Formulators of natural personal care products have the same lament as Kermit the Frog—i.e., “It’s not easy being green.” So before proceeding into the ever-unpredictable product development process, claims must be established as to what the final product aims to fulfill—especially in order to direct efforts toward the desired “green” claim for sustainable, natural, organic, etc. Boundaries must be defined and agreed upon, including what guidelines should be followed if a consensus does not yet exist among all the stakeholders. Agreement should even be reached within one’s own development group by asking: What do our customers want? What are our competitors doing? What do our suppliers recommend? What do the regulatory agencies tell us? Reviewing the available resources and examples to assess varying perspectives can provide an overall picture and assist in forming a consistent internal philosophy for future planning.
Clearly, making choices early in the product development process eliminates midstream changes that can derail a smooth ride to the goal, and resources such as The Twelve Principles of Green Chemistry1 can help in product planning. For instance, with the industry already under scrutiny by consumers, colleagues and regulatory agencies worldwide, cosmetovigilance2 using and designing safer ingredients and products is key. Three additional green chemistry principles that surface are designing for energy efficiency (i.e., reducing one’s carbon footprint), using renewable feedstocks such as sustainable vegetal derived ingredients, and designing for biodegradation.
These principles impact decisions in formulation, ingredients and methods, and further influence what ingredient suppliers develop and market to formulators, who in turn hope to make products that consumers want and judge as being effective in delivering benefits they desire and satisfying their varying levels of need to be green.
Consumers look to the media and popular press on principles of green living to make individual buying decisions. Most do not share the passion of lifestyles of health and sustainability (LOHAS) customers, but many find “green” and “natural” claims to be positive attributes of products. Further, while the general public may not be familiar with Rachel Carlson’s book Silent Spring, which jump-started the environmental concern movement in the 1960s, most are well-schooled in the need to protect the environment and accept the tenet that what’s good for the planet is good for individuals.
At the retail level, for instance, the Whole Foods Market chain has grown in volume and stature to the extent that many development projects are initiated under the direction that they must follow the Whole Foods quality standards for body care ingredients, which lists both acceptable and unacceptable ingredients. This standard can be further advanced by following the list of ingredients for premium body care.3 The company’s Whole Body evaluation process claims to identify: ingredients that are “necessary for the product to function well and look appealing, while providing real results”; products with “higher concentrations of botanically derived ingredients”; and both sourced “as close to nature and as minimally processed as possible.” Further, their environmental impact during manufacture and when released into the environment must be minimal; they must also have established safety data or be less likely to cause skin irritation or allergies than other options. Standards for Whole Foods premium body care are the company’s highest, and echo in the mantras of popular books about green living and consumer product company communications.
Although generally dismissed by cosmetic scientists, some lay books4 recommend the Environmental Working Group’s (EWG) Skin Deep database of products as a reputable source for ingredient safety information. This database features some 62,000 personal care products, and rates the safety of their ingredients. The EWG bases its ratings on research reported in the scientific literature, which it references should database users have the wherewithal to track them down. Ratings have two parts: a 0-10 rating of known and suspected hazards, grouped in colors where green = 0-2 or low hazard, yellow = 3-6 or moderate hazard, and red = 7-10 or high hazard—as well as a five-point data availability rating including none, limited, fair, good or robust.5
Note that since these ratings are based on ingredients listed on the label and not on actual product safety evaluations or actual formula recipes, their reliability rests on assumptions about how ingredient properties manifest themselves both in the products and during actual use. With this focus on the negative, and a wealth of alarmist assertions about cosmetics safety, the industry gets a picture of what the concerned consumer may be reading—hopefully with some skepticism about the finality of this data. The group also highlights the fact that cosmetics do not require premarket regulatory approval in the United States, which is all the more reason for the industry to strongly support self-regulatory efforts through the Personal Care Products Council, as well as individual initiatives.6
