Post by BCPP Director of Program & Policy, Janet Nudelman
Smart Companies Practice Ingredient Transparency for Health-Conscious Customers
Over the past decade, in response to consumer and worker demands for ingredient transparency, we’ve seen more and more cosmetic companies – large and small – adopt fragrance ingredient disclosure policies.
For years, many dozens of small to medium size “safe cosmetics companies” have been voluntarily disclosing their fragrance ingredients including California Baby, Intelligent Nutrients, Aubrey Organics, EO Products, Herban Lifestyle, Honeybee Gardens, Iredale Mineral Cosmetics Juice Beauty, Osea International, ThinkBaby, True Botanicals, W.S. Badger Company, and Beautycounter.
Notably, in February 2017, Unilever became the first multinational to announce it would voluntarily disclose fragrance ingredients in their entire U.S. and EU portfolio of personal care and cleaning products down to 100 ppm (0.01%). We like that Unilever has provided multiple ways for consumers to access fragrance ingredient information: through their brand websites or by scanning a QR code that appears on the product label, both of which link to the SmartLabel™ program. Procter & Gamble followed suit six months later announcing an almost identical fragrance ingredient disclosure policy. An important aspect of P&G’s policy is that they include a “red list” of fragrance ingredients on their website they will not to use in their products.
Unilever is the 2nd largest cosmetic company in the world and P&G is the largest consumer products company in the world, which suggests that companies are finally responding to calls from consumers and workers for product ingredient transparency. Companies cite that disclosing in-depth product and ingredient information for home, beauty, and personal care shoppers builds brand trust. Providing full product information helps shoppers to assess product ingredients based on health concerns and make informed purchasing decisions.
Unilever SmartLabel™ updates are due to be complete by the end of 2018 and they have publicly reported they are on track to meet that goal. By 2019, P&G pledged to begin disclosing the “secret” fragrance ingredients in over 2000 of its beauty, fabric, home and feminine hygiene products in the U.S. and Canada. According to P&G, after they meet their initial 2019 goal, they will expand into other product categories and into the other 180 countries where they do business.
Johnson & Johnson joins the race
The newest multinational cosmetics company to join the fragrance ingredient disclosure race to the top is Johnson & Johnson, the world’s 8th largest cosmetic company. On July 5th, J&J announced it would provide on-line disclosure of fragrance ingredients present in their baby products at concentrations of 100 ppm (0.01 percent) or greater. The transparency effort was rolled out as part of a relaunch of J&J’s baby care line on August 1, 2018, less than a month after its fragrance ingredient disclosure policy was publicly announced.
J&J also wins points for the extensive global scope of its fragrance disclosure initiative – compared to its competitors – which covers J&J products sold in the US, China, Canada, and India. We also like the fact that J&J discloses fragrance ingredients online through product web pages, given that’s where many consumers go to find ingredient information, in addition to the SmartLabel™ program. Like P&G, J&J also discloses online the fragrance palette it uses for its baby products. In addition, all three of these fragrance ingredient disclosure leaders are voluntarily labeling fragrance allergens according to EU standards.
On the flip side, however, J&J needs to catch up to Unilever and P&G by committing to disclose fragrance ingredients for its adult product lines as well. And all three of these multinational giants should announce a timeline and benchmarks for expanding their fragrance ingredient disclosure initiatives to the rest of the global markets where they do business.
Kudos to Unilever, Procter & Gamble, and Johnson & Johnson for paving the way for fragrance ingredient disclosure in personal care and beauty products. Despite their massive size, and the considerable number of brands these three companies represent, their fragrance disclosure policies include specifics regarding where, how, and when they will begin disclosing fragrance ingredients.
L’Oréal’s vague and uninspired fragrance announcement
In contrast, it’s hard to get excited about L’Oréal’s announcement that it too would begin disclosing fragrance ingredients given its lack of specificity.
L’Oréal, the world’s largest cosmetic company, announced in June 2018 that it would begin disclosing the secret fragrance ingredients in its beauty products. Said a L’Oréal spokesperson in a June 7, 2018 article in Chemical Watch:
We would like to take this opportunity to state our future goal of communicating to a larger extent the composition of our perfumes in all our products, in a way that meets the expectations of our consumers and ensures their safety while at the same time fully respecting the know-how of our perfume creators and protecting us from the major risks of fine fragrance counterfeiting.
Unlike its competitors, and true to form for L’Oréal, the multinational giant’s announcement lacked specifics as to where, when, and how that disclosure would take place. While it’s great to hear major multinationals using the word ‘transparency,’ we’re not holding our breath for full fragrance ingredient transparency any time soon given L’Oréal’s lengthy track record of vague and unfulfilled promises.
