Are You Paying for Harm?
The Troubling Truth About Skincare Regulation.
In the skin care landscape, the European Union (EU) has been seen as the flag-bearer of consumer safety for a long time.
Yet, there is a disturbing truth that continues to linger: the glacial speed at which harmful ingredients in skincare products are prohibited or restricted. This persistent issue throws into question the skincare industry's commitment to the well-being of its consumers, exposing its preference for profit over people1.
While it's easy to hide behind the complexity of the regulatory process and the need for exhaustive scientific research as reasons for the slow introduction of new regulations, this doesn't mitigate the grim fact that consumers are left exposed to potentially harmful substances for extended periods. This is particularly disconcerting given the direct application of these skincare products to our skin and the potentially serious health implications this may carry1.
Take, for example, the case of siloxanes (a group of silicones, widely used in skincare). These chemicals, namely D4, D5, and D6, have been identified as environmentally persistent, bioaccumulative, and toxic.
Despite their widespread use in high volumes, it wasn't until April 2021 that the European Chemicals Agency (ECHA) recommended tight regulation of these substances2. Even then, some uses of these siloxanes, common ingredients in personal care and cleaning items, remain in commercial applications2.
The industry's reaction to this recommendation? A dismissal of the need for further regulation, arguing that existing regulations already covered most uses and emissions of these chemicals2. The apparent disregard for consumer safety exhibited by the skincare industry is a stark manifestation of its predilection for privileging economic gain over the health and well-being of its customers.
Fast forward to 2023 and beyond, a plethora of harmful ingredients remain on the chopping block, awaiting their inevitable, yet inexplicably delayed, ban or restriction. The list includes known skin irritants and allergens like kojic acid and nano versions of copper, platinum, and gold, all of which are only expected to be banned by 2022-23. The potential endocrine disruptor 4-methylbenzylidene camphor (4MBC) faces a ban no sooner than 2023-241.
And the siloxanes? D5 and D6 in leave-on cosmetics are not expected to be banned until a shocking 2027, with D6 in wash-off cosmetics only slightly ahead with a ban expected in 20241.
Equally concerning are the upcoming restrictions.
Homosalate, a UV filter, is deemed safe at a concentration of 0.5%, but only faces restriction in 2023-24. Products containing formaldehyde-releasing preservatives, a known allergen and potential carcinogen, will only require a warning label if the concentration of formaldehyde exceeds 0.001%, and even this requirement won't come into effect until 2024 at the earliest1.
In an industry where trust is of the utmost importance, it's high time we shed light on these disconcerting practices and demand more from our skincare manufacturers. The approach needs to shift from reactive regulation to proactive prevention, prioritizing safety over all else. In this pursuit, transparency is key. Only by being completely open about the ingredients we use, their origins, their potential benefits, and risks can we empower our customers to make truly informed decisions about their skincare choices, ensuring their safety and peace of mind.
At NOAGE, we're committed to doing just that. We've adopted the TOTAL TRANSPARENT principle, providing complete clarity about the ingredients we use and their potential effects. But more than that, we strive to go above and beyond, not just complying with current regulations, but actively setting new standards for safety and transparency. We believe in a skincare industry that not only enhances your natural beauty but also prioritizes your well-being. We meticulously scrutinize every ingredient we use, ensuring they are safe, beneficial, and environmentally responsible. We are transparent about our products, providing clear labeling and full disclosure of ingredients, so you can be confident and informed in your skincare choices.
However, we cannot do it alone. We need your help to drive the change we all want to see. We urge you to demand the same level of transparency and commitment to safety from all skincare companies. After all, your health, your well-being, and our environment depend on it. Together, we can redefine the skincare industry and create a healthier, safer world for all of us.
Upcoming bans:
| Ingredient | Deadline for Placing on the Market | Deadline for Making Available on the Market |
|---|---|---|
| Kojic Acid | Expected 2022-23 | Expected 2022-23 |
| Nano Copper, Nano Platinum, Nano Gold | Expected 2022-23 | Expected 2022-23 |
| Nano Hydroxyapatite | Expected 2022-23 | Expected 2022-23 |
| Prostaglandins | Expected 2022-23 | Expected 2022-23 |
| 4-Methylbenzylidene Camphor (4MBC) | Expected 2023-24 | Expected 2023-24 |
| D5, D6 in Leave-On Cosmetics | Expected 2027 | Expected 2027 |
| D6 in Wash-Off Cosmetics | Expected 2024 | Expected 2024 |
| Microplastics in Wash-Off Cosmetics | Expected Q1 2027 | Expected Q1 2027 |
| Microplastics in Leave-On Cosmetics | Expected Q1 2029 | Expected Q1 2029 |
Upcoming restrictions:
| Ingredient | Restrictions | Deadline for Placing on the Market | Deadline for Making Available on the Market |
|---|---|---|---|
| Homosalate (UV filter) | SCCS concluded that the ingredient is safe at a concentration of 0.5% | Expected 2023-24 | Expected 2023-24 |
| Formaldehyde releasing preservatives | All finished products containing substances in Annex V and which release formaldehyde must be labelled with the warning ‘contains formaldehyde’ where the concentration of formaldehyde in the finished product exceeds 0.001% | Expected 2024 | Expected 2026 |
| Extra fragrance allergens | Labelling of approx. 60 new allergens. A Working Document and draft Annex III entry to the EU Cosmetics Regulation have been drafted by the Commission. The intention is to require the on-pack labelling of the additional fragrance allergens if they exceed the relevant thresholds. The last draft proposed transition periods of three years for placing on the market and five years for withdrawing non-compliant products from the market. | Expected 2025 | Expected 2027 |
Sources:
1. https://news.ceway.eu/upcoming-eu-cosmetic-ingredient-bans-and-restrictions-for-2023-and-beyond/
2. https://cen.acs.org/policy/chemical-regulation/Tight-EU-regulation-three-siloxanes/99/web/2021/04