”For plastic, it is not as black and white as commonly communicated”
ENA IGLEBAEK HERCEGLIJA
On the most frequently asked questions about beauty packaging
January 24, 2024
Who are you?
— I hold a master’s degree in chemical engineering (Molecular Science) from the Royal Institute of Technology in Stockholm, Sweden, and have been a part of consulting firm Toxintelligence’s team for the last 2.5 years.
— Our core purpose is to help companies build long-term, sustainable quality work from a regulatory and a scientific perspective, she explains. The primary focus revolves around regulatory advisory. In practical terms, we assist companies that are seeking to introduce or already market everyday products, such as cosmetics, paints, engine oils, detergents, and food supplements, to meet the necessary regulatory requirements associated with these products.
— As an example, we assess whether your chemical product requires hazard pictograms — the diamond-shaped symbol with a red border and white background — and determine the essential text your label should include to instruct customers on the safe usage of the product. Additionally, we guide companies to communicate about their products transparently and truthfully and use claims that are substantiated by scientific evidence. We’re aiming to create safety and confidence for customers when purchasing everyday products from various brands.
As all cosmetic products introduced to the EU market must undergo safety assessment before launch, the consultancy often works with evaluating the safety of cosmetic products and its packaging. One of the most frequently asked questions is: ”Is this packaging safe to use for our cosmetic product?”
— It’s always answered when the assessment is performed, and a safety report is compiled. The packaging must be compatible with the cosmetic product and without a suitable packaging solution, the product cannot be assessed as safe. Therefore, the choice of packaging material is crucial, considering the cosmetic formula and its parameters including pH, oil content, and solvents This is essential to prevent issues such as substance migration between packaging and formula, unpleasant odour, swelling, leaking, or corrosion, Iglebaek Herceglija says. She continues:
— In most cases, our clients can provide a declaration of conformity stating that the packaging would be suitable even for food storage, which can in principle serve as an indication of the safety of the packaging. However, stability and compatibility testing using the actual cosmetic formula and the intended packaging is crucial to evaluate the safety and detect any issues with the packaging material.
— Another recurring question is: ’Can we write that our packaging is recyclable?’ Then, we always counter-ask if the packaging has been designed to be recyclable. In Sweden, there are clear guidelines on how companies can design their packaging and consider factors such as packaging material, colour, and label material in order to enable it to be recyclable. Composite materials — for example, a blend of several types of plastics — and complex packaging solutions using parts of different materials are challenging to separate which results in non-recyclability. By, for instance, introducing paper pulp to a mono-material plastic film to claim that the packaging contains less plastic and is ’greener’ results in the plastic film being non-recyclable. I would refer to it as greenwashing.
— Last year, we also received numerous questions regarding the national labelling requirements for recyclable packaging in France and Italy. The responses to these questions varied based on the type of packaging material and the amount of packaging components as the purpose of new labelling was to guide the French and Italian consumers on how to sort the packaging. This truly showcased the complexity of unharmonised packaging legislations, particularly when countries within the EU have the flexibility to establish their own national packaging legislation. By the end of the day, these rules are supposed to help the consumers sort packaging waste without being too complicated for both consumers and the companies.
Although Toxintelligence doesn’t conduct any formal life cycle analysis evaluating and quantifying the environmental impact of a specific packaging, Iglebaek Herceglija points out one important thing on the topic.
— It is crucial to note that marketing campaigns presenting a company’s environmental and sustainability work, by using an LCA for example, will be reviewed from a cradle-to-grave perspective by a judge if you end up in a legal process. This means that one cannot selectively present specific parts of the LCA to its customers; instead, the entire life cycle assessment needs to be considered. For instance, saying that a product has been produced in Sweden should not come across as being equal to locally sourced if it truly is not. Considering the origin of the raw material that may have been transported from the other side of the world, before reaching Sweden, is essential.
Is the price always the most important for the clients? Or can other things play a bigger role when choosing packaging?
— The price sensitivity depends on the type of product, the performance required by the packaging, the target group, and the client’s vision for the brand. One can use glass, metal, or plastic — all obtained from finite resources with the property to enclose water. We can also use cellulose or biomass composite materials from renewable resources as packaging material. However, the decision often revolves around the specific properties required by the packaging according to the client and the frequency of product purchases by the consumer.
— As an example, comparing a cardboard with a plastic film packaging for milk to a glass packaging for perfume, it is evident that the perfume packaging is less price-sensitive, given the less frequent purchase of perfumes. Consumers expect a certain level of luxury and density in perfume packaging and are consequently less price-sensitive. Therefore, for cosmetic products, glass remains a popular packaging material, despite being more expensive and requiring substantial energy for production. The target audience’s willingness to pay for a particular packaging material or a specific sensation, such as luxury or innovation, plays a significant role in the choice of packaging.
What’s your view on plastic?
— For plastic, it is not as black and white as commonly communicated. Plastic possesses the capability to contain liquids, is relatively cost-effective in comparison to alternative packaging materials, and is formable, making it suitable for various applications. However, it is evident that we need to reduce the use of virgin plastics to decrease the carbon dioxide emissions associated with plastic production and the combustion of plastics. We need to elevate the use of recycled plastic. A sorting and recycling facility named Site Zero has just been opened by Swedish Plastic Recycling (Svensk Plaståtervinning). It’s designed to sort 12 different types of plastics, an increase from the previous capability of sorting only three. Consequently, the use of post-consumer recycled (PCR) plastic packaging emerges as a promising solution to establish circularity in the plastic industry.
What material innovations for beauty packaging do you see coming?
— We frequently discuss PCR plastic packaging. It seems as if the demand for PCR plastics is great within several sectors, and that it is driven by the emphasis on sustainability and circularity. However, the supply of high-quality PCR plastic is constrained by factors such as limited consumer recycling of plastics, contamination, and inefficiencies in plastic recycling systems at a global level. Additionally, the absence of standardised collection methods further impairs the problem, limiting the potential to meet the growing demand for PCR plastic. Hopefully, we can be a part of the change by just recycling our own packages, Iglebaek Herceglija shares. She adds:
— Yet, innovation does not always have to be the sole solution and sometimes a common-sense approach can also be impactful. For instance, the use of less and thinner packaging material, reduction in the number of packages, and optimisation of packaging usage should be viewed as a way of being innovative.
”In our regulatory world, we are anticipating an EU regulation on packaging and packaging waste”
What’s the biggest topic in packaging for 2024?
— In our regulatory world, we are anticipating an EU regulation on packaging and packaging waste. This is set to be a big topic in 2024. At the moment, a packaging directive is in place which allows countries to independently establish national packaging legislations. Challenges arise from the complexity when each country has their own implementation of the directive. Particularly in areas like labelling requirements has posed challenges for companies, sometimes causing them to overlook certain requirements. Hopefully, the new regulation will establish a harmonised perspective on the use of recycled plastics in packaging, more high-quality recycling systems and reduce the reliance on virgin materials. It will also require an extended producer responsibility (EPR) which determines that the producers of the packaging will be responsible for the costs associated with our take-back systems, Iglebaek Herceglija explains. She adds:
— For us, the regulations evolve constantly, with continuous changes being implemented. Consequently, we stay vigilant and monitor new regulatory adjustments that could impact our clients and ensure they are well-prepared to be proactive rather than reactive.
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