Clean Beauty's Reality Check
Experts weigh in on how the clean beauty trend gained momentum, where it went wrong, and what matters more than labels now.
Photo: Jocelyn Morales for Unsplash
In our reference articles on organic and natural cosmetics, we unpacked what those terms actually mean for the category — where definitions exist, which emblems to look for, and how claims can be verified. Clean Beauty is different.
Unlike organic or natural, the clean beauty trend never anchored itself to well-defined frameworks or certification programs. It emerged faster, spread wider, and carried far more emotional weight — without any guardrails.
Clean Beauty Was a Reaction
I’ve been watching the Clean Beauty movement unfold for well over a decade — and with sustained skepticism. In my view, Clean Beauty did not rise as a clearly defined category. It rose as a reaction.
That reaction was driven by a convergence of forces: growing consumer unease around ingredient safety, environmental impact, and long-term health considerations, paired with a broader sense that regulation had not kept pace with modern expectations. Even as overall cancer mortality rates in the United States have declined, rising incidence among younger populations and women sharpened public sensitivity around exposure and prevention. Against that backdrop, clean gained emotional momentum — even as the underlying science remained largely absent from the conversation.
This reaction didn’t happen in a vacuum. In the U.S., cosmetics have been regulated under the Federal Food, Drug, and Cosmetic Act since 1938. While enforcement tools and guidance evolved incrementally, the core legal framework governing cosmetic safety remained largely unchanged for decades. Against that reality, comparisons began circulating widely: the European Union was often described as having banned or restricted “more than 1,300” cosmetic chemicals while the U.S. had outlawed or curtailed only a small handful. Whether those comparisons were always scientifically appropriate is a separate question. What matters is that they resonated. They reinforced a growing perception gap between what consumers assumed modern regulation should look like and what actually existed.
Clean Beauty took hold in the gap between consumer expectations and regulatory reality. It positioned itself as a corrective — promising higher standards, faster action, and a more precautionary approach — without a shared definition or regulatory anchor. In the absence of a formal framework, the movement relied on simplified narratives, exclusion lists, and retailer-led definitions to signal safety and trust.
Born at the intersection of consumer anxiety, regulatory lag, and marketing language, Clean Beauty was emotionally relevant and commercially compelling. And that’s exactly why it rose so quickly — and why it was always open to interpretation.
To test my own skepticism, I turned to experts who have experienced this movement in the trenches: legal advisors navigating regulatory reality, formulators working at the bench, scientists focused on skin biology, and sustainability scholars. Their perspectives together reveal where Clean Beauty genuinely moved the industry forward — and where it oversimplified, overreached, or lost its way.
When Exclusion Lists Replaced Science
As Clean beauty gained traction, its lack of definition created a practical problem: if clean couldn’t be measured or verified, how could it be operationalized? The industry’s answer was simple — and consequential. Clean became defined not by what products were designed to do, but by what they were designed to avoid.
Ingredient exclusion lists emerged as a proxy for safety. They offered clarity where none existed and scaled easily across brands and retailers. For consumers, they provided reassurance. For brands, they offered a fast, legible way to signal values. But in translating concern into checklists, nuance was the first casualty.
From the formulation bench, that shift was immediate and absolute. As Kseniya Popova, Founder and Lead Cosmetic Scientist at Symbiotic Beauty Lab, describes it, “There was no nuance. It was about avoiding anything potentially—even remotely—unsafe.” Chemists were expected to reformulate accordingly, often across multiple, conflicting standards.
What looked like a short list of “free-from” claims on a label translated into hundreds or even thousands of ingredients formulators were no longer allowed to use. Each retailer, and often each brand, maintained its own restrictions.
Mistakes were costly. Product development became more about avoiding mistakes than making better products. Over time, formulating within these constraints became second nature — not because the science supported it, but because the system demanded it.
The problem wasn’t scrutiny. It was where that scrutiny stopped.
From a biological and immunological standpoint, exclusion lists mistake simplicity for rigor. As Dr. Ebru Karpuzoglu, Immunologist, Molecular Medicine Expert, Founder and CEO, AveSeena, explains, Clean Beauty largely abandoned the questions that actually determine safety and efficacy. “Instead of asking rigorous questions like how an ingredient interacts with skin biology at a cellular level, or what the toxicological and immunological literature says at a given concentration, the movement collapsed into simplistic good-and-bad ingredient lists.”
