Natural, Clean, and Green? – Common “Green” Cosmetic Claims Explained

As far back as the 1990s ^[1] , the US Federal Trade Commission (FTC) began providing green guidance to help ensure that companies to do not make misleading or deceptive claims ^[2] about sustainable or “eco” products that confuse consumers. It is expected that companies are able to substantiate any green marketing claim despite the fact that there is no formal process to validate these claims. Most companies let their marketing team define the terms they use. Below are common claims and what they may (or may not) mean. 

Companies that claim their product is “Hypoallergenic” or “Suitable for Sensitive Skin” are typically asserting that the product does not cause an allergic reaction. Unfortunately, these claims are not federally regulated and so do not follow a standardized set of criteria ^[3] .

In fact, the FDA states that “there is no such thing as a ‘nonallergenic’ cosmetic” and the ingredients in these products are also found in products without these claims ^[4] . The FDA worked to create a testing standard required for companies who make “hypoallergenic” claims in the 1970s, but the U.S. Court of Appeals for the District of Columbia ruled that the regulation was invalid.

This leaves it up to consumers in the United States to understand their own allergy triggers, look for them on labels, and avoid products containing them. Unfortunately, with trade secret formulations like “fragrance” and “flavor” that are exempt from disclosure, ingredients in personal care products are a black box, making it difficult for people with allergies to navigate product selection.

This is also why full transparency of ingredients, including fragrance and flavor, is important for brands to commit to even though it is not legally required.

Organic certification means that 95% of ingredients in a product have been certified to be grown and processed according to USDA standards through a qualifying certifying body. Manufacturers must follow standards related to pest control, additives, animal treatment practices, and more. USDA Organic restricts which pesticides can be used on crops and prohibits most synthetic fertilizers and pesticides. Organic means an ingredient is inherently not genetically engineered or ‘nonGMO’ ^[5] .

USDA Organic certification is intended for agricultural ingredients, which are ingredients grown and cultivated on farms. According to the USDA, only agricultural ingredients can be certified organic ^[6] . Because personal care products often contain ingredients that are not considered agricultural ingredients, it can be difficult for many types of personal care products to meet organic standards. For that reason, you’ll often see products that contain organic ingredients, as denoted on the label, but are not certified organic on the product level.

Looking for products made with many organic ingredients is a great way to ensure that you’re selecting ingredients that are made with more environmentally sound methods.

At MADE SAFE, we love organic products. But we also take note of that 5% allowance for non-organic ingredients. Some chemicals, particularly the ones that are known as endocrine disruptors, which are chemicals that disrupt your body’s own hormones, can be very active in teeny-tiny amounts. This is why it’s important to understand each and every ingredient, even in a certified formulation.

“Clean” is not a regulated claim in cosmetics, which means companies can use it freely without adhering to any specific standard or definition.

When “clean” first appeared as a claim on the market, it was used primarily by companies who believed they were making products with ingredients that were safer for both people and the planet and wished to differentiate themself from conventional products.

Since its introduction, it has been adopted widely, including by companies who utilize harmful ingredients. For example, a range of clean-claiming products may still use harsh ingredients, harmful preservatives and/or surfactants that are bad for aquatic life, they may even contain pesticides or have ingredients contaminated with carcinogenic material. Without a deep ingredient review, it’s impossible to substantiate the “clean” claim.

Unfortunately, this means that the term “clean” does not serve as a useful differentiator for shoppers, and as a result, clean-washed is the new green-washed.

If your goal is to purchase safer and more sustainable products, you can look for third-party certifications that ensure products are truly “clean”. Certifications that screen products for safety and sustainability include MADE SAFE Certification, Green Seal, and COSMOS.

Like “Clean”, “Natural” is not a regulated claim, which means companies can use it on products without following specific standards or definitions. Companies typically use this claim to denote that an ingredient or product is derived from a source from the earth – plants, animals, minerals, clays, etc.

What is often not considered when making a natural claim on an ingredient is how that ingredient is processed. Ingredients from the earth can undergo extensive processing that fundamentally impacts the ingredient. For example, essential oils can be extracted from plants utilizing harmful synthetic solvents, plant powders can be treated with carcinogenic ^[7] synthetic ethylene oxide for sterilization, and palm oil can be chemically processed and combined with synthetic ingredients to turn it into a completely new ingredient altogether like a cleansing surfactant in shampoo. So while these ingredients may have originated from natural sources, the end result is that they can contain or can be treated with synthetic ingredients, which may or may not be harmful, depending on the ingredient.

Eco and green claims are generally used to indicate that a product is made with sustainability in mind. These are common terms that prompted the FTC to create green guidance, but they are not defined by any agency or entity in the US, meaning they lack a standard definition of what it means to be eco or green.

“Eco” and “green” are typically used by companies who are asserting the product is more sustainable in some way. Because sustainability can encompass many different facets – carbon emissions, energy usage, human safety, environmental impact, water usage, and more – these claims could be related to anything eco.

It’s important to look for specifics on products making an eco or green claim. What makes the product green? Does the company have third-party certifications to back up their claims? With unregulated terms like “eco” and “green”, do your detective work to see if the product truly is more sustainable.

“Ocean Safe” and “Reef Friendly” are commonly used on sunscreen to indicate that they do not contain oxybenzone, an ingredient linked to coral reef bleaching and aquatic life harm ^[8] . Due to these issues, the ingredient was banned in Hawaii ^[9] . However, numerous other ingredients found in sunscreen are also linked to harming aquatic life including common sunscreen active ingredients octinoxate, nanomaterial zinc oxide, and octocrylene ^[10] . Additionally, dozens of inactive ingredients are linked to toxicity to aquatic life.

