OUR RESTRICTED SUBSTANCES STANDARD

INGREDIENTS WE CHOOSE NOT TO USE

Every cosmetic product sold in the European Union must comply with Regulation (EC) No 1223/2009. At The Today Project, regulatory compliance is our starting point—not the limit of our formulation criteria.

Our voluntary Restricted Substances Standard applies additional screening based on regulatory classification, scientific assessment, intended use and exposure, raw-material purity, environmental fate and our own formulation principles.

Some substances included in this standard are prohibited or restricted by law. Others are legally permitted in cosmetics but fall outside the deliberately limited palette we choose to formulate with. Their inclusion does not mean that every authorised use is unsafe; it means that we have chosen to apply additional precautionary, environmental or formulation criteria.

The standard is reviewed as legislation, scientific opinions and regulatory classifications evolve.

AUTOMATIC EXCLUSIONS UNDER OUR STANDARD

We also assess the foreseeable presence of restricted substances through raw-material specifications, supplier declarations and, where appropriate, analytical verification. “Without intentionally added” does not mean that technically unavoidable traces can never occur.

Our formulas are designed without intentionally added substances belonging to the following categories:

  • Substances prohibited under Annex II of the EU Cosmetics Regulation.

  • Substances classified as carcinogenic, mutagenic or toxic to reproduction—CMR categories 1A, 1B or 2—under the CLP Regulation.

  • Substances included on the current ECHA Candidate List of Substances of Very High Concern (SVHC).

  • Substances formally identified as persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), or as endocrine disruptors for human health or the environment under applicable EU chemical regulations.

  • Intentionally added per- and polyfluoroalkyl substances (PFAS).

  • Ingredients and fragrance materials excluded under our internal Restricted Substances Standard.

OUR REGULATORY WATCHLIST

Inclusion on a monitoring or assessment list does not automatically establish that a substance is unsafe in every use. It triggers an internal review considering the quality of the evidence, intended use, exposure, concentration, vulnerable users and the availability of suitable alternatives.

We continuously monitor substances undergoing scientific or regulatory evaluation, including:

  • ECHA endocrine-disruptor assessments and regulatory activity.

  • Harmonised classification proposals under CLP.

  • SCCS opinions concerning cosmetic ingredients.

  • CMR Omnibus updates to the EU Cosmetics Regulation.

  • Substances prioritised or assessed by ANSES for potential endocrine-disrupting properties.

  • New REACH restrictions and updates to the ECHA Candidate List.

  • Names:

    Paraffinum Liquidum / Mineral Oil / Petrolatum / Paraffin / Cera Microcristallina / Microcrystalline Wax / Ozokerite / Petroleum-derived isoparaffins and hydrocarbon waxes

    Why we choose not to use them:

    Cosmetic-grade mineral oils and petrolatum authorised in the European Union are highly refined and must comply with applicable purity requirements. We do not describe compliant cosmetic-grade materials as inherently unsafe.

    We exclude them as a voluntary formulation and ecodesign choice because they are generally derived from non-renewable fossil feedstocks and do not align with our preference for renewable, traceable alternatives when these can provide equivalent cosmetic performance.

    Environmental behaviour varies according to the composition and grade of each hydrocarbon, so our decision is based on origin, renewability and formulation philosophy rather than a generalised toxicity claim.

  • Why: Cocamidopropyl betaine, when used in formulations that also contain nitrosating agents (such as certain preservatives or impurities), may lead to the formation of nitrosamines—compounds that are potentially carcinogenic. This risk is particularly relevant under acidic conditions, which favor nitrosamine formation. For this reason, careful formulation and purity control are essential to minimize the presence of secondary amines and nitrosating substances in cosmetic and personal care products.

    It is advisable to avoid combining this substance with ingredients or preservatives that contain nitrites—such as diazolidinyl urea, imidazolidinyl urea, and sodium nitrite—as well as with diethanolamine (DEA) and triethanolamine (TEA). Other substances that should not be used in combination with nitrites include: cocamide DEA, TEA-lauryl sulfate, lauramidopropyl betaine (LAPB), sodium cocoyl alaninate, and sodium cocoyl sarcosinate.

