Guide to the Compact - 6 major steps for Compact compliance

The Compact for Safe Cosmetics aims to improve the safety of products made by companies who sign on, and to ensure that companies provide the fullest information possible to help consumers make informed decisions about the products they buy.

The Campaign for Safe Cosmetics launched the Compact in 2004. The Campaign is a national coalition of nonprofit health and environmental organizations. The Environmental Working Group is a founding member of the Campaign. We created and maintain the Skin Deep database to give people practical solutions to reduce everyday exposures to cosmetic ingredients that could pose health risks. We also work with the Campaign to help ensure that companies are complying with the Compact for Safe Cosmetics, analyzing and posting compliance data within Skin Deep to show company progress in meeting this pledge of safety and transparency.

The Compact's six provisions, and companies' requirements for complying with each of these provisions, are described below:

• Provision 1: Comply with the EU Cosmetics Directive in all markets
• Provision 2: Disclose all ingredients
• Provision 3: Publish and regularly update product information in EWG's Skin Deep database
• Provision 4: Comply with ingredient prohibitions and restrictions under the Compact for Safe Cosmetics
• Provision 5: Substantiate the safety of all products and/or ingredients with publicly available data
• Provision 6: Participate in the Campaign for Safe Cosmetics

The Campaign for Safe Cosmetics rates companies who sign the Compact for Safe Cosmetics as either "Gold member," "Full Member," or "Associate" status, depending on their progress in implementing the Compact. Gold member status is reserved for companies in full compliance with all 6 Compact provisions, including fully substantiating the safety of all products or ingredients with publicly available data. Full Member and Associate status are designated for companies that meet alternate, less stringent standards detailed below.

Provision 1. Comply with the EU Cosmetics Directive in all markets

Companies must comply with the formulation standards of the EU Cosmetics Directive upon signing the Compact. This means that as a minimum standard of safety, all products sold worldwide must be free of the over 1,100 toxic ingredients banned from personal care products by the EU. (Required for Gold Member, Full Member, and Associate status.)

Provision 2. Disclose all ingredients

Companies must disclose all ingredients on product labels or product inserts, and on company websites, within 1 year of signing the Compact. This includes all components of fragrance and other proprietary blends.

The Compact requires that companies use the INCI (International Nomenclature of Cosmetic Ingredients) system for ingredient labeling, as required in the EU, except in 2 cases: 1) for INCI mixtures, where the Compact requires full listing of components; and 2) for ingredients for which the Campaign has determined that alternate nomenclature provides greater transparency and clarity for consumers. The Campaign encourages companies' suggestions on ingredient nomenclature.

(Gold Member and Full Member status - requires full compliance; Associate status - requires submission to Campaign of official denial of request for ingredient disclosure from ingredient supplier, for one or more proprietary mixtures.)

Provision 3. Publish and regularly update product information in EWG's Skin Deep database

Within 1 year of signing the Compact, companies must enter information for all products they make or market into Environmental Working Group's (EWG) Skin Deep database. Companies must disclose all product ingredients and use the INCI system for ingredient nomenclature, subject to the exceptions noted previously. Companies must update information when products are introduced, reformulated or discontinued, and must review their data at least annually. (Required for Gold Member, Full Member, and Associate status.)

Skin Deep is an online cosmetic safety database created by EWG (a Campaign partner and founding member) that provides safety information on over 8,000 ingredients used in more than 40,000 personal care products. Product ingredients are cross-referenced against 60 toxicity and regulatory databases from around the world. Companies - and consumers - can use Skin Deep to generate comprehensive reports detailing adverse health impacts linked to cosmetics ingredients.

Provision 4. Comply with ingredient prohibitions and restrictions under the Compact for Safe Cosmetics

Within 3 years of signing the Compact or within 1 year of publication of a new standard, companies must comply with ingredient prohibitions and restrictions under the Compact for Safe Cosmetics, including:

a. Ingredient standards recommended or mandated by national health agencies overseeing cosmetics safety, including in the U.S., Japan, Canada, and the E.U.; and recommendations in industry-sponsored assessments, including under the International Fragrance Association and the Cosmetic Ingredient Review panel of the Personal Care Product Council. These standards include ingredient prohibitions, ingredient restrictions, and impurity limits.

b. Additional ingredient prohibitions and restrictions endorsed by the Campaign for Safe Cosmetics. These encompass ingredients known or suspected to be hazardous to humans or the environment based on findings of government, industry, or other peer-reviewed assessments.

(Required for Gold Member, Full Member, and Associate status.)

Provision 5. Substantiate the safety of all products and/or ingredients with publicly available data

Within 3 years of signing the Compact and subsequently upon introducing new products to the market, companies must submit to the Campaign assessments substantiating the safety of each product or ingredient, demonstrating compliance with the standard given below that would ensure a reasonable certainty of no harm from use of the products. All studies conducted, reviewed, or used to substantiate safety must be made available to the public, including all available information from ingredient suppliers. For members of the Personal Care Product Council, all safety dossiers must be made available to the public.

Standard for safety substantiation: Reasonable certainty of no harm: The safety of personal care and cosmetic products must be substantiated through peer-reviewed scientific publications or other publicly available studies, of a reasonable certainty of no harm from aggregate exposures to the product and its component ingredients including impurities, taking into account factors that may increase toxicity or penetration of the product or its component chemicals through the skin, including the presence of penetration enhancers and the effects of particle size including nanoparticles, and including all anticipated cosmetic exposures and all other exposures for which there is reliable information, taking into consideration vulnerable populations such as infants and pregnant women. Safety cannot be substantiated in the absence of data.

Safety substantiation for a cosmetic product must explicitly account for risks posed by impurities, ingredient degradates, and reaction products of ingredients, and must be based on an assessment of risk that incorporates 1) information about product use patterns including among vulnerable populations such as infants and pregnant women; and 2) analysis of the cumulative effects of ingredients, impurities, ingredient degradates, and reaction products of ingredients with common health effects or target organs. In the case of threshold effects, an additional ten-fold margin of safety shall be applied in assessments of risk for pre- and post-natal toxicity for infants and pregnant women. A different margin of safety may be used only if, on the basis of reliable data, such a margin will be safe for infants and pregnant women.

(Gold Member status - requires full compliance; Full Member and Associate status - if all studies conducted, used, or reviewed to substantiate safety, including safety dossiers required by Personal Care Product Council, are not made publicly available, company must submit to Campaign a full list of studies used to assess product or ingredient safety; and documentation of request to ingredient supplier to provide and make public all available safety studies, and response to request.)

Provision 6. Participate in the Campaign for Safe Cosmetics

Companies must be active participants in the Campaign for Safe Cosmetics, engaging in at least one Campaign activity annually. Qualifying activities include attending Campaign forums, participating in informational briefing calls, providing product data or survey responses, or participating in any other Campaign-sponsored event. Compliance with this provision also requires that a company official submit annually a signed statement of certification indicating compliance with the Compact, and a completed Compact compliance questionnaire, to the Campaign for Safe Cosmetics director. (Required for Gold Member, Full Member, and Associate status.)