Procter & Gamble: A strong example of a broad sustainability vision is that of industry giant Procter & Gamble (P&G), which encompasses dual environmental and social responsibility programs. This is likely in part due to consumer demand. A look at the company’s website reveals that up to 14% of U.S. consumers are committed enough to greener products that they are willing to sacrifice some performance and product value; more importantly, an additional ~70% “sustainable mainstream” consumers look for environmental improvements in products that deliver equivalent performance and value a large target population.7
During her talk at the 2012 Sustainable Cosmetics Summit,8 Gillian Briggs, PhD, Procter & Gamble’s beauty sector R&D sustainability leader, described two projects having the long-term goal, as she stated, of “using 100% renewable materials or recyclate for all products and packaging.” Also, in the shorter term, specifically by the year 2020, the company aims to replace 25 percent, based on 2010 levels, of the petroleum-based raw materials it uses for products and packaging with sustainably sourced, renewable materials. And by 2015, the company expects to confirm that all palm oil purchases originate from responsible and sustainable sources; further, the company expects to increase the use of renewable energy in its plants to 30%.7, 8
In her presentation, Briggs detailed a high density polyethylene (HDPE) used for shampoo bottles that is derived via fermentation from ethanol sourced from Brazilian sugar cane.8 P&G worked with its supplier, Braskem, which developed this “green cycle” plastic to capture some of the greenhouse CO2 in the atmosphere. The HDPE bottle can be recycled just like the petrochemical-based polyethylene, reducing the environmental impact of non-degradable packaging. Briggs described another packaging project, BeGreen, using a unique, robust fiber blend of bamboo and bulrush to form the resilient clamshell backing for Gillette brand razor packs, making them bio-sourced and biodegradable. Johnson & Johnson: Mainstream consumers in pursuit of “greener” options gravitate toward major personal care brands, and one major introduction speaks to these consumers.
Johnson & Johnson (J&J) recently launched its Neutrogena Naturals brand skin care line, with an apparent objective to touch all the bases.9 The line consists of 10 products and promotes the brand’s heritage, proclaiming “every Neutrogena Naturals product is made with the same standards of efficacy and excellence as every Neutrogena product you know and trust.” The products are promoted as “pure, safe and effective,” typical for this segment, and also disdain from using major ingredient pariahs, claiming “no harsh chemical sulfates, parabens, petrolatum, dyes and phthalates.”
Of interest to the formulator here is the use of coconut and palm-derived glycosides, and zwitterionic betaines and sultaines in the cleansing products. In addition, a mild anionic sulfoacetate is used in one formula. These materials are acceptable under the Whole Foods Body Care standards, but not its premium standards, nor the Natural Products Association (NPA) standards for personal care; for more on these standards, see the article by Duber-Smith.
The conditioning polymer guar hydroxyproyltrimonium chloride is acceptable under all these standards, and the Neutrogena Naturals line uses it in three of its rinse-off cleansers. Sodium benzoate, a food-grade preservative, also is used extensively throughout the line, supplemented with sorbate and benzyl alcohol as well as other nature-identical preservatives allowed by most natural standards groups. Further, sclerotium and xanthan gums are used as thickener stabilizers, with an acrylate polymer employed only in the cleanser/makeup remover. Liberal use is made of olive oil and palm oil esters as emollients and emulsifiers, although this author found it difficult to identify primary emulsifiers in the moisturizer and night cream emulsions. Each product claims to reveal the percent of its content from natural origin, water included, which ranges from 86% for the cleanser/makeup remover to 100% for the lip balm (the line averages 94%).
Partnering with conservation organizations the Nature Conservancy and the Forest Stewardship Council, Johnson & Johnson developed the Neutrogena line alongside two dermatologists (Jeanette Jacknin, MD, whose background is in holistic dermatology; and Balz Frei, MD, director of the Linus Pauling Institutes) to understand and use a range of “bionutrients” such as vitamins, minerals, amino acids/peptides, essential fatty acids, flavonoids/polyphenols and sugars for skin care.
Salicylic acid derived from wintergreen, which is commercially availablea, is chief among the active ingredients, and salicylic acid is active at 1% in the line’s three acne products. The remaining seven products include willow bark extract, another salicylate source, natural oils and plant-derived excipients.
Although many of the formulations, either as-is or with slight modifications, could have been certified under one or more natural and organic schemes—i.e., NSF/ANSI 305, Ecocert/COSMOS, NaTrue or the NPA—none of these is mentioned. The company asserts that the ingredients, being of natural origin, sufficiently justify the line’s designation as natural. Further promoting the green initiative of this line, the website touts the use of up to 50% recycled plastic in the product bottles; 100% recycled paper; and a green server employing renewable power sources, solar and wind to power the website.
