The Copywriter’s Challenge

An important part of my role as a copywriter for beauty brands is encouraging clients to use words responsibly. Explaining they can’t use language like ‘heal’, ‘treat’, or ‘repair’ is easy. There can be serious consequences for doing so, such as action from regulatory bodies like the Therapeutic Goods Administration (TGA). Steering clients away from using iffy claims like ‘boosts [collagen/elastin/fibroblast production]’ is trickier because these kinds of claims are ingrained in the industry jargon. But it’s doable once clients understand why it’s important to make realistic statements.

 

What’s incredibly difficult is asking clients to explain, justify, and back up their sustainability claims with sufficient evidence and credible sources. They often don’t have the answers themselves. I’m not a sustainability expert, so to learn more about the deep and pervasive problem with greenwashing in the beauty industry, I spoke with someone who is: Environmental Consultant, Mink Ruttanaphon.

 

How does greenwashing present itself?

 

As a person involved in the beauty industry, the onus is on me to reflect my best current knowledge in the work I produce. It requires me to re-examine my perspectives from time to time. I experienced a notable – and deeply infuriating – outlook shift when I worked with a ‘clean living’ brand. The founder said they only give a shit about eco-conscious products because their customers were idiots who would spend money on them. So long as their multi-million-dollar business was paying off their mortgage, they’d say whatever they needed to about the environment to make people buy their products.

 

Of course, most people aren’t that disingenuous. In my experience, most independent beauty brand founders are motivated and excited to contribute to the industry in positive ways. Even behemoth brands are slowly but surely responding to cues from society to regain consumer trust and compete with agile, independent brands. The beauty industry is competitive, so all brands must find ways to stand out. Unfortunately, misappropriating sustainability claims is viewed as a shortcut to achieving consumer approval.

 

Terms like ‘sustainable’, ‘green’, and ‘clean’ are constantly misconstrued, conflated, and used as virtue signals. Brands use these words in their marketing like they have black-and-white, singular definitions. In response to growing consumer awareness around vague sustainability claims, some brands try to rectify the issue by acknowledging there’s no standardised or regulated definition – but then proceed to boldly make up their own. This isn’t to suggest brands using these words are deliberately trying to deceive customers. It’s fairer to imagine well-intentioned brand founders, marketers, and creatives mightn’t fully consider the implications of their language choices.

 

“Greenwashing is when a company or a product is marketed as being environmentally responsible, or better than its counterpart from an environmental perspective, without actually living up to the promise,” Mink explains. “This can range from making false claims to misleading advertisements. An example of the latter might be over-inflating one aspect of being sustainable. For example, ‘our packaging is made from recycled plastics,’ but it’s actually 1% of the overall material.”

 

If you accept a brand’s sustainability claims at face value, it justifies your purchase. You can buy a single-use face mask because it’s made with plant bio-cellulose. Lipstick made from natural ingredients can’t be so bad for the environment. A bamboo lid on a plastic tube – it somehow evens out, right? It’s easy to become desensitised to marketing messages surrounding sustainability. Recyclable packaging, biodegradable materials, and naturally-derived ingredients sound great. But we’re not stopping to consider whether these things are genuinely helpful.

 

It isn’t a given that ‘greener’ innovations in the beauty industry are inherently more sustainable. Sure, ‘bioplastics’ made from renewable sources like sugarcane aren’t fossil fuel-derived. But this material still demands water to grow, energy to be produced, and fuel to transport it. They’re sometimes compostable and biodegradable – but not necessarily. What’s worse, Mink explains, bioplastics can’t be recycled using the infrastructure we currently have in Australia and most countries. They contaminate the sorting stream of waste they’re in, making the recyclable items around them unrecyclable. Brands might want to convince consumers otherwise, but there are few absolutes when it comes to what is ‘better’ or ‘best’ for the environment. The only absolute is creating new things, of any kind, costs the planet.