  • Names: Polyquaternium-7, Polyquaternium-10, Polyquaternium-37, etc.

    Why:

    Synthetic origin and low biodegradability
    Most polyquaterniums are derived from petrochemicals and are not readily biodegradable, raising environmental concerns—especially for rinse-off products that enter wastewater systems directly.

    Environmental persistence and aquatic toxicity
    Their cationic nature makes them prone to binding with negatively charged particles in the environment, potentially leading to accumulation in aquatic ecosystems and harm to aquatic organisms.

  • Names: Perfluorooctyl Triethoxysilane / Perfluorononyl Dimethicone / Perfluorodecalin / Perfluorohexane / PTFE (Polytetrafluoroethylene) / Polyperfluoromethylisopropyl Ether / Perfluoropolyether

    Why:

    Environmental persistence
    PFCs are extremely resistant to degradation, earning them the nickname “forever chemicals.” They persist in soil, water, and living organisms.

    Bioaccumulation and toxicity
    These compounds can bioaccumulate in the human body and wildlife, and some (like PFOA and PFOS) have been linked to hormonal disruption, immune system effects, and certain cancers.

    Regulatory scrutiny
    Many PFCs are under increasing regulatory pressure, especially in the EU, where several have been restricted or banned due to health and environmental risks.

  • Names: EDTA, Disodium EDTA, Trisodium EDTA, Calcium Disodium EDTA

    Why: Is a ghelating agent – used to bind metal ions and prevent instability or degradation in cosmetic formulas. EDTA is not readily biodegradable and is poorly broken down in wastewater treatment plants, leading to environmental persistence.

  • Why: A widely used preservative in cosmetics due to its broad-spectrum antimicrobial activity and good stability. However, it does not align with the principles of green chemistry, and its use raises several concerns from both environmental and process perspectives. Phenoxyethanol is synthetically produced by reacting ethylene oxide with phenol—two substances of petrochemical origin. While phenoxyethanol is moderately biodegradable, it still poses toxicity risks to aquatic organisms in higher concentrations.

  • Names: Diisononyl phthalate (DINP) / Diisodecyl phthalate (DIDP) / Di-n-octyl phthalate (DNOP) / Dibutyl phthalate (DBP) / Diethyl phthalate (DEP)

    Why: Phthalates are most commonly used in synthetic fragrances as fixatives—to help the scent last longer on the skin or in the air. They may also be used in nail polishes, hair sprays, and other flexible or film-forming cosmetic products.

    Environmental impact
    persistent in the environment toxic to aquatic life bioaccumulative in some cases.

    Regulatory status
    Several phthalates, such as dbp and dehp, are banned or heavily restricted in cosmetics in the eu, california (prop 65), and other markets.

    Health Concerns
    Certain phthalates—particularly DEP, DBP, and DNOP—have been identified as potential endocrine disruptors, meaning they may interfere with the body’s hormonal system linked to reproductive toxicity possible impacts on fetal development associated with hormonal imbalance and fertility issues in both men and women.

  • Names: Cera alba (beeswax), lanolin, mel (honey), carmine, emu oil, squalane (animal origin), collagen, keratin (animal origin).

    Why: These ingredients are traditionally used in cosmetics for their emollient, pigmenting, or texturizing properties. However, at The Today Project, our commitment to vegan cosmetics means we do not use any animal-derived ingredients in our formulas.

  • Names: Polysorbate-80, Polysorbate-60, Polysorbate-20

    Why:

    They are not biodegradable, and their breakdown products may pose environmental risks. They are produced through a process called ethoxylation, which involves ethylene oxide, a carcinogenic petrochemical. During this process, 1,4-dioxane, a potential human carcinogen, can be formed as an unintended byproduct, contaminating the final ingredient. Due to their toxic precursors, synthetic origin, and potential impurities, ethoxylated ingredients are incompatible with green chemistry and sustainable formulation standards.

