The Risk of Application: Addressing the Use of Harmful and Hazardous Chemicals in Cosmetics
Tanya Cox, Rory Sullivan and Anna Hattam
In October 2025, Chronos Sustainability, in partnership with Clean Production Action’s (CPA) Investor Environmental Health Network (IEHN), ChemFORWARD and the Safer Chemistry Impact Fund held a workshop in London to raise investor awareness of harmful and hazardous chemical use in cosmetics and personal care products, and to discuss the role investors might play to reduce the risks associated with these products.
Context
The global cosmetics industry is valued at $450 billion. Consumer demand for so-called ‘Clean Beauty’ – products thought to be produced with fewer harmful ingredients and a lower environmental impact – is a growing trend within the industry. Despite this interest, regulatory gaps and limited ingredient transparency mean that harmful and hazardous chemicals are still present in many popular cosmetics marketed by consumer-facing brands.
For example, ChemFORWARD’s 2025 Beauty & Personal Care Ingredient Intelligence Report found that 24% of the ingredients in cosmetics remain uncharacterised - meaning that a full, independent chemical hazard assessment of human and environmental impacts has not been completed. This report also found a small but critical group of high-hazard chemicals continue to be used frequently across a broad range of products. These chemicals are classed as persistent, mobile and/or bioaccumulative in the environment; some have known endocrine (hormone) disrupting qualities and others are of emerging regulatory concern, such as PFASs. Specifically, the report highlighted three product categories that are of particular concern:
Lip Colour: This category, including products such as lipsticks and lip gloss, contains the greatest number of persistent and high-hazard ingredients, primarily due to the widespread use of synthetic organochlorine and organobromine colorants which are used – for example – to achieve popular deep red colours in these products. Lip sticks have prolonged contact with the lips, increasing the risk of exposure to and ingestion of these chemicals during use.
Moisturisers: Some moisturisers – formulated for long-lasting coverage – were shown to use higher-hazard emollients/functional ingredients such as cyclopentasiloxane (restricted in EU but present in products on the US market). The development and assessment of safer alternative ingredients in these products is a recommended priority to reduce consumer exposure.
Shampoos and Conditioners: These products rely heavily on surfactants. While many of these ingredients are considered safer/low-concern and have moderate to low human hazards, environmental impacts are drawn into focus because surfactants may exhibit aquatic toxicity given that they are washed directly into the wastewater systems.
Importantly, the report makes it clear that safer chemistry in beauty and personal care is achievable, presenting multiple examples of how companies have – through closing data gaps, eliminating chemicals of concern, and investing in innovation – achieved a variety of benefits including reduced costs, reduced risk of litigation and increased numbers of customers for these products.
The Investor Perspective
In our discussions with investors, several themes emerged:
Investors recognise that there is a clear case (in terms of reduced business risk and in terms of the potential opportunities) for company action to replace the use of these harmful and hazardous chemicals with commercially viable, safer chemistry alternatives.
Investors recognise that they can play a role in supporting and encouraging company action, and that this is in their financial interests as investors – as evidenced in the recently issued IEHN guidance for Safer Chemicals Management in consumer products.
In order to engage more investors, it will be necessary to:
Clearly explain that the use of harmful and hazardous chemicals in cosmetics is a public health issue, with the attendant risks of regulation and of litigation.
Provide greater clarity on the business case for action, and why taking action now is in companies’ best interests. It is also important to highlight opportunities and examples of where companies benefitted by proactively taking action.
Develop tools that allow investors to understand and to evaluate the level of exposure in their portfolios – which companies, and which products.
Describe the costs to companies of substituting chemicals of concern with safer chemicals. This needs to include information on the relative quality/effectiveness of these substitutes, and on the costs and feasibility of substitution.
Our Reflections
This workshop and a series of meetings we had with the industry and other stakeholders point to harmful and hazardous chemicals in cosmetics as important both from a public health perspective and from a nature/environmental perspective.
The producers of cosmetic products – because they are applied to the skin and are frequently ingested or absorbed into the blood – are potentially exposed to litigation risks and may face tougher regulation in the future (e.g. following trends seen with emerging PFAS regulation and legislative bans on known endocrine disrupters such as bisphenol-a (BPA)). Companies and investors therefore have an interest in taking action now to reduce these risks and to demonstrate the commercial benefits of taking a proactive approach.
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To discuss our work on chemicals please get in touch with: tanya.cox@chronossustainability.com
Photo credit: Nadiia Borovenko, iStock images
