Green Seal Certification: Ensuring Safety and Sustainability in Personal Care and Cosmetic Packaging

Green Seal stands as a non-profit powerhouse dedicated to fostering a more sustainable world through science-backed programs. This organization sets rigorous leadership standards aimed at minimizing environmental, health, and social impacts throughout the entire lifecycle of products, services, and companies. These standards serve various crucial purposes, from conformity assessment to guiding purchaser specifications and empowering public education.

Green Seal provides a trusted certification for products, services, and companies that meet their stringent criteria. For those seeking deeper insights into Green Seal and how to connect with them, their website, greenseal.org, offers comprehensive information.

Delving into Green Seal Standards: A Commitment to Excellence

Foreword: The Evolution of Green Seal Standards

The current Edition 1.3 of these standards, updated on June 23, 2022, represents Green Seal’s ongoing commitment to improvement, superseding Edition 1.2 from April 8, 2020. Regular updates and clarifications ensure the standards remain at the forefront of best practices, with the latest adjustments made on August 23, 2024. Detailed information regarding these revisions is readily available on Green Seal’s website, under the Library of Standards Documents.

These standards are the result of a transparent and inclusive development process. Green Seal actively engages with stakeholders from all sectors, including producers, users, and those representing general public interests, to ensure a balanced and effective framework.

The core requirements within these standards are rooted in a thorough evaluation of the environmental, health, and social consequences associated with the products, services, and organizations they cover. These requirements are dynamic, subject to updates, and typically exceed basic regulatory compliance. It is crucial to understand that Green Seal standards complement, not replace, existing laws and regulations. Achieving certification requires full adherence to all applicable legal and regulatory frameworks governing product manufacturing and marketing.

While safety is paramount, Green Seal standards focus on environmental and social impacts, recognizing that regulatory agencies are primarily responsible for overseeing safety provisions. However, Green Seal emphasizes the importance of robust safety measures at all production stages and during any testing procedures with safety implications.

Products, services, or organizations with similar functions and lifecycle considerations to those explicitly covered may still be evaluated against the spirit of these standards. Green Seal maintains flexibility to account for variations between the standard’s intended scope and the specific item being assessed.

Green Seal acknowledges the dynamic nature of product development. Should a product feature emerge that unexpectedly and significantly increases its negative environmental, health, or social footprint, Green Seal is committed to amending its standards to address these unforeseen impacts.

References to external standards within Green Seal documents are intended to refer to the most current edition of those standards. Product evaluations may necessitate specific test methods. While certain methods might be specified, Green Seal retains the discretion to accept equivalent test methods, ensuring flexibility and practicality in the certification process.

Crucially, certification to Green Seal standards is exclusively granted by Green Seal itself. Third-party certification programs may only conduct on-site audits with explicit written permission from Green Seal, maintaining the integrity and consistency of the certification process.

Disclaimer of Liability: It’s important to note that Green Seal, as the standard developer, disclaims any liability for losses or damages arising from the interpretation, adoption, reliance on, or any other use of these standards by any party. Green Seal provides no express or implied warranties, including merchantability or fitness for a particular purpose, in relation to these standards.

Acronyms and Abbreviations: Understanding the Language of Certification

To ensure clarity and avoid ambiguity, Green Seal standards employ a defined set of acronyms and abbreviations. These include:

  • ACGIH: American Conference of Governmental Industrial Hygienists
  • ANSI: American National Standards Institute
  • AOEC: Association of Occupational and Environmental Clinics
  • BCF: Bioconcentration Factor
  • BOD: Biochemical oxygen demand, also known as Biological Oxygen Demand
  • BTU: British thermal unit
  • CFC: Chlorofluorocarbon
  • CFR: Code of Federal Regulations
  • CO2: Carbon dioxide
  • DFG: German Deustche Forschungsgemeinschaft
  • EPA: United States Environmental Protection Agency
  • FD&C: Food, Drug, and Cosmetic
  • FDA: The United States Food and Drug Administration
  • GHS: Globally Harmonized System for the Classification and Labeling of Chemicals
  • INCI: International Nomenclature of Cosmetic Ingredients
  • ISO: International Organization for Standardization
  • LLNA: Local Lymph Node Assay
  • LOAEL: Lowest-Observed Adverse Effect Level
  • MAK: Maximum Allowable Concentrations
  • NOAEL: No-Observed Adverse Effect Level
  • NSF: NSF International
  • OECD: Organization for Economic Co-operation and Development
  • OPPTS: Office of Prevention, Pesticides and Toxic Substances
  • OTC: Over The Counter
  • PPM: Parts per million
  • SPF: Sun Protection Factor
  • ThOD: Theoretical oxygen demand
  • TLV: Threshold Limit Value
  • USDA: United States Department of Agriculture
  • UVA: Ultraviolet A rays/radiation
  • UVB: Ultraviolet B rays/radiation
  • VOC: Volatile Organic Compound

