Nano in cosmetics: an industry case of RRI implementation

The application of nanomaterials in cosmetics has always been a matter of debate, raising some fundamental questions: what is the matter with using nano? Is there a real added value for people? Is it safe?  What are the uncertainties for human health?

As a typical unnecessary good, consumer acceptance of a cosmetic product is strongly affected by both functional and non-functional features of the product. Nanomaterials could be used to improve the efficacy of the product, for example ensuring filtering of UV radiation or better shelf-life, as well as to enhance aesthetic properties, as for example the colour of a make-up.

Though consumers might welcome new features given by the use of nanotechnologies, this conflicts with risk perception of new technologies, which is always higher for products getting in close contact with the human body such as cosmetics.

Cosmetics are as well the first sector where specific requirements for nanomaterials have been introduced in regulation (Reg CE 1223/09), forcing industry to make a specific safety assessment and declare the use of nanosubstances in the product (labelling).

A perfect case for RRI, with conflicting stakeholder positions, not straightforward/ambiguous social benefits, and regulatory challenges has to be faced.

One of the RRI industrial pilots (Nanocube project) conducted within the Prisma project is addressing a very interesting case: the use of nanomaterials is combined with the development of a cosmetic product based on natural and organic ingredients.

The NanoCube project, coordinated by Archa and Techa (Tuscany region funds POR FESR 2014-2020) develops innovative technologies aimed at producing nanocapsules and nanosystems providing controlled release of bioactive agents for cosmetic and biomedical applications. A key research challenge is to make use only of natural ingredients, including the nanocapsules, and processing steps without the use of chemical (synthetic) solvents. The final product is expected to fulfil specific voluntary international certifications for organic and natural cosmetics.

The system promises to have a number of advantages: reducing the risks for workers and users in handling and using the active substance; reducing the use of active substances compared to conventional treatments; avoiding the use of preservatives; and improving the efficacy of the final product (compared to benchmark products).

Archa has worked together with Prisma partners to understand the RRI aspects involved in the NanoCube project, and best ways to address them in product development. Key RRI issues identified include the adoption of a precautionary approach in the risk management of nanomaterials, addressing specific ethical values in product development (in line with demanding ethical certifications for natural and organic cosmetics), as well as the need to address issues related to  risk perception and user acceptability in relation with nanotechnologies.

As one of the RRI actions planned within Prisma, these aspects have been discussed in a multi-stakeholder dialogue held on June 13th, 2018 in the premises of Archa. This dialogue has been carefully designed, ensuring participation of all relevant actors along the value chain and supply chain. About twenty delegates contributed to the event, including researchers, producers, retailers, authorities, certification bodies and professional users active on both cosmetics and nanomaterials. As a follow up, a consensus document has been prepared, shared and revised with all delegates.

Efficiency and quality, in particular product performances and improvement of the shelf-life without the use of any preservative, have been identified as the key added values of using nanotechnologies. A distinguishing feature of NanoCube is the use of nanomaterials based on organic substances, with a much lower risk profile compared to inorganic nanomaterials (the ones generally considered in discussion on cosmetics and nanomaterials).

Several “RRI” actions for product development emerged by Prisma actions, and in particular the dialogue event. These include planning of further testing activities on nanomaterials to support product claims, specific risk management actions for nanomaterials during production phases, regular dialogue activities with stakeholders – in particular developers, producers, certification bodies, distributors – and development of a specific communication strategy to ensure transparency in the use of nanomaterials all along the supply chain.

What has become clear in working with Archa for the Prisma project, is a strategic approach[1] of the company to social responsibility and Responsible Research and Innovation. Specific procedures are in place on quality, worker’s accountability, risk management and ethics of R&I and production process, sustained by voluntary certification such as OHSAS 18001, SA8000, ISO 14001, ISO 9001. Specific CSR and RRI tools (examples are provided in the Prisma RRI toolkit) are implemented at project level, on a case-by-case basis. Social values and principles are part of the company culture and as well of regular company procedures.

Besides those related to NanoCube, Prisma activities are helping Archa and Techa to reflect on how to further integrate a socially responsible and responsive approach to R&I, starting from the early stage of innovation, structured and integrated in the decision process and company policies. This could help Archa to become a testimonial that promotes RRI principles also for other companies and actors.

(post by Andrea Porcari)

[1] See the five stages of RRI implementation proposed in Ibo van de Poel et al, Company Strategies for Responsible Research and Innovation (RRI): A Conceptual Model, Sustainability 2017, 9, 2045