Clean Beauty Can Get Messy

Health-conscious consumers want brands to come clean about ingredients in their products and they want a clear-cut definition of clean, too.

If there’s one thing consumers love, it’s buzzwords – especially when they see them emblazoned on the labels of their favorite toiletries and cosmetics. It gives them the peace of mind that what they’re putting on their skin – and ultimately in their body – is less likely to threaten their health down the road.

One of them is “clean beauty.” The phenomenon has become a fixture in the business given consumers’ adoption of healthier lifestyles. In fact, the “clean beauty” hashtag has amassed 5.6 million posts on Instagram and a staggering 1.2 billion on TikTok.

Health-conscious consumers want brands to come clean about what they’re putting in their products just as much as they want a clear-cut definition of what “clean” is exactly. In fact, 71% of consumers are unsure what brands mean when they tout “environmentally friendly” products. What’s more, as many as 79% of beauty consumers are skeptical about the beauty industry’s sustainability or “green” claims, per National Advertising Division, BBB National Programs.

No Standard Definition

These claims come in the form of certifications such as Leaping Bunny and Climate Neutral. According to Jennifer Santos, attorney at National Advertising Division, BBB National Programs, who presented at this year’s Sustainable Cosmetics Summit held in New York City in June, clean beauty is associated with a clean conscience. Packaging copy like safe, non-toxic and ingredient transparency with products being free from parabens and synthetic fragrances are examples under the clean beauty umbrella. It can also refer to a brand’s commitment to ethically sourced ingredients, cruelty-free testing and using biodegradable and recyclable materials in their packaging.

“The problem is, there is no standard definition,” said Santos. “And unless the brand defines what they mean by clean beauty, consumers do not understand the term either.”

Santos cited a recent class action lawsuit filed against Sephora. It alleges that the retail giant’s “Clean at Sephora” label was misleading. The court granted Sephora’s motion to dismiss as it found that a reasonable consumer would not interpret cosmetics labeled “clean” to mean they are free of all synthetic or harmful ingredients when the marketer had specifically defined “clean” cosmetics as free from a narrow list of ingredients.

Generalizing or being vague about clean ingredients and formulas is not a good idea, according to Santos. She cited NAD’s recommendation that Amyris modify its advertising related to the banning “over 2,000 ingredients that are known to be toxic” to people and environment to reflect the ingredients banned that are typically used in cosmetics products.

“When it comes to talking to consumers, even the most well-intentioned brands are leaving consumers disoriented by a wealth of buzzwords and ambiguous claims,” she said.

To gain and sustain the respect of loyal consumers and avert frivolous actions, authenticity is key. Santos recommends brands be specific and use clarity when defining green marketing terms. She also suggests displaying certifications and seals with caution and to be clear on their purpose to consumers.

“Words and images matter,” she said. “And advertisers must support express and implied claims.”

Bringing Ingredient Transparency to the Beauty Industry

According to Kimberly Shenk, co-founder of Novi Connect – a digital platform advocating for ingredient transparency and helping retailers and consumers make informed choices about the products they purchase – sustainability seals are driving revenue growth.

According to Shenk, 56% of sales growth during the past five years came from personal care and cosmetics products sporting a sustainability seal. In that time, half of retail sales have been for products with a sustainability seal. And the more, the merrier. The growth rate was three times faster for products that had multiple sustainability seals.

Apart from eye-catching packaging, brands are differentiating themselves by using “formulated without” claims. In particular, “free-from” dyes, parabens, phthalates and silicones are popular. However, these claims often lead to false marketing claims.

“The reality is, when you’re talking only about ‘NOs’ –what’s absent and not in the product – you are not talking about what’s in the product. So, you are forcing the consumer to accept that everything in the product is good,” Shenk explained.

In lieu of “made without” claims, Shenk suggested focusing on ingredient transparency by including what’s present in the entire product, including the impurities or contaminants introduced during manufacturing and ingredient sourcing.

She cited three examples of questionable claims. One of which was Target’s “reef-safe” claim in which the retailer was accused of deceptively marketing organic sunscreen products as safe for coral reefs despite containing ingredients known to cause coral bleaching.


While Target listed the ingredients it was formulated without – oxybenzone, octinoxate, octocrylene, homosalate, 4-methylbenzyldene camphor, PABA, parabens and triclosan – In lieu of “formulated without” Shenk suggested disclosing the particle size of the microbeads to be more transparent.

Another example was Dr. Squatch’s no harsh chemicals claim— denoted by use of a skull and crossbones symbol on its soap packaging. To be more transparent, Shenk suggested the brand provide per ingredient safety assessment and toxicology studies.

Truly’s Jelly Booster Pigment Treatment Body Potion was another example of a brand that used “formulated without claims.” In this case, the formula was free of common animal-derived ingredients like honey, beeswax, lanolin, carmine, stearic acid and gelatin. Shenk suggested companies provide the feedstock source of all ingredients used (e.g. animal by-products or vegetal).

Substantiating Ingredient Transparency Requirements

Novi Connect works with clean programs at Credo, Ulta and Sephora. Currently, there are over 2,000 active brands and formulators; more than 50,000 products verified for a seal; and over 20,000 sustainable alternative material options available to purchase. These labels are powered via substantiating ingredients transparency requirements, including testing for heavy metals, biodegradability and asbestos; certifications for vegan, cruelty-free, Fair Trade, USDA Biobased, organic, Environmental Working Group and Roundtable on Sustainable Palm Oil, among others; contaminants like 1,4 dioxane, PFAS and heavy metals; feedstock source which falls under animal by-products, vegetal, bio-based, microbeads, microplastics and USP grade; and percent composition, or the percentage used in product, threshold, IFRA and phenoxyethanol, among others.

“This is a huge push with all of our retail partners,” said Shenk. “They want to be a resource to their brands. And it’s also helping them, because at the end of the day, more brands, more products with more distinctions get more revenue. In order to do that, you need to combine resources for your brands to help them when they’re not compliant.”

Kimberly Shenk, cofounder, Novi Connect.

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