Raw Material Examples
Specialty chemical manufacturers also continue to respond with new natural and green initiatives. One company, Alban Muller International, self-proclaimed as “Le Natural Product Designer,” holds the core belief that being truly green cannot be superficial; it must be a global approach, otherwise it is no more than “green washing.” The company states, “To act ‘green’ is just taking the true stakes of our times into account: We shall very quickly need to do more with less, so we have to look for all our resources.” Further, “Cosmetics are a good industry to become greener, as it is already a pretty clean industry, and where progress can be made. New greener ingredients will help [create] greener formulations to meet consumers’ requirements.”10 The company takes an eco-responsible approach to developing its plant actives by sourcing high-activity cultivars, ideally from local sources, and using water and bioethanol for extraction; then it recycles the solvent and composts the residual plant matter to complete the cycle.
Soliance, a division of Agro-Industrie Recherches et Développements (ARD), is another company that uses a vertical integration and biorefinery approach to sustainable, bio-based specialty ingredient production. The research center develops non-food applications of agricultural products primarily grown around Reims in the Champagne-Ardenne region of France. Since 1994, it has focused on the development of natural active ingredients via green processes for the cosmetics industry. Some familiar chemistries manufactured here from feedstocks of sugar beets, wheat and rapeseed are hyaluronic acid and dihydroxyacetone (DHA), as well as the unusual natural biosurfactant class of sophorolipids.11
More specialty chemical companies are promoting this integrated approach of using primary plant metabolites—i.e., sugars, amino acids and proteins, and fatty acids and lipids, to produce functional materials for personal care using basic chemical processes allowed under most of natural certification schemes. Such processes include hydrogenation, esterification, protein acylation and glucosidation. Notable examples are the amino acid derivatives from Ajinomoto, sucrose esters from Croda, and glucosides from Seppic.
As witnessed at the 2013 NYSCC Suppliers’ Day, companies both large and small are promoting their materials as “certified natural” by one of the private certifiers such as the NPA, Ecocert and NaTrue. However, the question to ask is: Do typical personal care consumers look for such certifications?
Definitions, Certifications and Claims
Only the natural and organic niche products promote the use of “organic” ingredients, and these are compliant with the U.S. Department of Agriculture (USDA) rather than the NPA, Ecocert or NaTrue. Once there is regulatory agreement on definitions for green claims from agencies with jurisdiction, then maybe some language standardization will occur, and lead to consumer understanding. The International Organization for Standardization (ISO) continues to develop standards for “natural” and “organic” personal care under the Technical Committee on Cosmetics TC217: “ISO/AWI 16128 Guidelines on Technical Definitions and Criteria for Natural and Organic Cosmetic Ingredients and Products.” The industry would hope that this push for international harmonization of cosmetic regulations would help make it an acceptable standard globally.
Years ago, the U.S. Food and Drug Administration (FDA) and USDA proposed coming to a consensus about nomenclature, labeling and claims for “natural and organic” cosmetics but no recent progress has been reported, although this may all come together after ISO standards are promulgated.12 An information sheet was posted by the USDA to clarify its role in certified organic labeling of cosmetics in April 2008.13
Other regulatory agencies have weighed in with USDA’s Bio-Preferred initiative, and the U.S. Environmental Protection Agency’s (EPA) ratings for “environmentally preferred” products. In fact, the EPA now maintains a database of Environmentally Preferred Products (EPP),14 where one can find personal care citations under the “Grocery/Miscellaneous Store - Personal Toiletries” option in the group’s supermarket items category menu, as well as many other consumer and industrial products.
The EPA considers greener products as those for which “scientific evidence demonstrates that human health or environmental impacts have been significantly reduced in comparison with other products that serve the same purpose.”14 Standards the EPA references include third-party certifiers such Green Seal,15 for cosmetics and hand cleansers; Cradle to Cradle Products Innovation Institute,16 for moisturizers and face cleansers; and the USDA’s BioPreferred program, for lip care and certain bath products, among others.
