You’ve all seen “The Dirty Dozen” and “The Toxic Twenty” lists of ingredients deemed unsuitable for use in cosmetic products by Environmental Working Group (“EWG”). Articles such as The New York Times recent “The Dirt On Clean Beauty” and Goop’s “What Is Clean Beauty And Why It’s so Important” offer differing perspectives on the topic.

The marketing war rages on between organizations such as Environmental Working Group, private companies touting their own definitions of Clean Beauty and mainstream personal care brands and an increasingly skeptical press leaving consumers confused. What Is Clean Beauty? The question reminds me of the classic Saturday Night Live skit with Steve Martin “What The Hell Is That?”

Clean Beauty can be most simply defined as cosmetic products that do not contain specific ingredients. Most Clean Beauty Standards such as Clean At Sephora, Credo Clean Standard and EWG have pretty much the same ingredients on their prohibited lists:

Preservatives: Parabens, Formaldehydes, Formaldehyde-Releasing Agents (DMDM Hydantoin, Diazolidinyl Urea, Quaternium-15), Methylchloroisothiazolinone, Methylisothiazolinone, Triclosan, Triclocarban

Surfactants: Sulfates, Ethanolamines (DEA/ETA/MEA/TEA)

Miscellaneous: Phthalates, Hydroquinone, Coal Tar, Butylated Hydroxytoluene, Butylated Hydroxyanisole, Perfluorinated Compounds, Petrolatum, Paraffin, Resorcinol, Toluene, Aluminum Powder, Chemical Sunscreens, Mercury

For proponents of Clean Beauty these ingredients are deemed harmful to human health or the environment. For opponents of Clean Beauty the exclusion of these ingredients leads to cosmetic products that are less safe, particularly when it comes to “The Dirty List” preservatives, parabens in particular.

It is important to note that some of the ingredients on “The Dirty Lists” are also banned or are only allowed under restricted use in cosmetic products by the FDA, such as Hydroquinone and Mercury compounds (Perfluorinated compounds are currently under consideration). But, most of these Dirty List ingredients are allowed by the FDA to be used in cosmetic products, although some may be banned or restricted in other jurisdictions such as the European Union.

Is it possible to create Clean Beauty products that are safe? Yes, absolutely. I have formulated over 400 products without ever, or rarely, using any of the ingredients on the various “The Dirty Lists” and have never had a product recalled for contamination or safety issues as have countless other Clean Beauty cosmetic chemists. The new law Modification of Cosmetics Regulation Act (2022) requiring that all cosmetic products conduct Safety Substantiation tests will resolve any conflict on product safety for all cosmetic products.

if Clean Beauty products can be formulated that are safe, what is the controversy really about? The answer is: “Unfair” Competitive Advantage.

In business, Competitive Advantage, often called Unfair Competitive Advantage, is when a company has a unique competitive position that cannot be matched by its competitors allowing the company to outperform its competition.

To understand Clean Beauty’s Unfair Competitive Advantage let’s take a look at two virtually identical products:

Clean Beauty Compliant

Water, Niacinamide, Pentylene Glycol, Glycine Betaine (Beta Vulgaris) Beet Sugar Extract, Saccharide Isomerate, Zinc PCA, Sodium Hyaluronate, Glycyrrhiza Glabra (Licorice) Root Extract, Centella Asiatica (Gotu Kola) Extract, Camellia Sinensis (Green Tea) Extract, Gluconolactone, Phenoxyethanol, Sodium Benzoate, Ethylhexylglycerin

Clean Beauty Non-Compliant

Water, Niacinamide, Pentylene Glycol, Glycine Betaine (Beta Vulgaris) Beet Sugar Extract, Saccharide Isomerate, Zinc PCA, Sodium Hyaluronate, Glycyrrhiza Glabra (Licorice) Root Extract, Centella Asiatica (Gotu Kola) Extract, Camellia Sinensis (Green Tea) Extract, Methylparaben, Ethylparaben, Propylparaben, Butylparaben

From an end-use consumer’s perspective, these two products contain the same functional ingredients and will perform exactly the same in a blind product comparison test. The only difference is the use of preservatives allowed in Clean Beauty Standards in the Compliant version and parabens in the Non-Compliant version.

In the Clean Beauty Compliant version, one can apply for and get certifications from organizations such as EWG, CleanCert, Made Safe or have their products sold as Clean At Sephora, Credo Clean and in the Clean Beauty aisles of major retailers including Target and specialty retailers such as The Detox Market. The Non-Compliant version could not be sold in any of these distribution channels.

The Clean Beauty version can highlight in its marketing that it is “Free-From” any ingredients on the various Dirty Lists and prominently display its CleanCert or EWG seal on its product packaging. Opponents of Clean Beauty decry this as Fear Marketing and there certainly is validity to that argument. “Free-From” advertising is prohibited in the European Union for any ingredient that is approved for use in cosmetics, but not so in the United States. The US just passed the Modification of Cosmetics Regulation Act at the end of 2022 and did not prohibit Free-From marketing. Regardless, it is marketing malpractice to focus on what ingredients your product does not contain as opposed to the positive attributes of your product.

Clean Beauty’s niche market segmentation confers to Clean Beauty brands an Unfair Competitive Advantage over products that are non-compliant in access to specialty distribution channels, visibility, product placement and consumer mindshare. Clean Beauty allows brands to compete against a smaller set of competitors and be more easily found by consumers in the ever expanding universe of cosmetic products on the market. But, Clean Beauty certification alone is not sufficient for a brand to succeed. The product needs to be safe, effective and well-formulated for consumers to repeat purchase.

Clean Beauty is as much about what ingredients are not included in a product as it is about what ingredients are included and sustainability. In fact, the controversy about Clean Beauty is not so much about ingredients or product safety as it is about Unfair Competitive Advantage, market segmentation, specialty distribution channels, market share and consumer mindshare.

In the end, consumers choose cosmetic products that align with their values, they feel comfortable using, are safe and effective. With Clean Beauty sales now comprising 30% of cosmetic product sales in the US, it’s pretty clear that a large segment of consumers are choosing Clean Beauty. Now, if they only knew “What The Hell Is It”