The FDA has yet to define the term, so brand founders are doing it themselves. 

By Jenna Birch
Updated Apr 22, 2020 @ 4:30 pm
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Credit: MARC TRAN/Stocksy

A couple years ago, I developed angioedema after my third failed attempt on hormonal birth control. My eyes swelled up for weeks, blocking my visual field. At that point, suspicious of altering hormones, I decided to leave my body’s natural composition untouched. But it’s hard to do with so many endocrine-disrupting chemicals (EDCs) lurking in our everyday beauty products, like parabens, phthalates, formaldehyde, and talc.

In an effort to reduce my exposure to EDCs and other toxic chemicals, I started to dabble in clean beauty last year. In my opinion — and this is one that differs among experts and brands — there was more than enough research on ingredients like parabens, formaldehyde and phthalates to warrant a look at some alternatives.

The only problem? I discovered there was no common definition for what ingredients were considered “clean.” In fact, the only definitions out there seem to originate with brands themselves, and change based on who you’re talking to (or, I should say, buying from).

Why Isn’t There a Standard Definition of Clean?

Cosmetic ingredients are hotly debated in the U.S., where the FDA has banned just 11 additives in our cosmetic products. And there hasn’t been significant change to American cosmetic regulation since 1938. “With the exception of color additives, cosmetics may contain any ingredient, as long as it does not cause the product to be unsafe, adulterated or misbranded in any way,” Monique Richards, a spokesperson for the FDA, tells InStyle.

If this seems pretty wild considering how far technology and science has advanced in 80+ years, you’re not alone. Researchers and scientists have theorized some of these chemicals enjoy wreaking havoc on the body — and we’re slathering on creams with those disruptors in them. EDCs can act like thyroid hormone, testosterone, and more, causing health effects downstream, including neurological changes, low birth weight, reproductive issues, and certain kinds of cancer, says Dr. Tania Dempsey, an integrative medicine specialist in New York City. Ingredients like BHA, BHT, and plastic microbeads can also wind up in our pollute waterways and harm aquatic organisms, among other environmental concerns — so there’s another question of who’s calling what “clean.”

With so little cosmetic regulation, “clean” beauty brands have stepped in where the government has lacked. Beautycounter founder Gregg Renfrew launched her brand after looking to switch out her cosmetics to safer, more sustainable options, and couldn’t find products without questionable ingredients. “I felt people were being asked to compromise their health in the name of beauty,” she tells InStyle. She has testified before Congress, most recently in late 2019, asking for more oversight on what additives companies are allowed to put in their products. In fact, she’s been making regular trips to Capitol Hill since 2013, lobbying for better regulation.

Credit: truebotanicals/Instagram

She’s not the only one whose fight for cleaner beauty is personal. Hillary Peterson, founder of True Botanicals, was diagnosed with thyroid cancer at age 32, and only learned about the potential for EDCs in her cosmetic products afterward. When Tata Harper’s stepfather was diagnosed with cancer, she says she began analyzing every product she put on and in her body. Saint Jane Beauty founder Casey Georgeson’s second daughter was born “severely underweight,” which multiple studies have linked to EDC exposure in the womb. When she started her line, she tells InStyle, clean was “non-negotiable.”

A former executive at Estée Lauder, Saie founder Laney Crowell witnessed how slowly innovation happened at conventional cosmetic companies in general. When clean makeup felt like a long way off, she founded Saie in an attempt to move faster. Europe, for instance, has managed to blacklist 1,300 chemical ingredients from use in cosmetics — parabens, triclosan, formaldehyde, talc, coal tar, and more — and most clean beauty brands note they at least adhere to these standards.

But “green” and “clean” have “no FDA regulatory meaning” in the United States, according to Richards. So, what is “clean,” exactly? It depends on who you ask.

True Botanicals defines clean as “safe” above all (another movable target), but Peterson acknowledges the heart of the problem resonating with me: “When brands set their own definitions and standards, then of course they are going to meet them,” she says. “But that doesn’t really help the consumer.”

How Brands Define Clean — and How They Differ

It’s probably easier to figure out what beauty products are dirty, so to speak, packed with the sort of hormone-disruptors and environmental pollutants you may want to avoid, whereas there’s a lot of nuance between clean brands.

