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Why #USEtox should not be used in isolation to inform consumers about the #sustainability of a #cosmetic product.

A large consortium of cosmetics companies, supported by Quantis, has just published the Eco-Beauty Score (EBS) methodology. The aim of this new 'Eco-score' is to enable consumers to make more informed and sustainable choices. The public consultation closes on 9 May 2024.


This eco-score is based exclusively on the European approach, the Product Environmental Footprint (#PEF). This is a life cycle assessment (#LCA) method used to evaluate the environmental footprint of a product placed on the market, by calculating 16 impact categories (climate change, acidification, human toxicity, aquatic toxicity, ozone layer, eutrophication, use of resources, etc.).


The LCA approach is ideal for considering resource consumption and all the pollutant emissions that occur during all phases of the cycle. Roughly speaking, for a traditional LCA, we are talking about several hundred chemical substances emitted to each air, soil and water compartment, which will contribute to the calculation of the +/- 16 impact categories.


The #USEtox method is used to calculate the aquatic toxicity and human health score. This is done using characterisation factors[1] specific to each substance emitted.


According to its authors, USEtox makes it possible to identify the 10-20 substances, out of a list of several hundred, that could pose problems for aquatic ecosystems and human health. 


So far, so good. However, this is not enough to determine whether the formula used for a cosmetic product is sustainable (i.e. environmentally friendly).


The LCA and USEtox approach does not ;

  1. Identify problematic ingredients: these will rarely appear in the list of 10-20 substances identified by USEtox (their mass being negligible compared with the hundreds of substances emitted over the entire life cycle).

  2. Identify substances classified by European regulations as hazardous to human health and the environment (for those in the know: SVHC, PBT vPvb, carcinogenic, mutagenic, etc.)

  3. To conclude whether a formula is more respectful of human health and the environment. Direct toxicity - when the product is used - is not taken into account in the model, nor is the local environmental impact when effluent from treatment plants (if any!) is discharged into the adjacent river or lake.

  4. To conclude on the level of biodegradability of the formula.

  5. To conclude on the naturality and traceability of the ingredients.


Relying solely on an LCA and USEtox approach means labelling products as 'sustainable', whereas 'Ecolabel' type schemes will say exactly the opposite. This not only confuses the consumer but also runs the risk of undermining the credibility of these attempts at labelling, which are sorely needed to support more sustainable consumption.


If you are interested in this post and would like to find out more, please do not hesitate to contact me:



You can also read my publications on the subject:


1.     Sala, S., Biganzoli, F., Mengual, E. S. & Saouter, E. Toxicity impacts in the environmental footprint method: calculation principles. Int. J. Life Cycle Assess. 27, 587–602 (2022).

2.     Erwan Saouter, Fabrizio Biganzoli, Rana Pant, Serenella Sala, Donald Versteeg: Using REACH for the EU Environmental Footprint: building a usable ecotoxicity database (part I). Integrated Environmental Assessment and Management 05/2019;, DOI:10.1002/ieam.4168

3.     Erwan Saouter, Deidre Wolff, Fabrizio Biganzoli, Donald Versteeg: Comparing options for deriving chemical ecotoxicity hazard values for the EU Environmental Footprint (part II). Integrated Environmental Assessment and Management 05/2019;, DOI:10.1002/ieam.4169

4.     Erwan Saouter, An De Schryver, Rana Pant, Serenella Sala: Estimating chemical ecotoxicity in EU ecolabel and in EU product environmental footprint. Environment International 09/2018; 118., DOI:10.1016/j.envint.2018.05.022

5.     Saouter, E. G., Perazzolo, C. & Steiner, L. D. Comparing chemical environmental scores using USEtoxTM and CDV from the European Ecolabel. Int. J. Life Cycle Assess. 16, 795–802 (2011). DOI:10.1007/s11367-011-0314-6

6.     Serenella Sala, Assumpcio’ Anton, Sarah J. McLaren, Bruno Notarnicola, Erwan Saouter, Ulf Sonesson: In quest of reducing the environmental impacts of food production and consumption. Journal of Cleaner Production 09/2016; 140., DOI:10.1016/j.jclepro.2016.09.054

[1] The European Commission's research centre - the EU-JRC (Joint Research Centre) - has also built a database for use in PEF analyses. It contains characterisation factors for more than 6,000 substances: The consortium does not seem to want to use this database. What a pity!

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