 

“When terms like ‘green’, ‘sustainable’, and ‘eco-friendly’ are used without any supporting evidence, it is greenwashing,” Mink notes. She adds that supporting evidence should go far beyond an optimistic website claim. “Sustainability is a multifaceted issue with no single solution. When a product advertises itself as being green simply because it uses all-natural ingredients, it creates a misunderstanding among consumers that ‘all-natural equals sustainable’, which isn’t always the case. The ingredients may have been imported from all over the world, which increases a product’s carbon footprint, which contributes towards climate change.”

 

Thinking critically about the sustainability claims beauty brands make is exasperating. Mink finds herself scrutinising beauty brands’ sustainability policies, packaging choices, and ingredient sources to the point of “decision paralysis.” What is a recyclable box going to do to offset over-consumption and resource scarcity, or reverse the immensely harmful effects fossil fuel mining and greenhouse gas emissions are having on our planet? How much lasting change can be generated by supporting environmental causes without improving the beauty industry’s infrastructure? If taking a ‘anything is better than nothing’ approach is our best option, we’re in trouble.

 

Where does greenwashed information come from?

 

There’s a frequently cited statistic that summarises the beauty industry’s impact on the environment. “An estimated 120 billion units of packaging are produced every year by the global cosmetics industry, most of which are not recyclable.” It’s shocking, however, I’d consider it unverifiable. I clicked through five articles to locate the source. Australian Financial Review quoted Plastic Pollution Coalition, who quoted The Guardian, who quoted TerraCycle, who quoted Zero Waste Europe. When I reach the supposed original source, there’s an obstacle. There’s no indication as to which report this quote originated from. Checking reports published around the date this quote popped up yielded no results. If it’s this hard to validate such a widely-used claim, it suggests there’s a far larger problem to think about. Misinformation.

 

Finding true, credible, and valid information about pretty much anything is difficult. It’s a side effect of the world we’ve created and have little choice but to live in. The media, marketing, and entertainment we consume are rife with misinformation. Thinking about beauty, it starts with harmless hacks but turns into pseudoscientific reviews and “I think I read something once about preservatives being bad.” What’s more horrifying is the fearmongering and fallacy-spreading about consumer health and safety, toxicology, and environmental impact.

 

Research by sustainability marketing technology platform, Provenance, indicates that 55% of shoppers consult a beauty or wellness brand’s on-pack information when they’re looking for product sustainability information. (37% look on the brand’s website.) However, this on-pack or website information is written by a person or team of people involved in marketing. Someone like me. Depending on how and where information is found, some of the words printed on a package in your bathroom aren’t necessarily any truer than Karen on Facebook spouting something about sunscreen being dangerous. Rightly so, 79% of Provenance’s study respondents have doubts about the trustworthiness of beauty and wellness brands’ sustainability and social impact claims.

 

Beauty brands receive their information from sources they deem trustworthy, such as suppliers, industry research, media, and other brands. It’s not uncommon for brands to refer to their competitors as a benchmark for what to say. I’ve worked with marketers who click whatever the top Google result is to confirm their statements, with little regard for veracity. I’ve seen brand founders make claims based on nothing more than having a good feeling about something.

 

Raw ingredient or packaging component suppliers, for example, provide technical information about their products. This information needs to be factual, but they’re under no obligation to explain their product’s complete life cycle or environmental impact. It’s not because there’s a nefarious scheme influencing the entire beauty industry, where the truth is buried and suppliers are malevolent gatekeepers. It might be as simple as there aren’t enough people asking for more information.

 

Even a product as straightforward as face oil has a long list of individual components required to create it. Ingredients, bottle, closure system, label, label ink, label adherent. It might also have outer packaging, which requires ink and maybe a seal. Looking at the finer details, each supplier of a component requires their own list of materials for packaging and transport. Then there are essentials like electricity. It’s not realistic for every supplier’s claim to be cross-checked and verified, so brands have to put faith in their supplier’s operations. However, if more decision-makers in the beauty industry put the time, effort, and resources into asking for a deeper level of information, we could inch towards greater transparency.