Saie’s ethos is “good on you, good for you,” and they strive to use ingredients thatthe safest, purest ingredients available. Saie is also heavily focused on creating products that are safe for the environment and people’s bodies. “One of our top priorities is to think about whether or not the ingredients are biodegradable, how things wash into the water supply, the way ingredients are grown or processed, and whether they are organic or non-GMO,” she says. Some 2,000 ingredients are on Saie’s no-list, concerning both sustainability and human health.

Credit: tataharperskincare/Instagram

Tata Harper says clean means ridding products of “controversial ingredients” used in cosmetics for decades, and should be a “baseline.” “But we do so much more,” she tells InStyle. “All of our formulas are 100% natural and non-toxic and every single ingredient we use comes from nature,” she explains. She calls her line “green” beauty, with kelley-colored and recycled packaging to match.

Some brands opt for third-party certifications, which can often be found on product packaging. Saie, Beautycounter, Juice Beauty and W3LL PEOPLE have products that are EWG-verified, adhering to the organization’s list of over 1,500 “unacceptable” chemicals and limiting ones that are scientifically questionable for health. Tata Harper uses ECOCERT to certify its organic ingredients and environmentally-friendly practices.

Peterson enlisted MADE SAFE to certify True Botanicals, which she says is the “only organization I know of that examines every single ingredient” before deeming a formula safe for humans and the planet. Her line now avoids 2,500 ingredients, one of the most restrictive blacklists of all. Of course, these certifications can be costly and may exclude emerging brands who lack the funding to get such stamps of approval — all while following the same guidelines for what they consider clean and safe.

All verifications are not all created equal either, or without questions. The recent “Clean at Sephora” stamp came under fire for allowing PEGs, which are widely considered a clean beauty no-no. PEGs are made through ethoxylation, and a carcinogen called 1,4-dioxane is often a byproduct of that process. (Sephora is now, however, requiring brands that want its stamp to make sure 1,4-dioxane is kept to trace amounts.)

On the ingredient level, every brand’s decisions are unique. A lot of natural brands use essential oils, which are highly touted for their potential health benefits, reducing inflammation and soothing skin when used appropriately. It’s not hard to see why they’re a favorite in skincare as an alternative to synthetic fragrance either; they are dual-purpose. Strawberry seed oil, for example, is a naturally-derived astringent, and also responsible for the refreshing, botanical scent of Indie Lee’s Brightening Cleanser — one of the single best fragrance experiences of any beauty product I’ve encountered.

That said, essential oils may cause skin irritation in certain people, which has given rise to controversy in recent years. When it comes to making ingredient decisions, brands often have to weigh the pros and the cons. “We feel strongly about [essential oils’ and] their holistic benefits,” says Lee, who defines clean as using ingredients in their purest form while being as effective as traditional cosmetics. “Being mindful of the potential for irritation, we carefully select high-quality essential oils for the nourishing and soothing effects.”

Tata Harper issued a statement in 2017, saying the brand will always list the oils on its packaging and website so consumers can “make an informed decision” about the exact product they are purchasing. Still, some brands choose to formulate without essential oils entirely.

Tiffany Masterson, founder of Drunk Elephant, was suffering from acne, rosacea and excess oil production when she started researching ingredients that might be affecting her. Drunk Elephant now avoids the “Suspicious Six,” including essential oils, silicones, chemical screens, SLS, drying alcohols, and fragrance or dyes.

In creating her definition of “clean,” Masterson says she was as concerned about the health of the skin as the whole body. “I didn’t care if it was synthetic or natural, I just wanted it to be safe,” she says. “I didn’t know the word ‘biocompatible’ at the time, but I would have used it.” This means two things: If an ingredient got into the bloodstream, would it be linked to disease or hormone disruption? “Or,” she says, “would the ingredients be linked to irritation, disruption or stripping on the actual skin itself?” Every product in her line must be a “no” on both counts.

Some clean brands use silicone for bouncy, slippery texture. Wander Beauty called silicones “ideal” for clean beauty brands to use in a 2019 blog post. Crowell, on the other hand, did not like the research she found on the same substance. “Silicone is something your body can’t absorb,” she says. “When it goes down the drain, it goes into waterways, and it’s consumed, drank, bathed in, and more.” Avoiding silicone meant taking two years to formulate Mascara 101, but the Saie team eventually found success with nourishing beeswax, shea butter and hydra-mineral complex. The result is a lengthening formula that rivals any competitor in the conventional space.