A decade of advocacy
L’Oréal’s fragrance disclosure announcement comes after a decade of advocacy by BCPP and our Campaign for Safe Cosmetics urging L’Oréal to adopt a company-wide fragrance ingredient disclosure policy.
In July 2017, representatives from BCPP’s Campaign for Safe Cosmetics and U.S. PIRG visited the L’Oréal headquarters in New York to deliver over 150,000 petition signatures gathered by our coalitions as well as MomsRising, Credo and Safer Chemicals, Healthy Families demanding the company remove dangerous chemicals and fully disclose fragrance chemicals. Yet despite the tens of thousands of letters and the hundreds of thousands of petition signatures it has received over the years supporting these demands, L’Oréal continues to lag behind its competitors.
Secret fragrance ingredients & why we need labeling
The terms “fragrance” or “parfum” on the label of a shampoo, body lotion, deodorant, lipstick or fine fragrance can hide dozens – even hundreds – of chemicals that companies are not required to disclose. This is a problem for consumers because a large and growing body of scientific evidence has linked common fragrance chemicals to cancer, endocrine disruption, asthma and other health concerns as well as water and air pollution.
Fragrance is big business in the U.S. and abroad. In 2017, the global fragrance market was nearly $70 billion and by 2024, the global fragrance market is estimated to be worth about 92 billion U.S. dollars. (Statista) However, despite the vast and growing size of the fragrance industry, there’s no one minding the store. The fragrance industry is entirely self-regulated with no federal or state guidelines of any kind dictating the safety of fragrance chemicals nor the disclosure of fragrance ingredients to manufacturers, regulatory agencies or consumers. Which is why more and more environmental health organizations like ours and more and more consumers are calling for full fragrance ingredient disclosure – so they can make safer, more informed purchases.
Calling for transparency we can believe in
In addition to L’Oréal’s vagueness on the new fragrance ingredient policy, the company has a disappointing track record of not making good on its promises. That’s why the vague nature of their most recent announcement generated some heartache for us here at the Campaign for Safe Cosmetics.
We wish we could applaud L’Oréal for taking this step toward fragrance ingredient disclosure, but first we need more information because, ironically, their fragrance transparency policy lacks transparency. To win the public’s trust, L’Oréal should disclose:
- Which L’Oréal products and brands will be covered by this announcement;
- What they plan to disclose;
- Where disclosure will take place;
- When L’Oréal fragrance ingredient disclosure will take place;
- And, most critical of all – how the public will be informed about their progress.
We will hold our applause until we hear more and invite you to do the same.
Raise the bar: voluntary fragrance ingredient disclosure initiatives
In an ideal world, our federal law would require full ingredient transparency—including fragrance chemicals — in personal care, cosmetic and cleaning products, so that everyone could assess product information to bring safer products into their homes and their workplaces.
Instead, lobbying by industry trade associations and big multinational cosmetic companies has consistently blocked efforts to federally require full ingredient disclosure in cleaning products and personal care products. These trade associations have not kept pace with industry transparency best practices and instead cater to their membership’s lowest common denominator.
While consumers and workers wait for congress to get around to adopting meaningful, federal cosmetic safety legislation, we call on the $84 billion cosmetic industry to do a better job of self-regulating the safety of the fragrance chemicals they use. Disclosure is the first step to getting there. BCPP and our Campaign for Safe Cosmetics challenge cosmetic companies to meet our fragrance ingredient challenge.
This is what full fragrance ingredient disclosure looks like:
- Companies disclosure all intentionally added fragrance ingredients, regardless of concentration, to consumers.
- We know fragrance chemicals can be present in a fragrance at much lower levels than 100 ppm, the current industry “high bar” for fragrance disclosure. This is especially important for endocrine-disrupting compounds that can harm human health at extremely low levels of exposure.
- Product manufacturers require full fragrance ingredient disclosure – and safety data – from their fragrance suppliers.
- Disclosure occurs throughout a company’s entire product portfolio, including both retail products, professional-use products, and the global market. Fragrance ingredients are listed on brand websites.
- Online retail sites such as Drugstore.com and Amazon.com disclose all fragrance ingredients for the company’s products sold there.
- Manufacturers utilize a restricted substances list (RSL) of fragrance chemicals of concern (aka as a “red list” or “do not use”) list or provide that RSL to their fragrance supplier or independent perfumer to ensure that the chemicals used to formulate their fragrances are safe for human health.