  • Names: Imidazolidinyl urea, Diazolidinyl urea, 5-Bromo-5-nitro-1,3-dioxane, 2-Bromo-2-nitropropane-1,3-diol, DMDM Hydantoin, Sodium Hydroxymethylglycinate

    Why: they can release formaldehyde over time in the formula. Formaldehyde is a known human carcinogen and a strong irritant to the skin, eyes, and respiratory system. While formaldehyde-releasing agents are allowed in cosmetics within certain concentration limits, there is growing concern about cumulative exposure from multiple products and its potential long-term health risks.

  • Names: Polyethylene (PE), Polymethyl Methacrylate (PMMA), Nylon-12, Polypropylene (PP), Polyethylene Terephthalate (PET), Polystyrene (PS), etc

    Why: Although microplastics are now officially restricted under EU Regulation 2023/2055, their sale and use are still permitted in many cosmetic products for several more years:

    • Rinse-off cosmetics (like scrubs, cleansers, toothpaste): allowed until October 2027

    • Leave-on cosmetics (like creams and lotions): allowed until October 2029

    • Makeup, lip, and nail products: allowed until October 2035, with mandatory labeling starting in 2031

    Despite this regulatory flexibility, we have chosen to eliminate all microplastics from our formulas immediately—across all categories. Lack of biodegradability: Microplastics do not break down naturally and accumulate in the environment.

    • Environmental contamination: They persist in aquatic and terrestrial ecosystems, harming marine life and potentially entering the human food chain.

    • Soil degradation: Their presence affects the microbiome and health of soils, impacting agriculture and biodiversity.

    • Cumulative risk: Even if present in small amounts, their repetitive use across multiple products and long-term persistence pose real ecological threats.

  • Regulatory Timeline in the EU

    Until 2011 - Parabens were widely used in cosmetics without restriction, considered safe, effective, and broad-spectrum preservatives.

    2011 – First regulatory review (SCCS/1348/10)

    The EU’s Scientific Committee on Consumer Safety (SCCS) reviewed propylparaben and butylparaben for their potential as endocrine disruptors.

    • Concluded they were safe within specific limits, but raised concerns for infants and young children.

    • Marked the beginning of differentiated regulation.

    2014 – First bans (Regulation EU No. 358/2014)

    The EU fully banned five long-chain parabens due to insufficient toxicological data and potential hormonal effects:

    • Isopropylparaben

    • Isobutylparaben

    • Phenylparaben

    • Benzylparaben

    • Pentylparaben

    Restrictions tightened for:

    • Propylparaben & Butylparaben Max. combined limit: 0.14% (as acid). Banned in leave-on products used in the diaper area for children under 3 years old

    Why: While some parabens (like methyl- and ethylparaben) are legally permitted and even biodegradable, they are not aligned with green chemistry principles due to:

    • Synthetic origin (petrochemical-derived)

    • Concerns about endocrine disruption

    • Cumulative exposure through multiple products

    • Environmental toxicity (especially for aquatic life)

  • Names: Dimethicone / Dimethiconol / Amodimethicone / Cetearyl Methicone / Stearoxy Dimethicone / Behenoxy Dimethicone Cyclopentasiloxane (D5 / Cyclohexasiloxane (D6) / Cyclotetrasiloxane (D4) / Cyclomethicone

    Why:

    • Petrochemical origin
      Silicones are synthetic compounds derived from petroleum and silicon, making them non-renewable and incompatible with green chemistry principles.

    • Limited biodegradability
      Many silicones, especially cyclic variants (D4, D5, D6), are not readily biodegradable and persist in aquatic environments, raising concerns about their impact on marine ecosystems.

    • Environmental emissions
      The production and use of volatile silicones (like cyclopentasiloxane/D5) can release methylsiloxanes into the atmosphere, contributing to environmental persistence and potential bioaccumulation.

