Cosmetics Sustainability Claims - Green or Grey?

TAGS:   Sustainability / Natural Cosmetics   

ISO14201 (2016) — “The concepts involved in sustainability are highly complex and still under study. At this time there are no definitive methods for measuring sustainability or confirming its accomplishment. Therefore, no claim of achieving sustainability shall be made.” 

The foundation of any cosmetic product and its brand is its ability to effectively communicate with the consumer, extolling product virtues and benefits, without lying and misleading them.

In recent years the global cosmetic market has seen very rapid growth in sales of “natural” and “organic” personal care products. With the ever-expanding number of products and brands appearing in the market, they are often accompanied by a lack of transparency in terms of claimed “sustainability” resulting in a confused and “greenwashed” consumer.

With growing consumer demands for sustainable products of natural/organic origin and a global push from the UN to protect the planet and its resources, clearer labeling concerning the production and sourcing of such cosmetic products has become not only paramount but an expected “norm”.

Let's discuss the challenges surrounding so-called green and sustainable claims...

What are Cosmetic Claims?

For cosmetic products, a claim is:

• A statement that is used in advertising a product, and
• That addresses positive aspects of the products performance as well as the benefit to be gained from using that product

Selling a product with negative claims and attributes clearly has no consumer benefit!

Yet, we can still ask the question further - what actually is a claim? Here in the EU, according to the Cosmetics Directive, they are defined as:


In other words, whatever the consumer observes, perceives or feels when interacting with a cosmetic product, can be described as a “claim”.

Furthermore, claims are marketing tools that are essential to help end-users choose a product; foster competition; and promote innovation. We make them solely to make money, and to achieve these monetary gain products need to meet consumers real needs and expectations, whilst being compliant with regulatory requirements.

Lack of Compliance and Common Pitfalls

When trying (or not) to comply with claims requirements, brands/products always seem to lack integrity and credibility. that is, they either tell lies or just fill “space” with airy-fairy nonsense that has no bearing on the purpose of the product.

Common “claims” pitfalls are:

• Lack of Evidence
• Vagueness
• Irrelevant
• Not Truthful
• False Labeling
• Misleading
• Opaque rather than Transparent

It is still shocking that brands still want to make drug-like claims, and many claims are consumer irrelevant highlighting a clear lack of consumer insight (which is so important in claims development). Some brands still pursue trying to extrapolate “data” into claims, and most brands are still fixated on copy-pasting supplier information into their claims.

Furthermore, product development - be they marketing or other - suffer from Limpet Syndrome, whereby they are so fixated on a claim at the start of their development process, that it is impossible (nearly) to extract them from it. Developers still have the bad habit of starting with their claim (rather than a claim concept) and then trying to justify the claim. It’s rather like trying to put a square peg in a round hole.

Another issue is the very poor communication the industry provides to consumers. Whilst, the industry does well communicating business-to-business, communicating to the consumer falls short of expectations. More often than not is reactive (slow) rather than proactive. This is a concern since many consumers end up relying on fake news — gospels according to the tabloids or internet “noise”. The consequence is distrust.

Key steps in any claim development process are:

• Consumer insight
• Product purpose
• Claim development strategy
• Body of evidence, and
• Communication

If the developer cannot get these processes right, it does not matter what the trendy claim might be, they may well fail in the overall compliance.

Claims in a Green World

Given the above, what about so-called “green” and “sustainable” claims? For natural and organic products the following questions need to be considered:

• Where do you want to Advertise?
• What does your Consumer Insight tell you?
• Does every consumer have the same understanding of “Green” products?
• What do YOU mean by “Green” products?
• Are your products Natural or Organic?

When developing claims in this green space, the developer needs to be mindful that the so-called “green” consumer is mindful of consumption with respect to planetary issues, with:

• Environmental awareness
• Availability
• Affordability, and
• Product efficacy being key

For “sustainable” claims similar questions apply. In addition, we need to address the entire cycle of resource handling. The UN’s definition of sustainability is:



Furthermore, claims in this arena, especially for consumer products has been quashed for now since ISO14201 (2016) on consumer product environmental claims states that, “The concepts involved in sustainability are highly complex and still under study. At this time there are no definitive methods for measuring sustainability or confirming its accomplishment. Therefore, no claim of achieving sustainability shall be made.”

This clearly applies also to cosmetics since we are very successful at “greenwashing” the consumer. In the UN’s guidelines for providing product sustainability information, defines greenwashing as:

• An attempt to mislead consumers and to market products more environmentally friendly than they actually are.
• An exaggeration or misrepresentation; a claim that cannot be verified, is irrelevant or is simply false.
• Where green relates to environmental claims but is also used in the context of social and ethical product information.

How many brands fall foul of these guidelines?

Issues with Green Claims

Trying to make green and sustainable claims for the consumer is difficult given the enormity and complexity of the subject. Furthermore, we are still at the point where the world is operating as individual countries with no global harmonization in clear sight.

There are so many unaddressed issues when it comes to developing such claims for cosmetics, like:

• Widely differing definitions of each category exist
• Legal protection of the terminology does not exist
• Cosmetic ingredients are technically chemical and many need chemical modification before they can be used
• Standards (ISO) exist rather than regulations

Is this too little too late?

