Raise your hand if words like natural, organic, clean, and green in the beauty industry confuse the heck out of you. [Raises hand].
Now keep your hand raised if you’ve purchased products anyway, thinking these words mean the same thing or must denote high quality. [Keeps hand raised].
Unfortunately, understanding what these words mean is becoming incredibly important for consumers. It is projected that this year, the natural and organic personal care market will be valued at a whopping 13.2 billion dollars. Yes, you read that right. Thus, it’s safe to say that buzzwords like natural, organic, clean, and green aren’t going away anytime soon. And, despite how ubiquitous they are, the misconceptions about these terms persist.
Wait, these don’t words mean the same thing?!
Nope. From a marketing standpoint, these terms do tend to get lumped together, but in actuality, they have distinct meanings.
Well, then why do companies use these terms if they are so confusing?
Because they can. Despite what you may think, the regulation of the beauty industry is incredibly minimal in the United States. By “regulation,” I am referring to the extent to which the government directs the activities of the companies that create, handle or sell beauty products in interstate commerce. Lax regulation means that such companies do not have as much accountability as do their counterparts in, say, the EU or Canada where the regulation of beauty is more stringent.
While none of this implies that all brands are evil and out to dupe to people and the system, this regulatory background is important to help you understand why words like natural, organic, clean, and green matter to you as a consumer.
Okay, so tell me more about this “regulation” stuff.
Before I dive in, I must note that what I am saying in no way constitutes legal advice or creates an attorney-client relationship. Rather, my focus here is purely informational.
In the U.S., The Food & Drug Administration (“FDA”) has the primary federal authority to regulate the cosmetic and personal care industry. The FDA does this by enforcing specific federal laws (e.g., the Federal Food Drug & Cosmetic Act (“FD&CA”)), and regulations that anyone in the business of creating and/or selling beauty products must comply with. Even where one ingredient in the product or its packaging moves through a U.S. state or territory, it would fall within the FDA’s purview. Unfortunately, however, the FDA does not approve cosmetics before they enter the market. Rather, if the FDA has reason to believe that cosmetics that are already sold are “mislabelled” or “misbranded” (terms defined in the FD&CA), the FDA has the power to issue warnings and even recalls for every entity involved in the handling of that product from production through distribution.
Additionally, the USDA via the National Organic Program (“NOP”) regulations specifically govern “organic” beauty and personal care products. With regard to the USDA’s enforcement power, The Agricultural Marketing Service notes that companies who are found to use fraudulent labels are subject to fines. In recent years, there has been an increasing worry about USDA label fraud, and organizations like the Organic Trade Association (“OTA”) have been advocating to help address these concerns.
Of course, this is a very simplified explanation of a nuanced area of law and regulation. Without getting into the technicalities of law versus regulation and federalism, I’ll just note that in the U.S., other federal agencies and state laws and regulations also influence the beauty industry to some extent.
Are you still awake? This stuff is dry, I know. So, if you take away anything from this section, just remember that regulation matters and influences the meanings of some (but not all) of the various beauty buzzwords.
Um, weren’t you going to tell me what natural, organic, clean and green mean?
Yes indeed. I was just getting there! Here’s what you need to know:
This word is everywhere, from drug stores to high-end beauty counters, and is perhaps the most misleading term in the industry right now. Colloquially, a “natural” product is usually one that claims to have plant-based or naturally-derived ingredients. Yet, the federal laws or regulations noted above do not define “natural” in the context of personal care products. Indeed, products or companies that call themselves “natural” may very well have some naturally-based ingredients. However, there is simply no government-backed accountability structure to ensure whether these “natural” products are what they claim to be.