    • Under regulatory scrutiny
      While not yet strictly regulated, D4 and D5 are already restricted in rinse-off products in the EU due to environmental risks. Ongoing evaluations may lead to further bans or limitations.

  • Names: Sodium Lauryl Sulfate (SLS) / Sodium Laureth Sulfate (SLES) / Ammonium Lauryl Sulfate (ALS) / Ammonium Laureth Sulfate (ALES) / TEA-Laureth Sulfate / Sodium Myreth Sulfate

    Why:

    Sodium Lauryl Sulfate (SLS) and Sodium Laureth Sulfate (SLES) are widely used surfactants in shampoos and cleansers due to their strong cleansing power and foaming ability. However, we choose to exclude them from our formulas for several important reasons:

    Not suitable for treated or fragile hair

    Sulfates are known to strip natural oils and compromise the protective barrier of the scalp and hair, which makes them especially unsuitable for color-treated, bleached, chemically straightened, or sensitive hair. They can lead to dryness, brittleness, and accelerated fading of color.

    Possible contamination with 1,4-dioxane

    While SLS is not ethoxylated, SLES is produced via ethoxylation, a chemical process that can lead to contamination with 1,4-dioxane, a potential human carcinogen. This compound is not added intentionally but can remain in trace amounts unless specifically removed through purification.

    Environmental concerns

    Sulfates are often not readily biodegradable, raising concerns about their impact on aquatic ecosystems after rinse-off.

  • Names: Methylisothiazolinone (MIT) / Methylchloroisothiazolinone (CMIT) / Benzisothiazolinone (BIT) / Octylisothiazolinone (OIT) / Chloromethylisothiazolinone

    Why:

    • High sensitization potential:
      They are well-documented skin allergens and have been linked to irritation, contact dermatitis, and allergic reactions, especially in leave-on products.

    • Regulatory restrictions:
      In the EU, the use of MIT and CMIT in leave-on cosmetics has been banned due to safety concerns, and their use in rinse-off products is strictly limited in concentration.

    • Still used in cleaning products:
      Despite restrictions in personal care, isothiazolinones remain common in household cleaning products, posing a risk of cumulative exposure, especially for individuals with sensitive skin or respiratory issues.

    • Environmental concerns:
      These substances are toxic to aquatic life and not readily biodegradable, raising issues of bioaccumulation and ecosystem disruption.

    • Triclosan is currently allowed only in rinse-off cosmetics (e.g., soaps, shampoos) and specific products like toothpaste, deodorants, and nail cleaners. - Maximum approved concentration: 0.3% . New restrictions effective Dec 31, 2024 for products placed on the market, with full compliance required by Oct 31, 2025.

    • Triclocarban isPermitted in rinse-off cosmetics up to 1.5% and in leave-on products up to 0.2%, with strict purity and labeling requirements. Same December 2024–October 2025 deadlines apply.

    Why:

    Bacterial resistance

    • Continued use contributes to antibiotic-resistant pathogens in both clinical and environmental settings, reducing the effectiveness of important antibiotics.

    Environmental toxicity

    Health risks

    • Linked to endocrine disruption, skin irritation, and potential long-term toxicity concerns.

  • Names: Monoethanolamine (MEA) / Diethanolamine (DEA) / Triethanolamine (TEA)

    Why: Nitrosamine formation
    In the presence of nitrites, ethanolamines can form nitrosamines, which are classified as potential human carcinogens.
    Sources of nitrites in cosmetics may include:

    • Formaldehyde-releasing preservatives (e.g., DMDM hydantoin, imidazolidinyl urea)

    • Ethoxylated surfactants (with impurities)

    • Poorly purified botanical extracts

    • Ingredient degradation over time

    • Environmental concerns
      While ethanolamines may biodegrade in soil and freshwater, they are not readily biodegradable in marine environments, raising concerns about marine persistence and toxicity.

    • Regulatory scrutiny
      Due to the potential formation of carcinogenic byproducts, ethanolamines are restricted or discouraged in many clean beauty standards, especially when used in combination with nitrosating agents.