mejsevaenget 7, DK-5610 Assens, Denmark
It has become increasingly apparent there is a clear, long-term demand for sustainability with respect to consumer products. The objective of this paper is to provide different approaches to sustainability via the two lifecycle based label principles: Eco-label and Natural/Organic labels and via (ii) CSR principles and to provide a better understanding of what is (iii) the contrary to sustainability and how to find and interpret relevant information on these aspects. In order to provide a better understanding of sustainability and relevant aspects, it is of the utmost importance to employ all available tools and work in unison the consumers.
Definition: Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.
As cosmetic chemists, and in reference to the above definition, one faces (at least) two problems in this regard:
1. 90 % of cosmetic products are based on raw materials that are, at least, partly prepared from finite (petrochemical-based) resources such as mineral oil or gas. Despite petroleum companies’ best, optimistic estimations for continued oil supply, it is evident that supply is less than the demand. Consequently, it could be conceived that the net result is a reduction in the available of such resources for the next two generations. The use of cracked petroleum products as raw materials for synthesis of ingredients not only affects cosmetics but medicine and other important products for mankind(2).
2. The use of such finite resources produces two clearly undesirably by-products: waste and pollution. One such example of a by-product is carbon dioxide (CO2). According to research (3), accumulation of CO2 in the Earth’s atmosphere is only one factor of numerous variables which have been attributed to why four of the nine planetary boundaries already have been crossed. Boundaries are threshold levels and are defined as points of no return; for the world and humanity.
In future it seems apparent that further issues will arise associated with these areas, which will likely involve, and be influence by, consumers. Consumer awareness and education, together with like minded groups, will increasingly result in further proactive developments to tackle on these issues.
WHAT ARE THE IMPLICATIONS FOR THE COSMETIC INDUSTRY?
The cosmetic industry must provide consumers with the possibility to make an informed choice with reference to the sustainability of cosmetic products.Truly informed choice can only be made via product claims and branding, which can often result in misleading the average consumer. Therefore, the responsible use by (cosmetic) corporations to include relevant marketing, in addition to effective environmental and social responsibility, should be used in order to better assist consumer’s choice in terms of sustainable products.
All players within the (cosmetic) industry will have to consider and react to this situation. As such processes are already in motion to examine alternatives methods for sustainability, and this is where labels can help consumers to choose more sustainable products.
In light of the above, this document will discuss some of the relevant labels that might be relevant to use in this context. Additionally, we will look at some of the standard ingredients used and their status in the REACH process. This document is divided into four sections. The first two sections, which outline two different approaches towards sustainability, will focus on:the Eco labels and (ii) the natural/organic labels. The third section will cover issues related to the life cycle of products: Production processes, use of other resources and waste. The fourth main part will investigate some consequences of not using sustainable ingredients and connect to the REACH and CLP systems.
I. THE ECO LABELS ARE FOCUSING ON THE LIFE CYCLE OF THE PRODUCTS
In general the Eco labels focus upon life cycle assessments (Figure 1) (e.g. biodegradability) and measurements of the output of the process: What happens to the cosmetic product in the outlet? In terms of the final cosmetic, the intrinsic physical and chemical characteristics each ingredient must be evaluated. Factors that in need of evaluation, such as an ingredient’s inherent biodegradability and toxicity (aquatic toxicity), can be assessed by the Organization for Economic Co-operation and Development (OECD) often provides guidelines for such required parameters. Further examples of necessary evaluation include those requires those ingredients marked as possible fragrance allergens, which under EU cosmetics legislation need to be indicated on packaging when concentrations exceed a given level, and impurities resulting from polymers, tensides and emulsifiers which should be kept at very low levels. As a result this presents a big challenge for producers of cosmetics containing perfumes, natural extracts and emulsifiers. A clear method in order to reduce product waste, and in turn promote sustainable action, would be to focus on a reduction of the packaging material compared with the amount of active ingredients and their efficacy. An example of such an OECD data package is given in (4). This recent report (reference in page 18-21 of (4)) provides data concerning chronic toxicity to fish and other aquatic vertebrates, invertebrates and algae, in addition to biodegradation data linked to the chain length and the degree of ethoxylation. Data of this sort is needed for Eco-label applications with the ultimate aim being to ensure the survival and preservation of all of aquatic organisms in our waters.