1.0 Scope: Defining Personal Care and Cosmetic Products within Green Seal Standards

This Green Seal standard sets forth environmental, health, and social benchmarks for a wide array of products designed to enhance personal appearance, cleanliness, health, well-being, and the feel of skin and hair. These are products intended to remain on the body and hair after application. Examples include lotions, hair sprays, hair styling aids, sunscreens, nail polish, insect repellents, makeup, antiperspirants, and deodorants. The standard applies to products for adults, babies, and children, whether for personal, institutional, or professional use. Appendix 1 provides an illustrative list of products falling under this standard.

Notably, this standard excludes fragrance products (like perfumes and colognes), tattoo products, hair dyes and permanent/relaxer treatments, oral hygiene items (such as mouthwash and toothpaste), and products meant to be rinsed off (like soaps and shampoos). Products designed to be rinsed off are addressed under the Green Seal Standard for Soaps, Cleansers, and Shower Products, GS-44.

Words and phrases presented in italics throughout this document are formally defined in Annex A, the glossary section of the standard.

2.0 Safer Chemicals: Prioritizing Health and Environmental Well-being

2.1 Safer Ingredients: A Foundation of Responsible Chemistry

2.1.1 Aquatic Biodegradability: Green Seal emphasizes the importance of biodegradability. Individual organic compounds present at 0.01% or more in rinse-off products must demonstrate ready biodegradability according to OECD definitions. Polymers, chelating agents, and colorants are exceptions. Biodegradability is assessed using ISO or OECD test methods. For compounds not readily biodegradable, sewage treatment plant biodegradability can be demonstrated via the OECD 303A Coupled Units Test, achieving >90% DOC removal. Exceptions are made for compounds with low aquatic toxicity and inherent biodegradability.

2.1.2 Bioaccumulating Compounds: To prevent environmental harm, products cannot contain components at 0.01% or more that bioaccumulate or form bioaccumulative degradation products. A BCF ≥ 500 or log Kow ≥4 defines bioaccumulation. OECD TG 305 is the preferred data source. Biodegradable chemicals (meeting 2.1.1) are considered non-bioaccumulating.

2.1.3 Biocides: Biocides are restricted to product preservation purposes only, with dosage justification required. Deodorants and antiperspirants are permitted to include biocides for functions beyond preservation.

2.1.4 Carcinogens and Reproductive Toxins: Green Seal prohibits carcinogens and reproductive toxins in undiluted products, including components that produce or release them. Titanium dioxide and essential vitamins/minerals (within tolerable upper limits) are exceptions.

2.1.5 Colorants: Generally prohibited, colorants are allowed in makeup, nail polish, and sunless tanning products.

2.1.6 Components That Cause Asthma: Asthmagens are forbidden in undiluted products, except for zinc oxide.

2.1.7 Endocrine Disruptors: Components on the EPA Tier 1 Screening List shown to disrupt hormones are prohibited in undiluted products.

2.1.8 Formula Disclosure for Certification: Transparency is key. Certification requires full formula disclosure, including chemical names, CAS numbers, and percentage by weight of each component.

2.1.9 Fragrances: Fragrance components must adhere to the International Fragrance Association (IFRA) code of practice.

2.1.10 Makeup and Nail Polish Lead Contamination Limits: Lead content in undiluted makeup and nail polish must not exceed 0.05 ppm.

2.1.11 Mutagens and Neurotoxins/Systemic Toxins: Mutagens and neurotoxins/systemic toxins are prohibited in undiluted products, except for essential vitamins/minerals within tolerable upper limits.

2.1.12 Nanoscale Components: Nanoscale components are allowed only with European Commission Scientific Committee on Consumer Safety approval. If approved, products must label the component as “nanoscale” or “nanoparticle.”

2.1.13 Ozone Depleting Compounds: Ozone-depleting compounds are strictly prohibited in undiluted products.

2.1.14 Per- and Polyfluoroalkyl Substances (PFAS): PFAS chemicals are prohibited from undiluted products due to their environmental persistence and potential health concerns.

2.1.15 Prohibited Components: A comprehensive list of prohibited components includes substances like 2-butoxyethanol, alkylphenol ethoxylates, parabens, phthalates, and triclosan, reflecting Green Seal’s commitment to eliminating harmful substances.

