Increased investment in innovation and supply chain improvements could help to clarify ambiguous definitions and address regulatory gaps in the clean beauty sector, according to a report published by a collective made up of Sephora, Ulta Beauty, The Honest Company, Credo Beauty, Counter, Inolex, Dow and the Environmental Defense Fund.
The purpose of the 2025 Beauty Personal Care Ingredient report was to establish a unified analysis of safe ingredients across cosmetics, haircare and skincare. The collective — called the Know Better, Do Better (KBDB) Collaborative, established in 2023 in partnership with non-profit Chemforward — analysed 1.25 million ingredients across 48,000 US beauty products. It identified what it deems as “chemicals of concern”, according to a classification system established by KBDB that’s based on comprehensive toxicological assessments and validated through independent third-party evaluation and reporting.
Across its data set, 71.3 per cent of ingredients analysed were verified as “safe” or “low concern”, while 24 per cent were classed as “uncharacterised”, deemed by the report as containing common chemicals that are yet to be fully assessed under current regulation. (The report does not disclose details of the specific uncharacterised ingredients.) Meanwhile, 3.7 per cent of ingredients were found to be “high hazard”, defined by the report as having human and environmental impacts, with evaluated risks spanning carcinogenicity, skin irritation, mutagenicity, bioaccumulation and aquatic toxicity.
According to the report, its model of conducting ingredient audits, investing in chemical hazard assessments and phasing out high-hazard chemicals through its classification system has successfully led to increased ingredient safety and transparency by establishing comprehensive chemical hazard assessments for classifying ingredients as safe, and recommending safer ingredient swaps where possible.
The lack of a standardised definition for clean beauty presents a substantial risk to both consumer safety and brand credibility, the report reads, creating what it describes as a “fundamental paradox”, whereby consumer demand for safety drives the clean beauty market, but the “absence of clear, enforceable standards allows for varied interpretations across brands, retailers and consumers”.
Consumer demand for non-toxic ingredients continues to fuel market expansion: the global clean beauty market is expected to grow from $7.29 billion in 2024 to $20.51 billion by 2032. However, the absence of binding standards permits broad and inconsistent interpretations across the sector, and creates a challenge in pinpointing both its specific market share and growth.
Despite its popularity, clean beauty has remained a notoriously ambitious term. The US Food and Drug Administration (FDA) does not legally recognise it as a category, which leaves brands and retailers free to define it as they please, encouraging widespread inconsistencies in criteria. It often overlaps with environmental and social values such as sustainability, carbon neutrality, fair trade or cruelty-free practices. According to Neil Saunders, managing director of retail at Globaldata, confusion reigns around what clean beauty is because the term is very nebulous and unstandardised.
“Claims like vegan, cruelty-free, plant-based, or organic are all more obvious to consumers and are better understood by them. Clean beauty is still an important signifier, but consumers usually only accept it when they have looked into more details about the product,” Saunders says.
The report’s mission is to provide a data-driven approach to enforcing substantiated safer ingredient and product claims, but how exactly it can be enforced and the regulatory involvement required still presents challenges. In the US, the burden of safety is a brand’s responsibility, and progress is slow. Many products meet the market before the FDA can formally assess them.
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Despite retailers like Credo Beauty being committed to becoming authorities of the clean beauty sector with KBDB, Saunders believes the overall onus of responsibility remains on brands for widespread change. “Clean also has to be set in the context of the benefits it brings: is the product gentle on skin? Is it less likely to cause reactions? Is it better for the environment?” he says.
What’s not safe?
Key findings spotlight areas for improvement, specifically across lip, skin and hair products. Within the lip colour category, it contains the greatest number of “high-hazard ingredients”, due to the use of synthetic organochlorine and organobromine colourants, which help to create vivid pink and red hues. It cites a potential risk of “reproductive, neurological, immunological, endocrine, behavioral, and carcinogenic effects in humans and/or wildlife”, when both ingredients have prolonged contact with the lips and potential ingestion during use.
Some moisturisers were shown to use a higher-hazard emollient called cyclopentasiloxane, a silicone that improves the dry time of cosmetics, but is bioaccumulative and under assessment by the EU for its potential as a persistent organic pollutant.
Across shampoos and conditioners, the predominant ingredients throughout are surfactants, which is classified as “safer/low concern”, but there is concern for how they “may exhibit aquatic toxicity as they are washed directly into the wastewater system”.
The report also warns of the issue with “free of” product labelling, which relies on the US’s Restricted Substances Lists (RSLs), which has significant limitations as “a brand could remove a known hazardous chemical to comply with an RSL but replace it with a similar uncharacterised one”. It goes on to say: “This practice can lead to ‘regrettable substitutions’, where a product is ‘RSL compliant’ but contains an equally or even more hazardous chemical that isn’t on the list.” Instead, KBDB recommends that “verified safer” labels offer a clearer safety indicator to consumers.
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Ingredients assessed in 2024, following a toxicology report, have been moved into the chemicals of concern category: chlorphenesin, a preservative and antimicrobial agent; anisaldehyde, a fragrance ingredient used in perfumes; and D&C Red No 28, a colourant found in lip colour.
Retailer responsibility
While Saunders recognises that it remains the responsibility of brands to communicate product and ingredient safety improvements or potential risks, this particular effort to encourage the use of safer chemistry across the industry is being lead by retailers, for both mass sellers like Sephora and Ulta, but also dedicated clean-specific distributors like Credo Beauty and newly relaunched Counter.
Credo Beauty launched in 2014, defining clean as thoroughly examining ingredients and avoiding potentially harmful or hazardous chemicals. This strategy has since evolved, says Christina Ross, head of science and impact at the retailer, who has been a member of the KBDB coalition since its inception.
“Over time, it became clear that the best practice for clean beauty is one that includes the full impact of a product, from how ingredients are sourced to the way packaging affects the environment, and how the company behind it operates,” she says. Credo Beauty now treats clean as an ecosystem rather than an ingredients checklist.
According to Ross, people are realising that the impact of their products is not confined to the formula alone: “They are interested in learning more about supply chains, labour practices, packaging and the broader behaviour of the company.”
KBDB also calls on beauty brands to collaborate if they want to accelerate their progress in the clean beauty sector. It’s the coalition’s belief that proactive ingredient assessments are key to ensuring competitiveness, increased ingredient transparency and safer chemistry.
“We’ve made great strides in measuring the transition to clean beauty for all, yet the journey is far from over,” says Chemforward co-founder and executive director Stacy Glass. “Our 2025 report highlights that the next frontier lies in accelerating the understanding of and addressing uncharacterised ingredients to build a truly safer beauty and personal care industry.”
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