Unlike “natural” products, and as noted above, “organic” products are subject to federal regulation to some extent. Notably, the USDA, and not the FDA, has authority over the term “organic.” Per the USDA NOP regs, the term “organic” essentially means that either individual ingredients or a product as a whole is free of chemical substances and processes such as GMOs, fertilizers, antibiotics, etc. The NOP regs have criteria to certify that the agricultural ingredients in a product have been produced under conditions that would meet the USDA definition of organic. The regs also include labeling standards based on the percentage of organic ingredients in a product. This is why on some ingredient labels, you won’t see the “USDA Certified Organic” symbol (which denotes 95-100% organic ingredients), but you may see asterisks with a note that says a specific ingredient is “certified organic.” For more information about labeling requirements as well as the role of organic certification agencies that work with the USDA NOP, head over to the OTA website.
While the FDA and other agencies do have safety requirements for products, the term “clean” itself is not defined in any federal statute or regulation, and thereby not subject to oversight from the feds. The term “clean” is commonly used by companies that strive to ensure their ingredients have low to no health toxicity, i.e., allergens, links to cancer, hormone disruption, etc. They may not necessarily be “natural” (as in, plant-derived) or “organic” (as in, USDA-certified), but their main goal is safety for consumers. Examples of potentially toxic ingredients include parabens, phthalates, and formaldehyde. Additionally, there is also a reasonable basis to believe that the generic-sounding ingredient “fragrance” or “parfum” is also potentially harmful because companies are not required by the FDA to disclose exactly what is used to make the fragrance.
This word refers to goods and companies that are committed to limiting environmental damage and reducing carbon footprints. So, I’m talking ingredients, production processes, packaging – any or all of the aspects of bringing a product to market. Many green companies use recycled or biodegradable packaging or sustainable production practices, for example. With regard to the regulation of green beauty companies and goods, the FDA has some oversight for packaging, but only in the form of federal “guidance” or “guidelines.” Unfortunately, guidance/guidelines do not have the full force of law or regulation. As a result, over the years, there have been concerns with corporate greenwashing in beauty where companies will say they are green, but may actually be engaging in practices that are not so eco-friendly.
Can a brand fall into some of these categories, but not others?
Absolutely. For example, an “organic” product isn’t “green” if the company doesn’t engage in sustainable farming practices. Similarly, a product can be both “clean” and “organic” if it uses non-toxic ingredients that are also USDA certified. Moreover, even within brands, some specific products may be cleaner or greener or contain more organic ingredients than others.
How can I be sure about the products that I use?
Given the limited regulation of the beauty industry in the U.S., educating yourself is crucial. While it’s never a good practice to blindly believe everything that we read on the internet, it is still our responsibility to be more discerning as consumers. So, do your homework. Read labels. Use apps. Research each product and company to the best of your ability. Connect with knowledgeable bloggers and professionals.
For example, to understand if a product is all or mostly “natural,” I read the order of ingredients on the label. The FDA’s cosmetic labeling regulations generally require that ingredients should be labeled in “descending order of predominance.” As I have previously discussed this in the context of curly hair products, this means that, typically, ingredients that are among the top five in the label are those which are present in higher quantities. So, if having natural ingredients matters to you, I would identify products whose ingredient lists contain natural ingredients higher up and synthetic ingredients lower down.
With regard to how “clean” a product is, just because a product states it is paraben and phthalate free on the packaging does not necessarily mean that it is completely non-toxic. So, if safety is something you are concerned about, also read labels carefully. And, if you are confused by labels, there are great apps out there to help you, like ThinkDirty and Healthy Living by EWG. They allow you to search products for ingredient breakdowns with regard to toxicity levels and possible health impacts. As long as you read the apps’ ingredient breakdowns carefully, they can be great resources.
The bottom line?
That’s entirely up to us as consumers. Understanding terms like natural, organic, clean, and green has helped me discern what I value in my beauty and personal care products. While I don’t know if I will exclusively use products that are 100% “organic” or “natural”, I do know that I am shifting my consumer power to support brands that value transparency in marketing, using ingredients that are safe for animals, people and the environment, and engaging ethical labor and testing practices.
That being said, I sincerely hope that this post helps you demystify these important buzzwords and make important choices about your products.
So, what is your bottom line when it comes to beauty? Let me know in the comments!
FTC: There are no affiliate links on this page. This past is based on my personal opinions. All outbound links are purely informational.