So, while an “ocean safe” or “reef friendly” claim might help you find a sunscreen that does not use oxybenzone, it does not guarantee that the ingredients are all safe for ocean life.

“Cruelty free” claims on product labels are not regulated by the FDA or other governmental agencies. While it may seem straightforward that products with cruelty-free claims mean that the products and their ingredients have not undergone animal testing, that’s not always the case. Cruelty-free claims can refer only to the finished product itself and may not include whether the company has tested individual ingredients on animals.

Additionally, sometimes a company who makes a cruelty-free claim may be owned by a parent company who conducts its own animal testing. So while the subsidiary company making the product may look cruelty-free, their parent company is actually testing on animals.

There are numerous third-party certifications that work to identify cruelty-free products. Make sure to research the scope of any certification to ensure their policies align with your values, in terms of the breadth of permitted animal testing. Some cruelty-free certifications include: PETA’s “Animal Test-Free” certification, Naturewatch Foundation Compassionate Shopping Guide, and Cruelty Free International’s Leaping Bunny program.

Each of these designations is designed toward consumers who want to buy products that don’t harm animals. But each one is slightly different. PETA Cruelty Free Bunny Ears symbol is different and less stringent than the Leaping Bunny certification. Both are intended to discern

products that are not tested on animals. Animal Cruelty Free goes another step further with requirements for the parent company to also be cruelty-free and accredited.

Cruelty free designations indicate products have not been tested on animals, whereas ‘vegan’ typically means that a product or ingredient is not made with or from animal-derived ingredients. The term “vegan” is not regulated. However, numerous third-party certification companies verify that products are vegan including: Certified Vegan, The Vegan Society, BeVeg certification and more.

Certain bioengineered foods in the United States are subject to labeling requirements. Personal care and cosmetics, however, are not subject to the same standards. This means that ingredients derived from or made with GMOs are not required to be labeled on personal care products.

Although it’s not required to disclose bioengineered ingredients on personal care products, some companies state that their products are non-GMO. While this may seem uncomplicated, the definition of bioengineered foods complicates whether ingredients are actually nonGMO.

Bioengineered foods are defined as those that “contain detectable genetic material that has been modified through certain lab techniques and cannot be created through conventional breeding or found in nature ^[11] .”

One of the problems with GMO labeling comes in with “detectable genetic material” in the definition. This caveat means that if the final product or ingredient is tested in the lab, typically using PCR, and there is no detectable GMO DNA, then the product can be considered GMO-free. This does not mean that GMOs were not used in the process. Refining or chemically or physically altering ingredients can make it so that GMO is not detectable in lab testing. In practice, some personal care product manufacturers use ingredients derived from GMOs, refine or alter them so that GMO DNA is not detectable, and then label them GMO-free, even though they are derived from GMOs.

Furthermore, some personal care product manufacturers genetically manipulate microorganisms to produce a substance, which is in turn used as an ingredient in products. While that ingredient is not GMO itself, it was derived from genetically manipulated microorganisms. In these instances, because the ingredient itself is not GMO, it could be used in a product and labeled as nonGMO, despite genetic engineering being used in the manufacturing process.

Third-party verifications can confirm that an ingredient does not consist of, contain, is not produced with and/or by genetic engineering. NonGMO Project Verification and Organic are two standards that confirm ingredients are not bioengineered.

Free-of is a term that has direct and specific FTC guidance ^[12] .

Below is the specific guidance which says:

(a) It is deceptive to misrepresent, directly or by implication, that a product, package, or service is free of, or does not contain or use, a substance. Such claims should be clearly and prominently qualified to the extent necessary to avoid deception.

(b) A truthful claim that a product, package, or service is free of, or does not contain or use, a substance may nevertheless be deceptive if:

(1) The product, package, or service contains or uses substances that pose the same or similar environmental risks as the substance that is not present; or

(2) The substance has not been associated with the product category.

(c) Depending on the context, a free-of or does-not-contain claim is appropriate even for a product, package, or service that contains or uses a trace amount of a substance if:

(1) The level of the specified substance is no more than that which would be found as an acknowledged trace contaminant or background level ^[47]  ;

(2) The substance's presence does not cause material harm that consumers typically associate with that substance; and

(3) The substance has not been added intentionally to the product.

Overall free-of claims are useful only as very specific indicators but not as a general method for telling if a product is made with green, clean or eco ingredients on the whole. Some brands have moved away from these call-outs because many chemicals that get changed out use a similarly harmful one in its place, and technically that practice is not permitted by the FTC guidance. Look for something that is free-of an entire class of chemicals as opposed to just one. In other words, it’s better to see a claim of Free-of PFAS than Free-of PFOA or PFOS, which are merely chemicals within the larger PFAS grouping.

Paraben-Free, which is common to sunscreens and other beauty products, indicates the omission of these preservatives however they may merely have been replaced with antimicrobials or other harsh chemicals instead.

Synthetic Fragrance-Free is another one to look out for. While it may be good for a product to avoid synthetic fragrance, for some people any fragrance can be loaded with allergens or other harmful ingredients. Fragrance is a term that can include hundreds of undisclosed ingredients. Fragrances are considered trade secrets which are protected from being made public in the US. Some companies use fragrance as a place to hide other non-scent related chemicals that may be harmful to humans or the environment. Avoiding synthetic fragrance is a good idea if you are sensitive to fragrance, but it is not a defined term and it will not mean the product has no fragrance or that it doesn’t contain other harmful chemicals.

Be careful of free-of claims and look at what else the product uses or if it has certifications to back up any ingredient claims in addition.