Ontario Chapter Society of Cosmetic Chemists Dedicated to the Advancement of Cosmetic Science

The Challenges of Formulating Natural Cosmetics

by Perry Romanowski

Clean Beauty is all the rage these days and it can be directly related to the

difficulties in formulating natural cosmetics. Although there are not actually

any cosmetics that I would consider natural (there is no lipstick bush) some

things are seen as more natural than others. Ingredients that are obtained

from plants or chemically modified from plants or chemically identical to

plant ingredients are considered by some people “natural.”

The problems with formulating natural

However, there are some significant challenges to formulating natural. It was these problems that led to the

creation of this new niche called Clean Beauty. Some of the problems are as follows.

There aren’t many natural ingredients

First, when you commit to formulating natural you’ve significantly reduced your formulation options. The INCI

dictionary lists about 22,000 different chemicals that can be used in cosmetics. Maybe 10% of those would be

considered natural. Now, most natural standards groups and retailers solve that problem by just making

exceptions and letting formulators use synthetic ingredients that seem natural so it expands the actual

ingredient pallet. However, if you’re being a natural purist there aren’t many things you can use.

The natural options don’t work as well

Another problem with natural formulating is that the ingredients you are restricted to are not the best

functional ingredients. As an example, if you wanted a truly natural, from the planet cleansing surfactant,

you’re only real choice is a saponin from the berries of a soapnut tree. These are not nearly as effective as

synthetic surfactants and they’re hard to work with. And consider colorants. There are very few truly natural

colorants that have been approved by the FDA. I saw a blog post where they went through and listed all these

extracts and the different colors you can get from them. But you know what? In the US it is illegal to use most

of them for the purpose of coloring your product. There are less options and they don’t work as well.

The supply is inconsistent

And even if you find a natural ingredient that works great, you can’t necessarily count on always being able to

get that ingredient. I know in the recent past there was a significant problem with the yearly jojoba crop and

getting jojoba oil was a challenge for many brands. If you are a smaller brand and there is a problem with any

crop, you could be out of luck for getting a supply. Or you might get an ingredient that worked one way one

year but the growing conditions made it such that you got an ingredient with the same name that didn’t work

the same way.

Natural ingredients are harder to work with

When you formulate natural your limited in what you can formulate with and it is particularly difficult in terms

of preservation. Natural ingredients are more prone to contamination than synthetic ingredients. That’s what

happens when you leave something outside and exposed to the natural environment. And there are just not

many options when it comes to formulating using only natural preservatives. Sometimes you just can’t get a

preservative that is effective enough.

Natural Fallacy

Natural marketing is based primarily on fear and the natural fallacy. Marketers of these products want people

to believe that things that are natural are safer for you. They want people to believe that things that are natural

work better. Unfortunately, or fortunately depending on your perspective, neither of these things are

necessarily true.

Natural is not more safe

It certainly isn’t true that natural things are safer for you. Safety of an ingredient has nothing to do with

whether it is natural or not. Certainly there are safe natural ingredients. But there are also unsafe natural

ingredients. Who wants to take a blop of poison if extract and rub it on their skin? In fact, if you look at the

ingredients that cause the most skin reactions, they are normally natural or naturally derived ingredients.

Natural lacks performance

It is also not true that natural products work better. And this is probably the number one reason for the rise of

Clean beauty. While people can be fooled into believing that their naturally derived ingredients are safer for

them. Safety is not something you can actually see or experience in any immediate way. Performance, on the

other hand is something you notice right away. It’s easy for consumers to tell when a product isn’t working as

well as they expect. Consumers can tell when a product feels bad on their hair or it feels more irritating on

skin. When it comes right down to it, consumers want products that work. They might say they want “natural”

and environmentally friendly products, but what they really want are products that are effective and fun to use.

Natural has no legal definition

Another problem with the marketing term natural is that the regulators in the US have added to the confusion.

The term natural has no legal definition. In the US, pretty much anyone can call anything they want “natural.” At

least according to the FDA.

FDA on Natural

This is taken from the FDA website in regards to the question of natural.

“FDA has not defined the term “natural” and has not established a regulatory definition for this term in

cosmetic labeling. FDA also does not have regulations for the term “organic” for cosmetics. The U.S.

Department of Agriculture (USDA) regulates the use of the term “organic” for agricultural products under the

National Organic Program (NOP).”

So if you’re marketing is good enough you’ll be able to find consumers who want the product. Brands that use

standard technologies can legally claim that they are natural. And I suppose that since there isn’t any proof of

something “supernatural” they might have a point.

But things have changed a little bit recently due to actions by the FTC, which is the Federal Trade Commission.

In 2016, they filed suit against 5 cosmetic companies for making misleading claims about their natural


FTC Action

The FTC said they still don’t have a definition for natural however, if you are going to make the claim “100%

natural” or “All natural” then you can’t have synthetic chemicals in your products. They made it clear that

marketers who made those specific claims should not use synthetic chemicals.

The wording of the claims matters a lot. I would recommend you avoid claims like “all natural” and “100%

natural” until the FTC clarifies what those terms mean.

Just so you know, in the US you don’t only risk government action. You also risk being sued by any consumer or

lawyer who thinks that your natural product isn’t natural enough. The brand Tresemme was sued for their

natural product because it contained synthetic chemicals. They ended up settling the case for $3.2 million and

have stopped selling the naturals line. This is a real risk for brands trying to claim natural. You really need a

rationale for why your product is natural.

And if you use the term “organic” in your product, watch out for lawyers from California. In that state they have

a rule governing the term organic and a number of beauty brands have been sued or fined because they used

the term “organic” in their marketing. Brands like Babyganics, JASON, Avalon Organics, and Organix have all

had lawsuits brought against them. Some have settled while others have changed their marketing. Unless you

get certified, don’t use the term “organic” in your marketing.

Now with these murky regulatory rules and since performance of natural cosmetics was a problem, marketers

needed a new way to talk about this space. It is still pretty easy to convince consumers that natural things are

more safe, so some clever marketers got the idea to create this new category of Clean Beauty. Clean beauty

embraces all the fear motivating natural beauty without the performance deficits or the worrisome

government regulations. We’ll cover what that means in a future blog post.