Consumer Guide to the Compact for Safe Cosmetics
When companies sign the Compact for Safe Cosmetics, they are pledging not only to make safer products, but also to provide greater transparency to consumers about their products. But who defines what “safer” is? And how do we know they’re actually making good on their promise?
To help answer these and other questions related to implementing the Compact for Safe Cosmetics, we developed step-by-step instructions for companies who sign the Compact for Safe Cosmetics.
For more detailed information, read the full-length Compact Compliance Guide » (pdf)
There are five major steps for Compact compliance:
1. Global Compliance with the EU Cosmetics Directive
2. Ingredient Deck Inventory
3. Substantiate Ingredients and Impurities for Safety
4. Develop Substitution Plan
5. Practice Transparency and Public Reporting
1. Certify Global Compliance with the EU Cosmetics Directive
All companies who sign the Compact must be compliant with the formulation standards of the EU Cosmetics Directive. This means that as a minimum standard of safety, all of their products sold worldwide must be free of the over 1,100 toxic ingredients banned from personal care products by the EU.
The EU also instituted an ingredient naming standard. Toxic chemicals can sometimes hide in ingredient listings; for example, phthalates are a common component of the ingredient “fragrance.” The Compact requires that companies standardize their ingredient listings so that consumers know exactly what is in each product. The standard is based on INCI listings (International Nomenclature of Cosmetic Ingredients), and manufacturers’ ingredient lists must include individual components of all mixtures.
2. Ingredient Deck Inventory
Skin Deep is an online cosmetic safety database that provides safety information on over 7,000 ingredients used in nearly 25,000 products – a quarter of all products on the market. Product ingredients are cross-referenced against 50 toxicity databases from around the world. Companies – and consumers – can use Skin Deep to generate comprehensive reports detailing out any adverse health impacts linked to exposure to that chemical. Individual Compact signers are required to enter their products into Skin Deep, making safety information on their ingredients publicly available, within one year of signing the Compact. In addition, they must routinely enter information about reformulated products as well as new products.
Skin Deep is also a powerful research tool for companies. Within six months of signing the Compact, they must conduct an ingredient deck inventory to generate an initial assessment of known and suspected health hazards associated with each ingredient in their products – including potential impurities.
3. Substantiate Ingredients and Impurities for Safety
Without adequate toxicity data, there is no way to assess whether an ingredient is safe or not. Currently only 11% of the ingredients used in cosmetics have ever been tested for safety. The Compact for Safe Cosmetics asks that before a product is put on the market, reasonable proof of no harm should be established, by consulting peer-reviewed scientific publications and publicly available industry studies. This substantiation of safety must also take into account potential impurities, which can pose serious health risks, and other factors.
Ingredients for which safety cannot be adequately established must be marked as ingredients of concern. Companies must complete this process within three years of signing the Compact.
4. Develop a Substitution Plan
Once companies have analyzed their ingredients and all available data for health risks, they must develop a plan to replace ingredients of concern with safe alternatives. Compact signers must develop a plan that prioritizes those ingredients for substitution – and implement solutions – within three years of signing the Compact.
5. Practice Transparency and Public Reporting
One of the most important concepts of the Compact for Safe Cosmetics is transparency and public accountability. Companies who sign the Compact agree that consumers have a right to know which ingredients are used in their personal care products. By signing the Compact, companies agree to post a full list of their product ingredients – including components of fragrance and other mixtures – on their company Web site and in the Skin Deep database within two years of signing the Compact.
Part of this process goes back to the first step – standardizing ingredient names to INCI listings, following the international standard set by the EU. The Compact for Safe Cosmetics asks that other areas of the label be used for additional descriptive terms for ingredients.
Finally, it is important for each company to establish their own company policy on the use of chemicals as ingredients in their products. This policy must be developed and made publicly available – including on the company’s Web site and/or its annual report – within three years of signing the Compact.
