Katelyn McGruder
Associate Editor
Loyola University Chicago School of Law, JD 2026
“Clean Girl” makeup went viral on TikTok in 2024 following the usual pattern of micro trends. Along with the clean girl hashtag trending, social media influencers are making money off marketing products that allegedly create the “clean girl” look. Although influencers may be promoting little foundation, natural colors, and slick styles when marketing the clean look, the clean beauty market has grown significantly as consumers become more conscious of ingredient safety and environmental impact. This trend focuses on products free from potentially harmful ingredients, often marketed as natural, organic, or eco-friendly. The current regulatory scheme for clean and natural beauty fails to capture the goals of clean beauty.
Although the Federal Food, Drug, & Cosmetics Act requires cosmetics labels to include all ingredients in a product to be listed, a typical consumer will look over the complex words and be left no more informed on what is actually being applied to their skin. The word “clean,” highlighted in green on the front of the package is gaining the trust of a majority of consumers who aren’t chemists. There is often a misalignment between consumer expectations and regulatory standards. Consumers may have a broad or idealistic view of what “clean” and “natural” mean, while regulatory standards may be more limited or specific.
One of the major hurdles in the clean beauty sector is the lack of universal definitions for terms like “clean,” “natural,” and “non-toxic.” Regulatory bodies such as the Food and Drug Administration (FDA) have not standardized these terms, leading to ambiguity and inconsistency in their application. This ambiguity complicates compliance efforts for brands, as they must navigate diverse and sometimes conflicting standards. For example, a product labeled as “natural” in one country may not meet the criteria in another, making it difficult for companies to maintain consistent branding and marketing strategies.
Industry Standards versus Regulatory Guidelines
Several industry standards and certifications aim to provide clarity in the absence of universal regulatory definitions. Certifications like COSMOS and ECOCERT set criteria for organic and natural cosmetics, covering aspects such as ingredient sourcing, processing, and packaging. In the United States, the USDA Organic certification enforces strict guidelines on the use of synthetic ingredients and chemical processes, ensuring products labeled as organic meet specific standards. The proliferation of these certification bodies presents a challenge for brands seeking to obtain green certifications. Each body has different criteria for what constitutes “natural” or “organic,” leading to complexities in compliance. Additionally, obtaining these certifications can be costly and resource-intensive, requiring extensive documentation and adherence to stringent standards.
Recent regulatory shifts are reshaping the cosmetics landscape, with notable changes like the EU’s Regulation 2019/831, which restricts the use of endocrine-disrupting chemicals (EDCs), and Canada’s Cosmetics Regulations update, mandating the prohibition of microbeads in rinse-off products. EDCs are substances that interfere with the body’s hormone system. They can mimic, block, or alter the normal function of hormones, potentially leading to adverse health effects and are found in many everyday products, including plastics, pesticides, and personal care items. Microbeads, on the other hand, are tiny plastic particles often used in cosmetics and personal care products for exfoliation purposes. While not directly related to hormone disruption, they are considered environmental pollutants. The FDA’s new Modernization of Cosmetics Regulation Act (MoCRA) requires rigorous safety substantiation and transparent labeling. The European Union (EU), under Regulation EC No. 1223/2009, imposes stricter regulations, demanding proof for claims about product benefits and safety. Industry certifications and the push for governmental regulation are hopeful steps in the right direction towards obtaining the goals of a clean cosmetic industry.
The shift towards clean beauty presents both challenges and opportunities for the makeup industry. Brands must balance regulatory compliance with innovative product development to meet evolving consumer expectations. The cosmetics industry is needing a pivotal shift towards heightened regulation, which is crucial for ensuring consumer safety and sustainability. While the allure of “natural” ingredients persists among consumers and brands, it’s essential to recognize that some chemicals often offer significant advantages and are typically less resource-intensive, reducing water and labor demands. Moreover, “natural” does not always equate to safer. Many naturally derived ingredients lack the rigorous safety testing required for their synthetic counterparts, potentially leading to irritation and allergic reactions. As regulatory landscapes continue to evolve, it is crucial for companies to prioritize safety, transparency, and sustainability. By collaborating to develop clearer standards for clean beauty, industry stakeholders can promote transparency and drive innovation in safe and sustainable cosmetics.