Why "Clean Beauty" Claims Are Mostly Marketing Departments Arguing With Chemistry

As a cosmetic product developer, I get asked "is this clean?" more than almost any other question I hear. And every time, the honest answer is: clean by whose definition?

Because there isn't one. Between what a label implies, what a lab can actually prove, and which retailer decides to add its own standards: the definition is nothing but clear (n)

"Clean" is a retailer's opinion, not a regulation. There's no legal definition of "clean beauty" anywhere in the world. Sephora Clean, Credo Clean, Ulta's Conscious Beauty: each runs its own exclusion list, and the lists don't agree with each other. A product can be "clean" on one shelf and rejected on the next. So when a brand calls itself clean, what they usually mean is: clean according to the list we chose to follow. Marketing picks the retailer standard. Formulation works backward from there.

Non-toxic" is the claim regulators watch hardest: and most brands can't back it up. In the US, it falls under the FTC's Green Guides: it's effectively a safety claim, and it needs real scientific evidence: not just an absence of scary-sounding ingredients. Everything is a chemical, water included, so an unqualified "non-toxic" or "chemical-free" claim is often indefensible on paper. It's shakier still in the EU, where Regulation 655/2013's "fairness" criterion bans denigrating ingredients that are legally authorised and already deemed safe (The same rule that's caught out "paraben-free" for years. "Non-toxic" hits the same wall, just with a scarier word attached)

"Natural" has no percentage threshold. That's exactly the problem. In the EU, every cosmetic claim has to satisfy six criteria under Regulation 655/2013: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. Nowhere does the law say a product needs to be 70% or 90% natural-origin to use the word "natural." Brands can voluntarily calculate natural-origin content against the ISO 16128 standard, but "voluntarily" is doing a lot of work in that sentence. So a formula that's 60% synthetic can still say "natural" right up until an inspector applies the reasonable-consumer test and asks what an average person would assume that word means.

Every claim needs its own paper trail: and most brands only build it when someone asks. This is the part that never makes it into a launch deck: ingredient sourcing certificates, exclusion list cross-referencing, stability and compatibility data, and, for anything implying performance, like "dermatologically tested" or "clinically proven": An actual study with a real, statistically valid result behind it. In the EU, this all has to sit in the Product Information File (PIF) , ready to be produced on request. Not filed away for marketing's peace of mind. Filed away because an inspector can ask for it.

The real problem: the claim usually gets decided before the formula is finished. Marketing wants to say "clean." Or "non-toxic." Or "natural." And formulation and regulatory are handed the job of making that true after the fact : instead of the claim being built on top of what the product can already prove. That's the order most brands get backwards.

So the next time a label says "clean", ask what list they're measuring against. Ask to see the documentation behind "non-toxic." Ask what percentage "natural" actually means to them.

Because "clean" was never a formulation decision. It's a paperwork problem; and most brands would rather market around it than solve it.

If you're building a claim you're not sure you can substantiate, or building a product before you've decided what you want to say about it: that's exactly the kind of gap we help close!