Believe it or not, retinol is also a cause for discussion. Is it “clean” enough? Some research has shown concern that retinol might be cancer-causing when exposed to sunlight — which is why experts have long advised using only at night and with a powerful daily SPF for protection. A few brands have chosen to formulate without retinol entirely, like True Botanicals and Beautycounter, despite its history as an anti-aging powerhouse. Other clean brands like Drunk Elephant, Maya Chia, Tata Harper and The Honest Company all have retinol products in their lines — but stabilized without the BHT or parabens used in traditional cosmetics. (There is a lot of nuance here, mind you.)

Of course, avoiding retinol across anti-aging skincare products isn’t easy; Renfrew says it was one of her hardest challenges in formulating. “Our Countertime line was many years in the making,” she says. “For us, the winning combination to replace retinol was pairing Bakuchiol with Swiss Alpine rose.”

Sunscreen is another adventure. Peterson says she’d like to use “non-nano zinc oxide, but it’s difficult to formulate in a way that suits all skin tones and feels elegant.” How do you create an ultra-wearable formula that doesn’t leave residue? One of True Botanicals’ harder challenges has been SPF with performance to match her high ingredient standards. Her team is still looking for the workaround. “Finding pure iron oxides, not tainted with heavy metals, is also difficult,” she notes.

There’s not perfect agreement over the superior sunscreen, either; zinc as the go-to, though. Juice Beauty SPF Sport Sunscreen and 100% Pure Green Tea SPF 30 formulate with zinc oxide, but brands like Supergoop! opt for different actives.

In sticking to these high ingredient and performance standards, some brands take eons to finalize a product (or never do). Crowell says Saie has started and abandoned 10 products that simply didn’t work right, endlessly iterating on others. One of the latest launches, Dew Balm, was supposed to be a stick. “The easiest way to apply on-the-go is in a stick,” she says. “We spent six months on it, but the formula would just crumble, because we were not willing to use petroleum or plastics.” Crowell says a lot of sticks on the market rely on microbeads in melted-down form; she refused to do it. “The stick would give the effect we wanted, but it would melt or crumble too much.” When Dew Balm launched, the team had settled on aan environmentally-friendly, recyclable squeeze bottle.

Meanwhile, Harper took three years to perfect the rich, velvety texture of Crème Riche with its 43 actives, finally achieved with fatty acids, antioxidants, shea butter, and jojoba seed oil. “Sometimes, achieving the right texture or consistency can be a process,” she says.

That’s one approach. Masterson, on the other hand, has just embraced unexpected smells and textures — badges of the clean beauty sector, if you will. She didn’t want to add fillers for the sake of it. Masterson recalls concocting her C-Firma Day Serum, getting the vitamin C and pH levels just right for skin. “But my chemist would say, ‘Tiffany, are you sure that you don’t want orange oil? Or lavender? Or a little silicone?’” she says. “I was like, ‘No, I don’t want anything that will change the way the formulation smells, looks, or feels.’” C-Firma doesn’t have the smoothness of other serums; it’s a bit tacky on the skin, but oh does it glow. Masterson goes so far as to say the medicinal smell “excites” her, because it’s unaltered.

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How Do We Make “Cleaner” Choices?

It’s hard to imagine clean beauty will be regulated anytime soon, when the traditional cosmetics have such minimal standards. But that doesn’t mean change won’t happen, perhaps it will even be driven by savvy customers. “I am so excited to see that consumers are more informed than ever,” Peterson says. “They are looking into the safety and efficacy of their products at the ingredient level, and realizing they don’t have to sacrifice one for the other. And they are voting with their dollars. When consumers choose safe products, it forces the industry to adapt.”

Masterson hopes brands emphasize transparency and their points of difference to make things easier on consumers. “I really believe every brand and retailer is with good intent, even though everyone has their own definition,” she says. After all, she was really trying to solve her own problems when she started Drunk Elephant. “My skin did a big turnaround when I eliminated those ingredients,” she says.

I have spent years worshipping the performance of MAC, NARS, and Estée Lauder. But as I spent weeks researching this story, I used clean beauty religiously on my sensitive acne-prone skin. I found serums that didn’t break me out, lip balms with ingredients I actually recognized, and cleansers with new textures but perfect makeup-removal abilities; I did not have a single breakout.

As the informed consumer, you get to decide what ingredients you like, what products to try, what brand’s philosophy you believe in. Because for now, just like beauty, “clean” is in the eye of the beholder.