That collapse had consequences. Ingredients were judged in isolation, divorced from formulation context, delivery systems, exposure routes, and dose — the very factors that determine biological behavior. Origin became a stand-in for safety. Plant-derived was assumed benign; synthetic was treated as suspect. No branch of toxicology or dermatology supports that logic.
Clean Beauty’s defining move was not its demand for better products. It was its decision to equate absence with assurance. Once exclusion lists became the operating system, asking deeper questions became optional — and sometimes unwelcome.
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The Safety and Performance Trade-Offs
Clean Beauty rarely framed itself as a series of trade-offs. It presented exclusion as progress — remove the “bad” ingredients and the product would, by default, be better. What went largely unexamined was what those exclusions meant for performance, stability, and, in some cases, safety itself.
At the formulation level, removing tools from the chemist’s kit does not remove the underlying requirements of a finished product. A cosmetic still has to remain stable over time, resist microbial contamination, deliver its actives effectively, and perform consistently across real-world conditions. Those requirements don’t disappear just because certain ingredients fall out of favor.
As Popova has noted, eliminating certain preservatives, solvents, or stabilizers often forced formulators into difficult compromises: shorter shelf life, greater formulation complexity, higher production costs, or narrower margins for error. Performance expectations didn’t soften alongside clean standards — products were still expected to feel elegant, remain stable, and deliver visible results. They just had to do so with fewer and often less familiar tools.
From a biological perspective, those compromises matter. Karpuzoglu points out that Clean Beauty’s most persistent misconception was equating removal with reduced risk. “Consumers thought they were getting something safer,” she has observed. “In many cases, they were getting something less proven and less protective.” That dynamic was especially evident in preservative systems, where well-studied compounds with decades of regulatory review were broadly rejected, while alternatives with thinner safety data or higher sensitization potential rushed in to fill the gap.
The irony is that preservatives exist precisely to reduce risk — not theoretical risk, but real-world exposure to microbial contamination. Weak preservation doesn’t show up explicitly on an ingredient list. It shows up later, quietly, in compromised products and shortened usable life. Yet Clean Beauty discourse rarely made room for those nuances, because they complicated the narrative.
What also went missing was formulation context. Ingredients do not operate in isolation. Their behavior depends on concentration, delivery systems, pH, interactions with other components, and how the product is actually used. When safety conversations collapse into single-ingredient judgments, that complexity disappears. As Karpuzoglu has emphasized, no serious discipline within toxicology, immunology, or dermatology evaluates risk without considering dose and exposure — yet Clean Beauty often did exactly that.
Clean Beauty promised simplicity in a domain that is inherently complex. The cost of that simplification wasn’t just confusion. It was a collective reluctance to say the uncomfortable truth: that “cleaner” on a label does not automatically mean safer, more effective, or better suited to real human use.
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Retailers Created the Illusion of Standards
As Clean Beauty moved from idea to category in the early-to-mid 2010s, retailers stepped in to define what regulators had not. A wave of clean-focused retail concepts and proprietary standards emerged, reshaping how clean was understood and enforced. Specialty retailers like The Detox Market (began as a pop-up in 2010) and Credo Beauty (founded in 2014) built their identities around curated assortments and ingredient exclusion lists. By the late 2010s, that logic moved fully mainstream: Clean at Sephora launched in 2018, followed by Ulta Beauty’s Conscious Beauty initiative in 2020, anchored by its “Made Without List.”
Each program relied on its own internal criteria, resulting in a fragmented landscape where a product could qualify as “clean” in one store and not in another — without any change to its formula. This wasn’t about retailers doing a poor job — it was the predictable result of letting each retailer define “clean” on its own.
That fragmentation also carried legal consequences. As Antonella Colella, Esq, Founder, Colella Legal Studio, explains, “The lawsuits against retailers aren’t about ingredient safety — they’re more about consumer perception and implied guarantees.” In the Clean at Sephora class action, a federal judge dismissed claims in part because Sephora had publicly defined what the program meant, weakening allegations that reasonable consumers were misled into believing it promised something broader than its stated criteria. By contrast, more recent litigation targeting retailers has alleged failures to follow their own standards—shifting the dispute from “are these ingredients dangerous?” to “did your marketing match your rules?”