 

What does it take to be a sustainable brand?

 

Mink explains there are many different metrics and methods used to measure sustainability. She believes the framework behind life cycle assessments (LCA) applies to the beauty industry, as it covers the entire product journey.

 

“To me, being genuinely sustainable starts from the product development, stepping through the product’s entire life cycle and addressing areas of opportunities within the business’s control,” she describes. “Consider the four life cycle stages of a product – raw material extraction, production, use, and end-of-life – and what can be done to minimise the impact along the way.”

 

Some questions to ask during each stage of the life cycle assessment include:

• Raw material extraction – Can the raw ingredients be sourced locally to limit transport emissions? Are my suppliers also environmentally conscious? Do they exploit their workers?
• Production – How can renewable energy be used in the factory to reduce reliance on the grid? Can we use second-hand machinery? Can the packaging be avoided, minimised, or recycled?
• Use – Can consumers use every last drop of the product? Are other products or accessories required for it to function?
• End-of-life – How do we make sure end-consumers dispose of the product responsibly? Which components will waste management facilities be able to recycle?

 

Mink concludes, “It is likely unfeasible to address every concern, but what’s important is the business is continually improving, being transparent about their practices, and using science-based evidence and/or third parties to verify any claims.”

 

Beauty industry leader, L’Oréal, uses the life cycle assessment methodology for product development, with an internal tool called Sustainable Product Optimisation Tool (SPOT). Documents published by the company explain this tool was developed with independent scientists and experts, in line with European Product Environmental Footprint (PEF) guidelines. L’Oréal product managers use SPOT to scientifically evaluate a product’s environmental and social impact, and measure progress. The company says since SPOT’s introduction in 2017, all new or ‘renovated’ L’Oréal products are evaluated using it, and by 2021, 96% of new or renovated products had an improved profile.

 

Similarly, LVMH Moët Hennessy Louis Vuitton’s (LVMH) Perfume & Cosmetics portfolio (P&C) has a suite of internal tools to assess their environmental impact. An example is EDIBOX, which tracks goals such as eliminating the use of virgin fossil-based plastics and recyclability, and calculates a product’s environmental footprint. LVMH P&C also uses an in-house waste management platform, Environmental Center for Eco-friendly Packaging Breakdown and Recycling (CEDRE). Additionally, the company engages with third-party environmental organisations and initiatives, such as Action For Sustainable Derivatives.

 

Smaller, independent beauty brands should also bear some responsibility for adopting sustainable business models. They’re more agile than their heritage brand counterparts and can respond faster because they don’t have to deal with layers of bureaucracy and steadfast board members. However, the reality that is industry-leading companies have the resources to invest in research, development, and roll-out of more sustainable practices. It’s not within my jurisdiction to evaluate whether their current sustainability actions are enough to mitigate their environmental impact. (Or if they’re genuinely committed to their goals.) When I ask Mink if she believes any beauty brands are doing a good job with sustainability, she tactfully replies, “No specific brand comes to mind.”

 

How do we minimise greenwashing?

 

Brands might be reluctant to be fully transparent. Admitting to mistakes, rescinding previous statements, losing credibility, and possibly sacrificing consumer trust isn’t necessarily a commercially viable move. But the alternative is continuing as we are, misinforming consumers, and making little progress towards sustainability. It’s not a stretch to assume most people are concerned about the environment and want to make a positive difference in the industry. So, who’s going to do something – and how?

 

Looking broadly, every beauty brand should not only strive to operate in an environmentally accountable way, but extend this responsibility to their communication. Findings by Provenance revealed that 71% of shoppers aren’t sure what is meant by ‘environmentally friendly’ and 62% say the same for ‘green’ claims. If consumers don’t understand something important to their purchase, brands should feel compelled to educate them and explain it properly. Not only is it the sensible thing to do, it demonstrates transparency, authenticity, and honesty. Ironically, many brands that are hellbent on telling consumer they operate ethically struggle to demonstrate it through their sustainability claims.

