Guidance

The scope of this KPI includes company-level activities for manufacturers that sell beauty and personal care products in the United States.  Company-level activities for products sold in other regions are not to be considered.


Both intentionally and unintentionally added ingredients in final formulations are in scope for this KPI.


  • For D and E, chemicals that are reasonably expected to be present include intentionally and unintentionally added ingredients present above trace quantities where the manufacturer knows or should reasonably know of such ingredients, impurities, or contaminants, unless they are withheld as confidential business information (adapted from the New York State Department of Environmental Conservation).
  • For D, the limit of detection is 100 ppm.  Chemicals that are reasonably expected to be present at levels lower than 100 ppm are not included.
  • For E, chemicals that are reasonably expected to be present at detectable levels are included.


For this KPI, the "Stewardship List" is comprised of all of the chemicals on the following published lists:


  • CA EPA Prop 65 - Reproductive and Developmental Toxicants, Carcinogens
  • EPA Toxics Release Inventory PBTs
  • EU - Cosmetics Regulation Annex II
  • EU - Priority Endocrine Disruptors (Categories 1, 2)
  • EU REACH - Annex XVII CMRs (Appendices 1-6)
  • IARC - Categories 1, 2A, 2B


These published lists have been referenced in public retailer chemical policies.  Where a chemical is accompanied by a specific route of exposure on these published lists, and the exposure route is relevant to the product during consumer use or foreseeable misuse, then the chemical is relevant to this KPI.


Resources

The Globally Harmonized System of Classification and Labeling of Chemicals (GHS):  GHS provides specific human and environmental health criteria along with physical hazard criteria for chemicals in industry. These criteria are used for hazard communication and labeling of chemicals.


Definitions

Intentionally added ingredient: A chemical that provides a function to the final formulation during consumer use or is present as a result of formulating a product for safe use by consumers (e.g., pH balancing by acids or bases).


Limit of detection: Defined by the IUPAC Compendium of Chemical Terminology, 2nd ed. (the “Gold Book”) as: “The limit of detection, expressed as the concentration, or the quantity, is derived from the smallest measure, that can be detected with reasonable certainty for a given analytical procedure.”


Unintentionally added ingredient: An ingredient that provides no function in a final formulation and is not present as a result of formulating a product for safe use by consumers (e.g., pH balancing by acids or bases). Unintentionally added ingredients include chemical contaminants (naturally occurring impurities present in procured raw materials that are unintentionally incorporated into final formulations where they provide no function) and incidental chemicals (chemicals in raw materials present as a result of processing or for stabilization such as catalysts, solvents, residual monomers, reactive by-products, and raw material preservatives).