This is where the clean paradox becomes legal reality: retailers defined clean, consumers relied on that definition in purchasing decisions, and those definitions are now tested under consumer protection law. Once "clean" became a retail-defined promise, ambiguity didn’t disappear — it simply became a potential liability.
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Clean Beauty ≠ Sustainability
One of Clean Beauty’s most persistent — and least examined — assumptions was that it represented a meaningful step toward sustainability. In practice, the overlap was limited.
Clean Beauty focused primarily on ingredient acceptability, not on systems thinking: sourcing, lifecycle impact, manufacturing efficiency, or long-term environmental trade-offs.
That difference matters more than it might seem. Sustainability is not an ingredient attribute; it is a framework. Conflating the two allowed Clean Beauty to borrow the language of environmental responsibility without consistently engaging its rigor.
From a systems perspective, that disconnect was clear. As Rosita Nunez, PhD, Professor, Stevens Institute of Technology, who has worked across R&D, global marketing, and sustainability education, explains, Clean Beauty often prioritized optics over outcomes. “Adding a raw material because it was natural or plant-based did not always improve efficacy or safety,” she notes. The same logic applies environmentally: plant-derived does not automatically mean lower impact, nor does exclusion guarantee improvement.
To its credit, Clean Beauty did shift consumer behavior. It encouraged label reading, normalized questions about sourcing and ethics, and increased awareness of concepts like cruelty-free and fair trade. That cultural shift mattered. But awareness is not alignment. Clean Beauty rarely connected ingredient decisions to broader sustainability frameworks such as life-cycle assessment, land use, energy intensity, or waste reduction.
Transparency, efficacy, responsibility, and sustainability now carry more weight than the clean label itself. As Nunez observes, “The term has been absorbed for the most part,” as brands move toward clearer disclosures and more specific claims.
In hindsight, Clean Beauty was never designed to be a sustainability framework — and it shouldn’t be judged as one. Its real legacy lies in raising expectations and forcing long-deferred questions. But sustainability requires more than what you leave out of a formula. It demands accountability for what you put in, how it’s sourced, how it’s made, and what remains after the product is gone.
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Next Phase of Beauty
Clean beauty didn’t fail because consumers asked the wrong questions. It faltered because the answers stopped at the label.
What’s emerging in its place is not a new buzzword, but a recalibration of expectations — one driven less by marketing language and more by accountability. Across law, formulation, science, and sustainability, the direction is remarkably consistent: more proof.
From a regulatory standpoint, the floor is rising. Under MoCRA, FDA’s Modernization of Cosmetics Regulation Act of 2022, oversight is expanding into practical requirements designed to strengthen accountability and rebuild consumer trust by mandating serious adverse event reporting, safety substantiation expectations, and a stronger enforcement toolkit, and allergen disclosure requirements. Colella’s point lands here: in a world where “clean” is undefined, credibility increasingly hinges on whether a brand’s claims are consistent with its documentation and practice — and whether standards are applied the way they’re marketed.
At the bench, formulation is beginning to move past exclusion as a design principle. Popova’s experience points to a shift toward more intentional trade-offs — where performance, stability, and safety are acknowledged openly rather than obscured by “free-from” shorthand. Slower development, clearer priorities, and more intentional formulation choices are beginning to replace the reflex to remove first and explain later.
The focus is shifting back to science. Karpuzoglu’s insistence on biology-first thinking reflects a broader recalibration: ingredients are being evaluated in context — by concentration, delivery, exposure, and interaction — rather than by origin stories. The new standard asks harder questions: How does this work? For whom? And can you show it?
And from a systems perspective, the language itself is evolving. As Nunez has observed, "clean" hasn’t disappeared — it’s been absorbed. Transparency, efficacy, responsibility, and sustainability now carry more weight than a single, overloaded term. Sustainability, in particular, is being reclaimed as a systems problem, not an ingredient virtue: one that demands attention to sourcing, manufacturing, packaging, and end-of-life, not just what’s been left out of a formula.
Taken together, these shifts point to a more mature phase of the industry — one where standards are quieter but firmer, and where credibility is built through proof rather than assertion. Clean Beauty helped consumers care but the future of beauty won’t be defined by what products promise to exclude. It will be defined by what brands are willing — and able — to substantiate.
Birnur Aral, PhD, is a chemical engineer and consumer product expert with a career spanning research and development, testing, and sustainability. She brings a rigorous, evidence-first lens to product claims and consumer-facing topics.