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Developing a Restricted Substances List for Beauty and Personal Care Products

July 22, 2020 | Insights,

What is a Restricted Substances List (RSL)?

In simplest terms, an RSL is a list of chemical substances that are restricted or banned in a final product. RSLs may be developed by industry groups, brands, or retailers, and can serve multiple purposes. Some RSLs are based on regulatory requirements, clearly stating what regulatory obligations a product must meet. Other RSLs may go beyond regulatory compliance by restricting chemicals that may not currently be legally restricted. Since regulations are often seen as lagging indicators, this allows industry to address chemicals that are emerging as substances of concern faster than regulations can be updated. RSLs can also give brands and retailers a competitive advantage by advancing their sustainability agendas.

At a minimum, RSLs should include the chemical name, applicable Chemical Abstracts Service (CAS) number (or other identifying number), and the restriction level or maximum allowable concentration of the substance. More robust RSLs may also include information on test methods to ensure compliance with the stated restriction, and why and where the substance is restricted.

How to develop a Restricted Substance List?

Initially, developing an RSL may seem like a daunting task, but the process can be broken down into steps. Sources for chemical lists can come from a variety of places. A logical starting place can be global government regulation of chemicals in consumer products, focusing on those restricted in beauty and personal care (BPC) products. Including the chemical substances that are restricted by regulation in your jurisdiction is a helpful way to ensure regulatory compliance. Since product reformulation is expensive and time consuming, most companies will survey regulations across all the countries into which they sell products. Often, companies find it easier and less costly to use the country with the most stringent regulatory RSL as their baseline for screening chemicals. For example, the EU has a much longer list of restricted chemicals than the US.

Another source of chemicals of concern, chemicals that pose a hazard to human health or the environment, can be from competitors or industry associations and groups. There are many companies and groups that have already established different types of RSLs or unwanted chemical lists. True RSLs are typically found at the brand manufacturing level because brands have the insight and ability to more fully restrict substances. Though some retailers, like Sephora and CVS, will develop RSLs for their private label products, others implement strategies to work with national brand products. One example of this latter approach is to create an “unwanted” or “priority” chemicals watch list as a means of providing brands with guidance about the types of chemicals retailers would like to avoid in the products they sell. By putting chemicals on watch lists versus RSLs, retailers can signal their intentions without pressing their suppliers to immediately find safer alternatives if they are not available. This also allows for more dialogue with manufacturers about interpretations of the hazards and risks associated with a particular chemical and whether more research is warranted before arriving at a final decision. Examples of this type of approach include Target’s Unwanted Chemical List and Wal-Mart’s High Priority List. These chemical lists are often viewed as signaling tools for supply chains to work toward identifying feasible alternatives for the chemicals being called out. Retailers may also use these lists to set reduction goals or create clean label criteria to incentivize brands to remove chemicals of concern. A review of these lists can help establish what are commonly restricted substances. Chemicals frequently found on BPC lists include: phthalates, parabens, formaldehyde and formaldehyde donors, nonylphenols and nonylphenol ethoxylates, and anti-microbials.

Yet another approach is to inventory the chemicals that are found in your products and use a method to conduct a preliminary assessment of their hazards. Different approaches to hazard assessment could include using a substance’s Globally Harmonized System of Classification and Labelling (GHS) classification or using a method like GreenScreen to determine its GreenScreen List Translator™ score. GreenScreen List Translator™ scores are based on a “list of lists” approach to identify chemicals of high concern by scoring them based on a vast array of authoritative information. You can then use the list of chemicals of high concern found in your products as candidates for inclusion on an RSL.


Alternatives for Listed Chemicals

While it may be tempting to simply list a whole host of hazardous chemicals on an RSL to appear that you are making strong efforts toward greener chemistries, you will want to consider the concepts of alternatives assessment and regrettable substitutions. You understandably want to phase out chemicals of concern, but they do usually play an important role in your BPC products. For example, certain preservatives are commonly listed on RSLs, but preservation is an important function in BPC products. Excluding all preservatives would result in product spoilage, creating another type of hazard for users.

When a chemical is restricted, brands, suppliers, and manufacturers must search for an alternative chemical or process that serves the same function as the one being eliminated. Regrettable substitutions are ones where a hazardous chemical is replaced by another chemical that later proves to have a similar or even higher level of hazard or that may introduce other adverse effects.  To avoid regrettable substitutions, suppliers and brands may perform an alternatives assessment to ensure that the chemical or process being proposed as a safer substitute does not pose the same or worse hazards down the road. Alternatives assessment is the process of identifying chemicals of concern and then determining, assessing, testing, and implementing safer alternatives.


Clean Labels

Clean labels are becoming increasingly popular among retailers. A clean label is a slightly modified approach to an RSL. In general, a clean label indicates to consumers that a product is “free-of” specific chemicals. To date, these are often chemicals which are widely recognized by consumers and generally regarded as being unsafe. Many retailers are choosing clean labels to help take the ‘guess work’ out of identifying better products for their customers and incentivizing brands to “clean-up” their ingredient list in order to meet consumer demands for safer products.

The process for developing the criteria for a clean label may mimic that of developing an RSL, however clean labels tend to have a shorter list of chemicals of concern they are addressing. Retailers with existing clean labels include Target, Holt Renfrew, Sephora and Nordstrom. Again, you will notice that there are typically similarities in the chemicals being called out on these labels.

Not all clean labels adhere to the same set of chemical criteria, so it is important for retailers and brands to clearly understand what chemicals, hazards, or issues are being addressed by the clean label. Consumers may make assumptions about what “clean” means, so clearly communicating the intentions of the clean label will help eliminate confusion.

The growing demand for cleaner products is rising among consumers who want to protect their health and the environment from harmful substances and use their buying power for good.  Whether taking on a full RSL program or starting with a clean label approach, both have their merits and work to achieve the same goal, safer chemistries in beauty and personal care products to ultimately help protect consumers.

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