This is an open letter we sent to the Environmental Protection Authority in July 2020 asking them to update their list of banned ingredients to align with best international practices and the latest scientific research.   

Dear Julie,

Protecting consumers from unregulated ingredients in cosmetic products: an open letter calling the EPA to update the list of banned ingredients in the Cosmetic Products Group Standard.

1. I am the founder of Emma Lewisham, a natural skincare business based in Auckland. I write this open letter requesting that you apply to the decision-making Committee of the EPA to update the list of ingredients regulated in cosmetic products.[1] I ask that you prioritise the regulation of 25 ingredients in particular, all currently unregulated in New Zealand.   
   
   
2. In what follows, I set out my background and more details of the change I propose.

The Emma Lewisham story

3. Emma Lewisham is a mission-led skincare business that is centred around people and the planet. The Emma Lewisham story began with my personal quest to combat hyperpigmentation, an issue for 40% of New Zealand women and 62% of Australian women. After months of using a cosmetic product with hydroquinone in it, the then-most common ingredient for hyperpigmentation treatment, I was told by my doctor to discontinue using it while I was pregnant because use of hydroquinone is highly questionable.  I went looking for a natural and science backed solution, only to find that it did not exist.  So I set out to create it.  After many years of innovation and research, I launched the Skin Reset serum which is natural and scientifically proven to outperform the most recognised and luxurious Vitamin C and brightening products on the market.[2]

4. With an expanded skincare range, we continue to work hard to provide natural and high performing skincare. You can read more about our sustainability policy here. 
   
   
5. Emma Lewisham is proud to be redefining standards for the beauty industry, and proud to be New Zealand made. However New Zealand is lagging behind when it comes to regulating the use of harmful ingredients in cosmetics products. Hydroquinone, the very catalyst for the Emma Lewisham brand, continues to be unregulated (except when used in hair dye products) despite being regulated in other jurisdictions like the European Union, Australia and Japan and restricted in Canada. This is only one example. There are over 272 ingredients that are currently regulated in the EU but unregulated in New Zealand. This is concerning given our framework is based on the EU’s and strives to reflect best international practices. 

Our request

6. In keeping with our mission to create meaningful change in the beauty industry, we invite the EPA to update the list of regulated ingredients in New Zealand by reference to the EU’s. Specifically, we ask that you prioritise banning the 25 ingredients listed in Schedule A appended to this letter. These ingredients include hydroquinone, four types of formaldehyde, some of the most toxic parabens and phthalates, and the fluorinated compounds known as PFAS. 
   
   
7. All of these ingredients are banned in the EU.[3] Many of them are also listed in EWG’s unacceptable ingredient list in personal care products[4] and in California’s upcoming cosmetics law reform which regulates highly toxic chemicals.[5]
   
   
8. Our request should be a priority for the EPA. Women use an average of 12 cosmetic products daily, exposing themselves to around 168 different chemicals.[6]  The Group Standard has a crucial role to play in ensuring that the ingredients in those products are safe.

Conclusion

9. As the founder of a skincare business, I believe the proposed amendment would help align New Zealand with best international practices, and would enhance New Zealand’s reputation in the global marketplace. As a woman, the proposed amendment would give me confidence that other women will not have to discover, like I did, that their skincare routine includes ingredients that may have adverse health implications.
   
   
10. Thank you for taking the time to consider this request. I would be happy to discuss these matters with you further.

References:

1. The current list of banned ingredients is contained Schedule 4 of the Cosmetic Products Group Standard 2006, see https://www.epa.govt.nz/assets/Uploads/Documents/Hazardous-Substances/2017-Group-Standards/46a81f194f/Cosmetic-Products-Group-Standard-Schedules-4-8.pdf.

2. Independent Scientific in vivo testing, 2018 and in vitro testing, 2019. 

3, Last updated in May 2020. See https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R1223-20200501.

4. https://static.ewg.org/ewgverified/docs/EWG_License_Unacceptable_List_C01.pdf

5. AB 2762 Toxic-Free Cosmetics Act, see Bill text https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201920200AB2762.

6. See https://www.ewg.org/Personal-Care-Products-Safety-Act-Would-Improve-Cosmetics-Safety.