The Standard
[ COUNTER'S REAL CLEAN ]
WHAT CLEAN MEANS
“Clean beauty” is undefined—not just in the beauty industry, but in legislation, in the market, and in culture. When a term has no definition, it can mean anything. And when it can mean anything, it effectively means nothing. The result is confusion: people don’t know what—or who—to trust, and companies can claim “clean” whenever they want, whether it’s real or not.
But clean does mean something. It is the reason Counter exists: a commitment to human health and safety with every formula—from ingredient selection and sourcing to formulation and packaging choices—without compromising product performance. It's not a look. It's not a trend. It's a methodology. And because clean products alone aren't enough to create lasting change, we also advocate for stronger legislation, market accountability, and a cultural shift in what clean beauty means and does.
The clean beauty revolution¹ proved this fight was worth having. Counter is here to show that, so long as your health matters, clean is still worth fighting for.
What follows is the standard for real clean.
WHAT'S OUT
The Never List®*, originally created in 2013, quickly became one of the most recognizable, widely-used elements of the clean beauty movement. It remains the original, industry-leading prohibited ingredient list—much more than simply a worst-offenders list, it is a comprehensive guide of ingredients that should be left out of your formulas. We use the best available peer-reviewed² science to inform The Never List® and our general approach is precautionary³, meaning, when there's scientific uncertainty, we choose the most protective path.
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Many "clean" brands don't maintain their own prohibited ingredient list and may rely on contract manufacturers to avoid chemicals flagged by retailer certification programs. Counter's The Never List®, a foundational piece of the clean beauty revolution’s legacy, was built from scratch in 2013 by clean beauty pioneer Beautycounter. We update it regularly as scientific understanding evolves.
Here's something we'll say plainly: no brand—including us—can claim to be entirely free from heavy metals⁴, PFAS⁵, or phthalates⁶. These are global pollutants. They exist in supply chains, and anyone who tells you otherwise is oversimplifying. Which is why, even though we don’t formulate with these ingredients, we still test for them. Because not formulating with something isn't the same as guaranteeing its absence. (More on that below in How We Test.)
We believe clean doesn’t stop at what’s inside the bottle. It extends to the packaging we choose, too. That’s why we work closely with our partners to understand exactly what our packaging materials are made of and set clear standards for safer, more responsible materials.
*While some ingredients on The Never List ® might not be commonly considered for use in personal care or beauty products, the scientific evidence around their potential general harm means we include them as part of our precautionary approach—so there's never any question about their use.
WHAT'S IN
Only about 30% of the ingredients we screen are approved for use in our formulas. The other approximately 70% end up restricted or prohibited.
Prohibiting ingredients is the floor, not the ceiling. The harder work is what we let in. Before any ingredient goes into a Counter formula, it's screened against the best available science we know for hazardous health endpoints: carcinogenicity, reproductive harm, endocrine activity, organ toxicity, and more. We do this in-house, with a team of scientists who specialize in human health—not cosmetic chemistry alone. Because secrets are shady, we also share every ingredient we use in our formulations.
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“Clean” has come to mean different things across the industry. For many, it begins with prohibiting a short list of ingredients. We welcome that progress and encourage any brand trying to make a shift to start there. But we see this as the baseline, not the standard.
To truly raise the bar, ingredient screening matters. Many beauty brands partner with contract manufacturers to develop formulas and evaluate ingredients. These teams are highly skilled in formulation, but approaches to safety assessment can vary. At Counter, we don’t take anything at face value from our suppliers or manufacturing partners. Every single raw material is screened and assessed by our in-house team of scientists to ensure it meets our standards. Our safety program has been built and refined over more than a decade, with input from scientific experts and ongoing review of emerging data.
Real clean takes real work. This is ours.
How We Test
Even a well-formulated, clean product can carry contaminants it didn't choose: heavy metals that occur naturally in pigments, phthalates that leach from shipping equipment, or PFAS from manufacturing surfaces. Formulation and testing are two different things. Real clean requires both.
We test for potential contaminants as part of our safety process—because we believe more information leads to better decisions.
Safety comes first, always. But performance is non-negotiable. “Clean without compromise” only works if it’s proven. We conduct third-party performance efficacy testing on most products to support our efficacy claims, and base any other efficacy claims on well-grounded and known science and supporting documentation—so you know what to expect.
We invest where it matters most: product safety, testing, and formulation—even when it means allocating more resources here instead of other areas of the business.
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We will never tell you our products are heavy metal free. We don’t believe that's possible. We won't oversimplify the PFAS issue because we know they're global pollutants and nearly impossible to fully eliminate. What we commit to: we test ahead of the industry curve, we act on what we find from a scientific perspective, and we use that data to build better supplier relationships and stay ahead of an industry that's still largely under regulated.
The FDA does not mandate a specific testing panel and much of the industry only screens for a basic set of four (perhaps seven) heavy metals. We go further, testing for nine to eleven distinct heavy metals on all color cosmetics.
Why We Advocate
Prior to the clean beauty revolution, U.S. cosmetics law went more than 80 years without a major update. We’re not willing to wait another 80 years for more progress.
One brand can’t do this alone. We need to strengthen what the laws protect, what the market rewards, and what culture accepts. That fight was underway for over a decade. Our founder, Gregg Renfrew, was at the center of that revolution—testifying before Congress, helping drive the passage of state and federal laws on toxic chemicals in beauty products, including the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the first major federal update to cosmetic safety regulation since before World War II⁷. Not much has happened since then, and now MoCRA is under threat of not even being fully implemented.
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There’s more work to do. Some of the most concerning ingredients in beauty products are still not prohibited—PFAS, for example, are often still intentionally used in long-wear makeup. Fragrance ingredients can still be hidden behind a single word on a label—often referred to as the “fragrance loophole⁸.”
While the FDA plays an important role in establishing safety regulations, it does not have full capacity to proactively review every ingredient or product before it reaches the market. The system relies heavily on post-market surveillance and on manufacturers to ensure safety and go beyond current standards—and recent federal progress remains vulnerable to rollbacks⁹.
We believe in the power of conversation and community. When one person speaks up, it empowers others to do the same. To move the industry forward, we are pushing for stronger implementation of existing cosmetic safety laws, clearer ingredient restrictions and health-protective standards, and a consistent, health-first definition of “clean.”
We've made it easy and effective for you to urge Congress to ban the worst ingredients in beauty product. Click below to message your representatives directly.
MAKE ACTION
Small actions add up—and together, they create the pressure that drives change.