 

Mink encourages beauty brands – of all sizes – to actively avoid greenwashing by:

• Being transparent with consumers
• Specifying and backing up any claims with evidence or third-party verification
• Setting sustainability goals that are tangible and achievable for their business
• Educating consumers on sustainability issues that matter to them and/or their brand
• Committing to a timeline and outlining measurable steps towards meeting goals
• When goals are met, set new ones. Never stop improving.

 

Beyond making more sensible, realistic claims, brands should consider utilising tracing, verification, and certification technology. Blockchain is seen as a promising solution for substantiating claims in the beauty industry, as product components could be traced with greater transparency. There are also calls to standardise information and implement a universal environmental scoring system. L’Oreal, LVMH, Natura & Co, Unilever, and Henkel joined forces to form the EcoBeautyScore Consortium, along with over 60 small and large beauty businesses.

 

In October 2022, The Guardian reported the Australian Competition and Consumer Commission (ACCC) is “cracking down” on Australian gas and energy companies making false claims about environmental action. Around the same time, the ACCC announced it was conducting “internet sweeps” of brands suspected of greenwashing, across a range of industries, including cosmetics. However, this sweep included 200 websites across other industries including energy, vehicles, household products and appliances, food and drink packaging, and clothing and footwear industries. If these sweeps were evenly distributed across industries, they would only cover about 33 cosmetics websites.

 

Later that month, the Australian Securities & Investment Commission (ASIC) took action against an ASX-listed energy company, Tlou Energy Limited, for making greenwashed statements. After making four questionable claims, the company was forced to pay a $53,280 infringement notice, based on ASIC’s decision that they “did not have a reasonable basis to make the representations, or that the representations were factually incorrect.” Perhaps if similar action was taken against beauty brands for making greenwashed statements, the threat of actual consequences (such as financial penalties and bad press), would encourage brands to be more responsible.

 

In June 2022, ASIC published an information sheet titled, ‘How to avoid greenwashing when offering or promoting sustainability-related products’. Though ASIC’s main concern about greenwashing is its threat to the financial system, ASIC neatly summarises, “Greenwashing distorts relevant information that a current or prospective investor might require in order to make informed investment decisions.” Swap investor for consumer, and herein lies the crux of the problem with greenwashing in the beauty industry – and every industry.

 

The most recent action by the ACCC was in July 2023, when they published guidance for businesses about how to make environmental and sustainability claims. It contains eight principles for businesses to follow. They are: make accurate and truthful claims, have evidence to back up your claims, do not hide important information, explain any conditions or qualifications on your claims, avoid broad and unqualified claims, use clear and easy to understand language, visual elements should not give the wrong impression, and be direct and open about your sustainability transition. I wholeheartedly agree with these principles and intend to conform to these standards in my work. However, the attention Australian regulators pay to greenwashing in the cosmetics industry is relatively low, compared to prominent carbon emitters like gas and energy companies.

 

The United States Modernization of Cosmetics Regulation Act of 2022 (MoCRA) represents an egregious missed opportunity for sustainability progress in the cosmetics industry. MoCRA describes itself as, “the most significant expansion of FDA’s authority to regulate cosmetics since the Federal Food, Drug, and Cosmetic (FD&C) Act was passed in 1938.” Gradual changes to the cosmetics industry include mandatory product and ingredient registration with the FDA, product safety substantiation, consumer information for reporting adverse events, and fragrance allergen identification. That’s fantastic, but where is the federal regulatory oversight about sustainability or greenwashing in the cosmetics industry? If regulators aren’t going to take real action now, then it’s up to beauty industry decision-makers to do it.