Clean beauty is one of the most commercially successful ideas in the history of the personal care industry. It is also one of the least defined. ‘Clean,’ ‘natural,’ ‘non-toxic,’ ‘green,’ and ‘pure’ are marketing descriptors, not regulatory categories. No US federal agency defines or enforces any of these terms in the context of cosmetics. A brand can call a product ‘clean’ regardless of what is in it, and many do.
This is not an argument against the principles behind clean beauty — ingredient transparency, harm reduction, and informed consumer choice are genuinely valuable. It is an argument for understanding exactly what these labels do and do not tell you, so you can evaluate products based on evidence rather than packaging language.
The regulatory gap
In the United States, cosmetics are regulated under the Federal Food, Drug, and Cosmetic Act (FD&C Act), last comprehensively updated in 1938. Under this framework, cosmetic brands are not required to prove product safety before bringing a product to market; they are required only to ensure it does not contain specifically prohibited or restricted ingredients.
The FDA restricts or prohibits approximately 11 ingredients in cosmetics. The European Union, under its Cosmetics Regulation (EC) No 1223/2009, restricts or bans approximately 1,328 substances. This gap is frequently cited in clean beauty marketing, and it is a real and meaningful regulatory difference — European cosmetic standards are substantially more protective than US standards, and many ingredients permitted in US products would not be allowed in their European equivalents.
The Modernization of Cosmetics Regulation Act (MoCRA), signed into law in December 2022, represents the most significant update to US cosmetics regulation in over 80 years. It requires manufacturers to register facilities and disclose product ingredients to the FDA, and it gives the FDA new authority to require safety substantiation and issue mandatory recalls. It does not, however, define ‘clean’ or regulate marketing claims around naturalness or safety.
What ‘clean’ means in practice
In the absence of regulatory definition, ‘clean’ means whatever each brand or retailer decides it means. Several retailers have established their own clean standards with published ‘prohibited ingredient’ lists:
- Sephora Clean prohibits a list of approximately 50 ingredients including parabens, formaldehyde-releasing agents, SLS, synthetic fragrances, and several controversial preservatives.
- Credo Clean Standard is one of the most stringent retailer-level standards, prohibiting over 2,700 ingredients and requiring supply chain transparency.
- EWG Verified (Environmental Working Group) prohibits ingredients on EWG’s concern list and requires full ingredient disclosure with safety substantiation.
These standards are not equivalent to each other and not equivalent to regulatory approval. A product meeting Sephora’s Clean standard may not meet Credo’s, and vice versa. ‘EWG Verified’ is the most rigorous of the commonly seen third-party clean certifications, but EWG’s hazard assessments have been criticized by some toxicologists for applying a precautionary principle that does not always reflect dose-dependent risk.
What ‘natural’ means
‘Natural’ is similarly unregulated. An ingredient can be described as natural if it is derived from a natural source, regardless of how extensively it has been processed, refined, or chemically modified in the production process. Sodium lauryl sulfate, for example, is typically derived from coconut oil — it is a naturally derived ingredient that has undergone significant chemical processing. A shampoo can legally describe itself as containing ‘naturally derived surfactants’ while using SLS.
Conversely, some synthetic ingredients have exceptional safety profiles and are used specifically because they are more stable and less allergenic than their natural counterparts. Synthetic fragrance compounds identified as safe by the International Fragrance Association (IFRA) may be safer for sensitive individuals than complex natural essential oil blends, which contain a broader array of potential allergens.
What ‘non-toxic’ means
Toxicity is dose-dependent. The foundational principle of toxicology, established by Paracelsus in the 16th century, is that the dose makes the poison: virtually any substance is harmful at a sufficient dose and safe at a sufficiently low dose. ‘Non-toxic’ as a marketing claim implies that a product’s ingredients pose no hazard at any dose, which is a claim that no responsible toxicologist would make about any substance.
The more meaningful question is not whether an ingredient is toxic in isolation, but whether it is present in a finished product at a concentration and in a delivery format that poses a realistic risk to the consumer who uses it as directed. This requires reading safety assessments from bodies like the CIR (Cosmetic Ingredient Review), not marketing claims on the bottle.
How to actually evaluate a haircare product
- Read the full ingredient list (INCI). Ingredients are listed in descending order of concentration. The first five to ten ingredients make up the vast majority of the formula.
- Use the EWG Skin Deep database (ewg.org/skindeep) to look up individual ingredients and their associated hazard scores. Take scores as a starting point for investigation, not a final verdict.
- Look for third-party certifications with published ingredient standards — EWG Verified, COSMOS Organic, or Credo Clean — rather than relying on brand-originated ‘clean’ claims.
- Be skeptical of ingredient fear marketing. Claims that a product is ‘free from X’ are only meaningful if X is actually a concern at the concentrations used in personal care products.
- Prioritize formulation quality over marketing language. A well-formulated product with a clear ingredient purpose — regardless of whether it carries a ‘clean’ label — is more likely to deliver results than a poorly formulated product with impressive packaging claims.
Sources
- US Food & Drug Administration. Cosmetics Safety Q&A. fda.gov/cosmetics. Accessed 2026.
- European Commission. Regulation (EC) No 1223/2009 on Cosmetic Products. eur-lex.europa.eu.
- Cosmetic Ingredient Review. cir-safety.org. Independent safety assessments of cosmetic ingredients.
- Environmental Working Group. EWG Skin Deep Cosmetics Database. ewg.org/skindeep.
- Nohynek GJ, et al. Grey goo on the skin? Nanotechnology, cosmetic and sunscreen safety. Critical Reviews in Toxicology. 2007;37(3):251–277.
- Gilpin SJ, et al. Cosmetics and personal care products: risk communication and regulatory practice. Regulatory Toxicology and Pharmacology. 2020;110:104529.
Explore MDRN Beauty’s ingredient-transparent lineup here. For more guidance, visit the MDRN Edit.