As a result of the continuous strive to achieve for higher goals regarding environmental issues the criteria is revised every 4-5 years. The ideas presented and demands required, which go beyond the specific formula could be demands on production facilities, waste treatment and …
The focus of the Eco-labels is towards each company having a general ecological certification akin to ISO 14001 whilst, and for example, BRA-miljøval focus on low pollution from transportation of goods and personnel (carbon footprint). Comparison of different Eco labels – details
II. THE NATURAL AND ORGANIC LABELS ARE ALSO FOCUSING ON THE LIFE CYCLE OF THE PRODUCTS
Here the focus is on the intrinsic contribution to the products: the raw materials. The questions of concern here are: Do these come from nature? Are they grown, processed and handled in a sustainable and responsible way? For many a clear example of where both of the above questions can be answer with a ‘yes’ is organic agriculture whereby production rules require the absence of (for example) synthetic fertilizers, which may pollute land or waters, and biocides. With regard to life cycle principles, the materials and produce from such production methods follow the generally accepted theorem: What nature can build, it can also break down. Whilst it can be the case that certain ingredients will not fully biodegrade in 28 days (according to the OECD 301 standards), the products and raw material are seen as biodegradable. Hence, they will be broken down to fundamental building blocks for the next cycle of (new) natural substances. Natural and organic labels have existed for many years. However, they cover different methodologies/practices, interpretations or definitions (particularly of natural), and have evolved from different parts of the world. This has led to certain labels which are often not well-known and with differences between their criteria. The following scheme provides a basic summary, however the overall picture is really complex.
III. OTHER ISSUES: CORPORATE SOCIAL RESPONSIBILITY – CSR
Other topics of utmost importance to sustainability, from a general perspective and other than those specifically involving cosmetic product ingredients, involves collective (corporate) social responsibility.
This area poses the following questions:
In Europe concerns, and answers to, these types of questions are increasingly becoming more and more popular amongst the general public. This has in turn, resulted these concerns becoming equally crucial for companies themselves. A prime example is the building of new, state-of-the-art data center facilities in Ireland and Denmark by Apple Inc., which follows their decision to provide 100 percent of the energy requirements from renewable energy sources. At present, many multi-national cosmetic industries are focusing on such issues. It remains the case that for the majority of consumers the product in question, its efficiency and cost, remains the focus when it comes to a purchase. Therefore, labels are in a good position to effectively communicate with the consumer when choosing sustainable products.
IV. WHAT ABOUT THE STANDARD INGREDIENTS? WHEN AND WHY SHOULD THEY BE SUBSTITUTED?
Many of these cosmetic ingredients remain problematic from a sustainability point of view since a majority of the current ingredients are synthesized from finite sources such as mineral, oil, or gas. Additionally, many of these ingredients are non-biodegradable, which means that they will persist and accumulate in Nature. Under the EU REACH (Registration, Evaluation, Authorization and restriction of Chemicals) legislation there is the potential, in the absence of regulatory provisional requirements, for such unsustainable, non-biodegradable ingredients to be registered for use in the EU during the coming years. As a consequence, it is likely that there will be increased emphasis and additional focus on environmental issues, which are of equal, and major concern. Specifically, these concerns are related to the clarification of whether ingredients are biodegradable. It is apparent that the problematic products are those which are non-biodegradable. The questions therefore are: Under what conditions are these ingredients biodegradable, and can the products of their degradation be used by natural environmental cycles to provide the basis for new raw materials/ingredients? Notable, there is often a close connection between those ingredients that are non-biodegradable, and those ingredients with the following markings of concern (6):
As a useful point of reference empirical data from many ingredients is available on the European Chemicals Agency (ECHA) website (7);the general requirement being the availability of a CAS number for chemical ingredient in question. Some of the ingredients of interest included on the ECHA website are used in cosmetics, and include (for example): Silicone oils (especially the small cyclic D4 and D5 molecules), phthalates, borates, EDTA, a number of conditioners and certain toxic (heavy) metals.
Many cosmetic development departments try to avoid the sustainable markings because this gives restrictions as to the number of ingredients possible for use. From a start point of view, formulating according to specified label criteria may lead to lower cosmetic quality of the final cosmetic products in relation to consumer acceptance. However skilled formulators will soon learn how to prepare nice cosmetic formulas under new restrictions. By analogy to perfumes: When or if certain ingredients become restricted or banned, the creative development team will always find a solution. Hence, restricting the use of raw materials of choice will always be responded to by challenges of innovation whose solutions fundamentally require creativity.
It has become increasingly apparent there is a clear, long-term demand for sustainability with respect to consumer products. With respect to possibility of choices of sustainable cosmetic products, manufacturer claims can often be misleading to the consumer. For this reason labels are required to provide consumers with an informed choice regarding sustainable products. Though problematically there exists many labels within a given sector and, as a consequence, can lead to confusion and inability for the consumer to differentiate between them. Nevertheless, the traditions in the natural and organic world market vary from market to market and changes towards harmonization of such terms will take time. Indeed, consensus agreement on clear, strict standards and principles might be able to pave the way towards fewer and more broadly accepted labels. Two principles of sustainability can be established with regards to labels; both of which are based on life cycle thinking:
i. The Eco label principle where focus is on the output, and documented factors such as environmental toxicology and biodegradation or
ii. The natural/organic principle: Nature will give back to Nature. In order to protect and preserve the Earth for possible future generations it seems apparent that one should to take responsibility in the present to avoid further points of no return.
REFERENCES AND NOTES
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