2.1.16 Respiratory Sensitization: Respiratory sensitizers are not permitted in undiluted products.

2.1.17 Skin Absorption: Components with ACGIH or DFG skin notations are restricted, aiming to minimize skin absorption of harmful substances.

2.1.18 Skin and Eye Corrosion and Irritation:

2.1.18.1 Skin and Eye Corrosion: Undiluted products must not cause skin corrosion or serious eye damage. Component data at ≥0.01% is evaluated. Products with pH ≤2 or ≥11.5 are considered corrosive unless proven otherwise.

2.1.18.2 Skin Irritation: Undiluted products must not cause skin irritation. Component data at ≥5% is evaluated.

2.1.19 Skin Sensitization: Undiluted products must not be skin sensitizers. Component data at ≥0.01% is assessed.

2.2 Safer Products: Ensuring Product Safety and Environmental Protection

2.2.1 Acute Toxicity: Products must not be acutely toxic to humans, evaluated using LD50 and LC50 data for components at ≥0.01%.

2.2.2 Eutrophication: Phosphorus content in undiluted products is limited to 0.2% by weight to prevent water pollution.

2.2.3 Toxicity to Aquatic Life: Rinse-off products must not be toxic to aquatic life (LC50 ≥100 mg/L for fish, daphnia, and/or algae). Weighted averages are calculated using component data at ≥0.01%.

2.2.4 Chronic Aquatic Toxicity: Rinse-off products must not contain components at ≥0.01% with chronic aquatic toxicity. OECD TG data is preferred; GHS guidelines are used if data is lacking.

2.2.5 Volatile Organic Compound (VOC) Content:

2.2.5.1 Total VOC Content: VOC content in undiluted products must not exceed CARB regulatory limits or specific percentage limits (e.g., 35% for astringents/toners, 55% for hair spray, 1% for other products), whichever is stricter. VOC content is determined by summing contributions from organic components with vapor pressure >0.1 mm Hg or using CARB Method 310.

2.2.5.2 High and Medium Volatility Organic Compound Content: Antiperspirants and deodorants must meet CARB regulations for high and medium VOCs.

2.2.6 Sunscreen:

2.2.6.1 Enhanced Sensitivity to UV: Sunscreens must not contain components that increase skin’s UV sensitivity, such as alpha hydroxy acids and retinoids.

2.2.6.2 Product Form: Sunscreens cannot be sold as powders or in pump spray packages.

2.2.7 Insect Repellent: Insect repellent should not be combined with sunscreen in a single product.

2.2.8 Animal Testing: Animal testing for standard compliance is prohibited. Existing data and alternative testing methods are prioritized.

3.0 Responsible Sourcing: Ethical and Sustainable Material Procurement

3.1 Disposable Wipes: Promoting Renewable and Recycled Materials

Products with disposable wipes must use 100% renewable materials, primarily cellulosic, and incorporate state-of-the-art levels of recovered material content.

4.0 Low-Impact Manufacturing: Environmentally Conscious Production

4.1 Social Responsibility: Upholding Ethical Labor Practices

Product manufacturing must meet social responsibility standards, ensuring:

4.1.1 Freedom of Association and Collective Bargaining: Workers’ rights to unionize and bargain collectively must be respected.

4.1.2 Freedom of Labor: Forced, bonded, and child labor are strictly prohibited.

4.1.3 Freedom from Discrimination: Discrimination based on race, color, sex, religion, age, disability, and other factors is forbidden. Corporal punishment, harassment, and exploitation are not tolerated.

4.1.4 Occupational Health and Safety: Safe, hygienic workplaces with potable water and safety training are mandatory.

4.1.5 Conditions of Employment: Fair wages, working hours meeting national standards, and regular employment must be provided.

5.0 Sustainable Packaging: Minimizing Environmental Footprint

5.1 Packaging Materials: Reducing Waste and Promoting Recycling

5.1.1 Source Reduction in Packaging: Primary and secondary packaging must be source-reduced, recyclable with post-consumer recycled content (at least 25% or maximum feasible amount), part of a take-back program, or contain at least 50% post-consumer material. Alternative approaches with similar lifecycle benefits may be accepted.

5.1.2 Concentrated Product Packaging: Concentrates cannot be packaged in ready-to-use forms.

5.1.3 Aerosol Packaging: Aerosol packages are prohibited due to environmental concerns.

5.1.4 Pump Spray Packaging: Pump spray packages are prohibited for antiperspirants, deodorants, sunless tanning products, and sunscreens, with exemptions for aluminum-free and titanium dioxide-free antiperspirants/deodorants.

