Here’s the thing about bringing clean beauty products to the market: if you’re doing the real work, it’s really, really hard. As we’ve said for years, clean beauty is not just about banning ingredients—and our most recent journey into PFAS and fluorinated compounds is the perfect example of just how hard this work is.
In the spirit of transparency, we want to bring you along on this journey (just like we have done with child labor in the mica industry, heavy metals in color cosmetics and phthalates in manufacturing equipment), because our work is always about progress over perfection. Each day we show up, aiming to take on the conventional ways of doing beauty, challenging the status quo.
Here is a quick primer on PFAS ingredients, which are part of a class of fluorinated compounds. These ingredients are used in a variety of applications but are specifically used in the beauty industry to create products like long-lasting lipstick, longwear foundation, and waterproof mascara. Beautycounter bans PFAS ingredients from our formulations as part of the The Never List™. The issue is that fluorinated compounds are also used in the beauty industry supply chain, which is very difficult to control, including cleaners used on manufacturing equipment, undisclosed treatments on packaging and raw materials, and coatings for plastic totes that ship raw materials overseas, and they even contaminate water supplies.
These supply chain complexities are part of the reason we advocate for more regulation and have openly shared the issue with trace contaminants with consumers. Case in point, while all of our ingredients are sourced with a higher standard of safety and quality in mind, it is well recognized—and accepted by regulatory authorities around the world—that incidental, trace levels of a chemical may inadvertently be introduced in a cosmetic product due to the complexities of the supply chain and manufacturing process. At Beautycounter, we work incredibly hard to minimize—but unfortunately, can’t eliminate—the potential that a product may contain trace levels of a chemical from The Never List™ due to this inadvertent contamination.
This work is ongoing, and it brings us back to what we can control: our product development process. Knowing the desire for longwear finishes for makeup, we have spent years improving our formulas to have this desired effect without using PFAS ingredients. Select makeup products were tested for 23 commonly used PFAS ingredients in cosmetics and all the test results were “non-detect,” which is a scientific way of saying the chemicals we tested for are not detectable (for the discerning eye out there, the detection limit was less than 3 ppb).
We also wanted to take things a step further and we sent select makeup products to a different lab that tests for fluorine generally (rather than just select PFAS ingredients). We selected high-risk makeup products, produced by three different manufacturers.
So why test for fluorine? By way of background, the overarching family of chemicals called fluorinated compounds consists of over 9,000 different chemicals (PFAS are some of them and many are hard to test for), but they all break down into fluorine. Which is why we tested certain finished products for fluorine to see if there were other exposure points we should know about.
The results for most of the products we tested showed non-detectable levels and other products we tested had minimal fluorine contamination found (at varying detectable levels). We weren’t surprised by these results given the widely shared understanding that fluorine is a widespread environmental and supply chain contaminant (like heavy metals and phthalates as we have addressed previously). While we feel confident in the safety of our products, the testing inspired a complex journey to understand where the select contamination could be entering our supply chain.
Here is an overview of our current approach to this issue and what we are finding along the way. Please stick with us until the end because we have a call to action that will help us address this issue in meaningful ways.
1. We ban PFAS ingredients outright.
We do not formulate with fluorinated compounds. They were added to our Never List years ago.
2. We ask raw material suppliers for certain high-risk products and packaging suppliers to verify, in writing, that they do not use fluorine treatments in our products and packaging.
PFAS can sneak their way into products without companies knowing in a variety of ways, one of which is through the treatments of pigments on packaging. Pigments (also known as colorants) are sometimes treated with PFAS to help the color have lasting power. Oftentimes brands don’t know about these treatments and therefore, they don’t make their way onto product labels (legally treatments like these don’t need to be included on product labels). In addition, packaging suppliers may use fluorine treatments for packaging—specifically, certain plastics like high-density polyethylene (HDPE)—without necessarily disclosing this to brands.
For certain high-risk products (makeup products mentioned earlier like foundation, mascara, and lip products) Beautycounter has requested in writing that raw material and packaging suppliers confirm that they do not use any fluorinated treatments in our products and packaging. Moving forward, this documentation will be requested for all new products and packaging (not just those identified as high-risk). Without federal legislation, we are taking suppliers at their word. Which is why we take things even a step further.
3. We periodically test high-risk products for PFAS and fluorine.
We recently tested certain high-risk products like mascara, foundation, lipstick, and lip gloss for 23 PFAS chemicals and the test results were “non-detect.” We also went further and tested certain high-risk products for fluorine, where the results were mostly non-detect, but minimal contamination was detected in some, which pushed us to continue on this journey.
4. We audit and press manufacturing partners for certain high-risk makeup products.
The presence of fluorine without PFAS raises important questions as to the potential root causes of the issue. Fluorinated compounds are known to be highly effective cleaners in industrial settings. So, we promptly asked our manufacturing partners of high-risk products to confirm if they use any fluorinated cleaners, agents, or treatments anywhere in their facilities. Some of our manufacturers noted they didn’t use fluorinated compounds and others transparently shared how some fluorinated compounds are used in the manufacturing equipment. We are working with them to address the use of fluorinated compounds in their facilities. And as you might expect, given the persistence of fluorinated compounds, simply washing equipment doesn’t make them “go away.” (We are even going so far as to test water samples from three of our manufacturing partners. This testing is underway.)
5. Raw material and packaging testing
Fluorinated compounds can also sneak into products since they may often be used to treat the barrels that raw materials are sent in (even at the very beginning of the supply chain), where brands don’t have any visibility. Talk about a wild goose chase, right?
In order to understand this, we initiated independent fluorine testing of all raw materials for select makeup products and the empty finished good packaging, so we could learn more about these as potential sources. This testing is underway and will help us pinpoint and further inform future development and packaging selection.
6. Advocate, advocate, advocate
Like we have discussed with other contaminants (heavy metals, phthalates, benzene), we believe getting to the bottom of a clean supply chain is virtually impossible without federal regulations that hold our manufacturing and raw material suppliers accountable. Beautycounter has been the most outspoken brand on Capitol Hill asking for supply-chain transparency measures to be included in federal legislation, including the recently introduced PFAS language (because banning PFAS outright is not enough). Please join us and demand that Congress and Parliament take immediate action to hold the entire beauty supply chain accountable. Without new oversight, it is hard for companies like Beautycounter to truly make meaningful change.
We value transparency; it’s painted on the walls of our office. And to us, that’s not lip service, it’s the truth. We hope you value being brought along on this journey with us, because doing the real work to bring clean beauty products to the market does not start and stop with banning ingredients.
It takes long and painful investigations. It takes pressuring raw material, packaging, and manufacturing partners. And it takes intentionally asking Congress to better regulate our industry.
We will continue to keep you up to date on this important work and in the meantime, we need your help. Please support our efforts and text BANPFAS to 52886 to ask Congress for change.