With a number of private standards, their authenticity is also questionable; Greenwashing abounds; and media attention to “green issues” drives confusion amongst both consumers and the industry alike.

Furthermore, all private standards for Natural and Organic Cosmetics should mention that a baseline requirement is that these products must first comply with EU Cosmetics Regulation 1223/2009 (plus any recent updates), as well as any other national requirements, and not try to circumvent them!

A Grey Reality and Label Confusion

In trying to do the right thing, it is clear as an industry we have created a millstone around our necks. Globally anyone working in the personal care industry especially cosmetics agrees with the fact that there exist:

• Too many organic/natural labels and so-called standards with little harmonization
• Abuse of greenwashing, and
• Outright confusion

There is an enormous demand for global harmonization when it comes to certification and standardization. Current standards whilst a step in the right direction are also incredibly confusing. This does not bode well for consumers. Furthermore, all standards except for Asia are VOLUNTARY.

However, there is consumer pressure via “product expectation” and standards offer added value above so-called “norms” (e.g., ISO16128). Many so-called national standards also have international reach, and many of them (except Natrue, Cosmos and ISO) are based or derived from food standards which do not fit with personal care products (especially those outsides of the EU).

The Need for A Global Standard

The Natrue standard was developed to prevent greenwashing and sets out a detailed yet clear easy-to-follow process for gaining accreditation. It is an ingredient and product driven. Cosmos was set up soon after Natrue - its standard is more process focused and is not clearly set out which makes it difficult in places to follow. It is more flexible than Natrue since it permits petrochemicals in the processing of some ingredients. Both labels prohibit GM ingredients and promote animal welfare.

It is technically incorrect to compare these 2 standards to ISO16128 (see next section), since not only has the ISO standard itself has been globally criticized for its contradictions and lack of clarity but that this lack of clarity is driving confusion. Thus, it could be considered legitimized greenwashing, since it is a malleable document rather than a good solid basis which could have led finally to a standard worthy of inclusion into the Cosmetics Directive.

There are too many hidden “what-if’s” and no provision for a definition of an organic product. Consumers are more conscious of product origins from food to cosmetics and the ISO standard excludes this.

Since this standard is also voluntary and a basic calculation tool, Natrue and Cosmos offer a better approach - there is an achievable benchmark whereas with ISO there are no set criteria. However, should any region or country were to adopt ISO16128 into law, then serious issues will arise such as “legitimized greenwashing,” and would also fall foul of the claims criteria Informed Decision (as it also the current status). ISO16128 requires amendment (e.g., the prohibition of petrochemicals and GM ingredients), and input from both Natrue and Cosmos experts.

Clearly, there is an urgent need for a global standard when it comes to natural/organic cosmetics. The lack of harmonization and transparency will continue to drive greenwashing.

Given the industry’s need for clarification in the field of organic/natural products, brands should consider 3 key questions:

• What market do you want to penetrate (ultimate consumer)?
• How do you want to present your product?
• How deep is/will be your commitment to the label you choose (Natrue setting a standard for 75% of the total brand; and Cosmos per product)?

Obviously with the development of organic/natural products this also entails evaluating and changing/building good sustainability practices as well, since these have a major impact going forward.

Sustainable Claims

It is clear that it is just about impossible to make this type of claim(s). The complexity of “sustainability” demands made under the UN’s definition make it hard and extremely challenging. So, how do we get there? Given the lack of legislation we are reliant (at least in the EU) on the 6 Claims criteria of the EU cosmetics legislation and we can use these to harmonize with the current UN’s current standing on the issue of sustainability, as a way forward.

When developing, a cosmetic product developer needs to understand that whilst these criteria are very much an EU initiative, if you look at other countries national requirements you will find their demands are basically the same - an honest product with clear credibility and integrity.

These criteria cannot be just ticked off one by one since they are inextricably linked to each other and thus cannot be viewed nor taken in isolation:

• Claims cannot be considered “Legal” unless they are “Truthful”.
• Truthfulness requires “Evidence”.
• Evidence needs to be “Honest”.
• Honesty requires “Fairness” which itself provides for
• “Informed Decision Making” - and ultimately a satisfied consumer

Assuming you are compliant with the 6 criteria in terms of product performance and efficacy, you can use them in trying to make sense of improved green claims as a way forward to sustainability. The “objectives” (Table above) are just suggestions and not set-in-stone but give an idea of just how complex making a sustainable claim actually is. There is indeed much to think about!

Concluding Remarks

With careful consideration and focused development, Natural/Organic claims can work. Greener, so-called sustainable claims will require a complete global cultural shift, harmonization and implementation of globally accepted standards and legislation. In order to achieve these, a step-by-step process will be required starting with compliance with current claims legislation and consumer focus. To avoid confusion, the industry should drop the term “sustainable claims”.

Keep Updated with Cosmetic Sustainability Claims

Talk to Dr. Theresa Callaghan where she will discuss issues surrounding cosmetics sustainability, claim pitfalls (irrelevant, drug-like, limpet syndrome…) and how to avoid them.

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