Late last year, a number of multi-national cosmetic companies came together to publish their findings from developing and applying a new method to assess the environmental impacts of a shampoo. Companies involved included L’Oreal, LVMH, Unilever, Procter & Gamble, Estee Lauder and Chanel.
Quantifying the overall environmental impact of a product is complex. Environmental impacts can arise during manufacture, transport, use and disposal. Identifying and measuring the impacts at each life stage can be very resource-intensive, and as a result these studies are not commonly performed.
In this study, a representative shampoo was assessed using a method based on guidance from the European Commission Environmental Footprint project. The assessment found that the most significant impacts for the shampoo were in the areas of climate change, depletion of water resources, depletion of fossil fuels, and freshwater ecotoxicity.
Based on the method used, contributions to climate change and the depletion of water resources mainly came from the use of hot water for showering. These impacts can be reduced by encouraging the user of the shampoo to take shorter showers and use water at a lower temperature.
The main uses of fossil fuels were in heating hot water for showering, in transport vehicles, and in the production of certain ingredients. For the representative shampoo formulation that was used in this assessment, the production of sodium laureth sulfate had the most impact.
Freshwater ecotoxicity was found to be a problem when the shampoo was washed down the drain. This was the biggest end-of-life impact of the shampoo; bigger than the environmental impact of the packaging after use.
The study also highlighted a number of limitations in using this sort of assessment more broadly. In particular, the authors noted that there was a lack of information for many chemicals and packaging materials. This made it difficult to accurately assess their impacts.
Rating: Not great
- Packaging is easy to recycle
- Many ingredients are readily biodegradable
- Main ingredient is not readily biodegradable
- Multiple ingredients are very toxic to aquatic life
- Contains EDTA
Olaplex is an American hair care company, which was launched in 2014. Their signature products focus on repairing hair damage.
Aside from water, the main ingredient in their No. 3 Hair Protector – and most of the other Olaplex products – is bis-aminopropyl diglycol dimaleate. (See a great explanation of how this chemistry works here). This chemical is not readily biodegradable. Some biodegradation has been observed under test conditions, but without further information it is impossible to know if this suggests that this chemical will eventually ultimately biodegrade in the environment.
The available ecotoxicity data for bis-aminopropyl diglycol dimaleate is also a little limited. I found results from short-term tests on aquatic invertebrates, and tests on algae, which showed that the chemical has not toxic. But there was no information on the effects of this chemical on fish, or effects on aquatic invertebrates over the long-term.
More information is available for the other ingredients in this product. The other main ingredients are readily biodegradable, which means a large amount should be removed during waste water treatment. However, some of these chemicals will be released to the environment after use, and some are toxic or very toxic to aquatic life.
One of the main ingredients is glycerin, which can be derived from palm oil. Olaplex has not published any information on the source of their glycerin, or how sustainable it is.
Some of the minor ingredients – specifically, quaternium-91, cetrimonium methosulfate, cetrimonium chloride and polyquaternium-37 – are quaternary ammonium compounds. The behaviour of these chemical depends greatly on the local environmental conditions, but they are all very toxic to aquatic life under test conditions. It looks like the cetrimonium compounds will be readily biodegradable, but this looks less likely for the other two compounds.
Most of the fragrances in this product are undisclosed, being just listed as “parfum”. It is impossible to determine what the environmental impact of these substances could be without further information.
The rest of the ingredients are primarily preservatives and vitamins. This includes EDTA and another similar chemical (etidronic acid). These two are not readily biodegradable and, in the environment, they may disrupt nutrient availability and cycling.
The packaging for this product is a simple plastic bottle which should be easily recycled in most kerbside schemes.
But does it work?
Considering how well a product works is a big factor in determining whether a product is a good one or not. A product that does not work is a waste.
Image credit: Kelly in the City
In 2017, the European Union Working Group on Cosmetic Products – a group established to provide advice to the European Commission on cosmetics – endorsed an update to their Technical Document on Cosmetic Claims. This document provides guidance for Member States to help them apply the requirements of Commission Regulation No 655/2013. The changes came into effect on 1 July this year, and many are currently speculating on its implications.
Two new sections were added to the Technical Document. One of these new sections relates to ‘free from’ claims (for example, “free from toluene”). It illustrates different types of ‘free from’ claims that could be considered unacceptable. For example, the Technical Document says that the following claims do not meet the requirements of Commission Regulation No 665/2013:
- “Free from formaldehyde”, where the product contains a chemical that may break down to release formaldehyde (such as a formaldehyde-releasing preservative)
- “Free from preservatives”, where the product is alcohol-based (like a perfume) and therefore self-preserving
- “Free from fragrances”, where the product contains an ingredient that has a perfume function, even if that ingredient was not added for its fragrance
- “Free from triclosan”, because triclosan is deemed safe in cosmetics when used in accordance with European law
The last example is particularly notable, and has generated the most interest. Many cosmetic brands rely on these sorts of ‘free from’ claims. This can create fear about the safety of some chemicals. However, some consumers may want to avoid ingredients that are safe for human use but could still have environmental impacts.
The justification for including this example is that claims like this “imply a denigrating message”. Particular issue is taken with claims that “are mainly based on a presumed negative perception on the safety of the ingredient”. As the changes have only just come into effect, we are waiting to see how this guidance will be applied in practice and if it will extend to environmental-based claims.
Commission Regulation No 655/2013 is law in all European Union Member States. It says that claims on cosmetic products must be legal, truthful, supported by evidence, honest, fair, and understandable to the user. However, the Technical Document is not law. Member States may apply the guidance in the Technical Document as they see fit.
Some are predicting the end of ‘free from’ claims, but only time will tell the full impacts of these changes.