As arbiters of environmentally acceptable products, here the EPA crosses into the FDA’s and Federal Trade Commission’s (FTC) territory. When companies make green product claims, the magic word is “natural.” Although marketing’s focus about the product sometimes shifts toward the sustainability of its core technology or toward minimizing the consumer’s carbon footprint, the default claim for product and ingredients is “natural.” In relation, tasked with consumer products claims validation, the FTC issued its “Proposed Revisions to the Green Guides” in the Federal Register in October 2010 to elicit comments to update the original 1992 Green Guides, which were revised in 1996 and 1998,17 to assist marketers in making non-deceptive claims. These guides were ahead of their time for personal care, but they did not address “natural” or “organic” claims.
Organic claims for agricultural products fall within the jurisdiction of the USDA National Organic Program (NOP), and the FTC will not address organic claims for non-agricultural products, such as cosmetics. The FTC lacks basis for this decision, however, because as it reported, “no commenters submitted consumer perception evidence [i.e., surveys] on this issue.” Likewise, the lack of consumer perception data has led the commission to refrain from defining “natural.” The term natural can be used in many contexts, according to the FTC, and hence is difficult to define out of context. One online survey by P&G, cited by the FTC,15 sought to discover the consumer definition for “natural,” but apparently it did not clarify the term. To date, the FTC still does not provide guidance, and continues to seek consumer perception evidence. However, the group does warn that “marketers must qualify claims appropriately to avoid consumer deception, and must ensure they can substantiate any reasonable interpretation of their claims,” per section 5 of the FTC Act.17
The industry is again left to its own devices to decide what is natural, and what constitutes a green direction in product development. Until such time as one organization such as ISO proposes guidance that the regulatory agencies adopt, one can presumably operate under a laissez-faire arrangement, keeping internal substantiation records on file so they can be shown when the time comes. Maybe it’s better that way.
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1. J Warner and P Anastas, The Twelve Principles of Green Chemistry, available at www.warnerbabcock.com/green_chemistry/12_principles.asp (1996)
2. U Moretti and G Velo, Cosmetovigilance: The ‘beautiful’ risk, available at www.ncbi.nlm.nih.gov/pubmed/18422387 (2008)
3. Whole Foods Premium Body Care standards, available at: www.wholefoodsmarket.com/department/article/premium-body-care-standards (Accessed Jun 19, 2013)
4. D Bach, Go Green, Live Rich, Broadway Books, NY (2008) p 82-83; and R Loux, Easy Green Living, ch 5, Rodale, Emmaus, Penn., USA (2008) p 167ff
5. Skin Deep database, Environmental Working Group, available at www.ewg.org/skindeep (Accessed Jun 19, 2013)
6. Personal Care Product Council, www.personalcarecouncil.org
7. Sustainability web page, Procter & Gamble, available at www.pg.com/en_US/sustainability/index.shtml (Accessed Jun 19, 2013)
8. G Briggs, The development of renewable packaging material, Sustainable Cosmetics Summit presentation, May 17-19, New York (2012)
9. Neutrogena Naturals website, available at www.neutrogenanaturals.com (Accessed Jun 19, 2013)
10. A Muller, private communication via e-mail (May 24, 2013)
11. Soliance sourcing presentation, www.soliance.com (Sep 9, 2012)
12. J Ansell, personal communication, May 23, 2013, reference to ISO/AWI 16128 Guidelines on Technical Definitions and Criteria for Natural and Organic Cosmetic Ingredients and Products, available at www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=62503 (Accessed Jun 19, 2013)
13. Cosmetics, body care products and personal care products, USDA, available at www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5068442 (Accessed Jul 3, 2013)
14. EPA Greener Products Portal, available at http://yosemite1.epa.gov/oppt/eppstand2.nsf/Pages/Search.html?Open (Accessed Jul 9, 2013)
15. Green Seal Standards: GS-44 soaps, cleansers and shower products, GS-50 personal care and cosmetics, available at www.greenseal.org
16. Cradle to Cradle Products Innovation Institute, available at www.c2ccertified.org (Accessed Jun 19, 2013)
17. FTC, The green guides: Statement of basis and purpose 2012, available at www.ftc.gov/os/fedreg/2012/10/greenguidesstatement.pdf, www.ftc.gov/opa/2012/10/greenguides.shtm and www.ftc.gov/os/fedreg/2010/october/101006greenguidesfrn.pdf (Accessed Jun 19, 2013)