5.2 Packaging Label: Guiding Consumers Towards Responsible Use

5.2.1 Use Labeling: Detailed instructions for proper product use and waste minimization are required.

5.2.2 Resin Identification Code: Plastic packaging must be marked with resin identification codes for recycling. Recyclability qualifications are needed if recycling is limited geographically.

5.3 Restricted Substances: Eliminating Harmful Materials in Packaging

5.3.1 Heavy Metal Restrictions: Intentional introduction of heavy metals (lead, mercury, cadmium, hexavalent chromium) in packaging and applicators is prohibited. Total concentration must not exceed 100 ppm, with exceptions for refillable packages or those using recovered materials.

5.3.2 Other Restrictions: Phthalates, bisphenol A, and chlorinated packaging materials are prohibited from intentional introduction, with exceptions similar to heavy metals for recovered materials.

6.0 Verified Performance and Claims: Ensuring Product Efficacy and Transparency

6.1 Product Performance: Meeting Functional Expectations

Products must demonstrate satisfactory performance for their primary characteristics (Appendix 2), verified through objective testing, comparative testing, or consumer testing (Annex B).

6.1.1 Antiperspirant: Antiperspirants must achieve at least a 20% sweat reduction per FDA guidelines.

6.1.2 Insect Repellent: Insect repellents must use EPA-registered active ingredients or meet EPA OPPTS guidance for minimum risk pesticides.

6.1.3 Sunscreen:

6.1.3.1 Sun Protection Factor (SPF): Sunscreens must achieve an SPF of 15 or higher (21 CFR 352).

6.1.3.2 Broad Spectrum: Sunscreens must meet European Commission recommendations for UVA protection.

6.1.3.3 Photostability: Sunscreens must maintain at least 80% of their sun protection after 120 minutes of UV radiation exposure.

6.2 Product Label: Providing Essential Information to Consumers

6.2.1 Ingredient Line: Ingredients must be listed using INCI names in descending order of predominance. Fragrance can be listed as “fragrance.”

6.2.1.1 Nanoscale Component Labeling: Nanoscale components must be labeled as “nanoscale” or “nanoparticle.”

6.2.1.2 Consumer Communication: Ingredient lists must be accessible to consumers beyond the product label, such as on company websites.

6.2.2 Precautionary Statements: Products with components increasing UV sensitivity (e.g., alpha hydroxy acids, retinoids) must include sun damage warnings and sun protection advice.

6.2.3 Small Packages: Small packages (<⅛ fl oz) are exempt from full labeling if information is available elsewhere (e.g., website).

6.2.4 Disposal Labeling: Proper disposal instructions, including recycling guidance, are mandatory.

6.2.5 Efficacy Labeling:

6.2.5.1 Antiperspirant Efficacy Labeling: Antiperspirant effectiveness claims must meet FDA guidelines.

6.2.5.2 Insect Repellent: Insect repellent labels must indicate protection time per EPA OPPTS guidelines.

6.2.5.3 Sunscreen Efficacy Labeling: “Broad spectrum” claims are permitted for compliant sunscreens.

6.2.6 Claims and Transparency:

6.2.6.1 Antimicrobial Claims: Antimicrobial, disinfecting, antiseptic, or sanitizing claims are generally prohibited, except for deodorants and antiperspirants.

6.2.6.2 Organic Claims: Organic claims must be based on certified-organic content and meet USDA NOP or equivalent standards.

6.2.6.3 Natural and Biobased Claims: “100% Natural/Biobased” claims require 100% natural/biobased content (excluding water). “Natural/Biobased” claims require at least 95% natural/biobased content (excluding water). Component-specific claims are allowed if accurate.

6.2.6.4 Fragrance and Allergen Labeling: Labels must declare fragrance addition or absence and indicate allergen components.

7.0 Trademark Use Requirements: Maintaining Green Seal Brand Integrity

7.1 Trademark Use: Adherence to Green Seal Guidelines

Use of the Green Seal® Certification Mark and name must comply with Green Seal’s Trademark Use Guidelines to ensure proper representation and brand protection.

7.2 Misleading Claims: Preventing Consumer Deception

Green Seal trademarks cannot be used with misleading modifiers or graphics that misrepresent the certification’s scope or nature, maintaining consumer trust and the value of the Green Seal.

(Annex A – Definitions and Annex B – Guidelines for Performance Testing, and Appendices 1-3 are included in the original document for detailed reference.)

This revised article aims to enhance the original document by providing a more structured and accessible explanation of Green Seal standards, focusing on the key aspects relevant to personal care and cosmetic product packaging while implicitly touching upon the importance of clear product information – a form of “product coding” – for consumer understanding and trust in certified products. The emphasis throughout is on safety, sustainability, and responsible manufacturing practices within the personal care and cosmetics industry.

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