UPSTREAM THINKING.
Straight from the source.
The Source
Your skincare is not safe.
Forward this to anyone who is about to buy a beauty advent calendar. Twenty-four separate hazards. One business model.
Your bathroom shelf is an e-commerce engine.
In a study mentioned in a Guardian article in August 2026, researchers published the results of running 113 everyday personal care and cleaning products bought off the shelf at Target, Amazon, Walmart etc., through a screen that looks for everything, rather than only for what the label admits to. (Link)
98% of them contained at least one chemical that was not on the label.
85% contained at least one unlabelled chemical with known or suspected health hazards.
The average product listed 16 ingredients and contained 51.
And more than one in four contained something the packaging explicitly said was not in there.
"Phthalate-free" products with phthalates in them. "Fragrance-free" products with fragrance chemicals. "Hypoallergenic" products containing known allergens.
As the authors put it: the label can't protect you when it doesn't show what's really in the bottle.
Before you start throwing bottles away, it is worth knowing how the shelf got so full in the first place.
Wave 1: The multi-step boom
Historically, Western skincare marketing leaned on harsh, quick-fix astringents and single, heavy anti-aging creams. Then the curators arrived. Peach & Lily and Soko Glam both launched in 2012, bringing South Korean cosmetics (K-Beauty) to Western consumers through e-commerce; broad retail distribution followed between 2014 and 2017.
The "10-step routine" has an author. Soko Glam co-founder Charlotte Cho coined it in 2014.
While Korean consumers traditionally practiced layered hydration, they rarely followed a rigid ten-step rule. Cho has said since that it was never meant to be taken literally. Korean trade press pointed out at the time that very few Koreans used all of those products. But the Western market adopted the "10-Step" mythology because it was a perfect e-commerce engine.
Wave 2: The correction and "skinimalism"
The model hit a wall earlier than the backlash story suggests. "Skip-care", a cosmetics diet, explicitly a reaction against the multi-step regimen, was being reported by 2018. Pinterest named "skinimalism" its trend of the year for 2021.
The reason given is barrier degradation and breakouts from over-exfoliation and product clashing. Dermatologists do see it: in a 2025 survey of 168 Dutch dermatologists, 92% were concerned about the popularity of multi-step routines, 88% regularly treated skincare-induced skin problems, and only 12.5% recommended structured multi-step routines to patients.
So the 10-step routine is officially a declining format. The business is not declining at all: Korean cosmetics exports hit a record $11.4 billion in 2025, pushing Korea past the United States into second place globally behind France.
The beauty industry overall has adapted its business model yet again: instead of selling more bottles, brands sell fewer, more engineered formulations now, which captures the same revenue through premium pricing rather than product volume. Fewer steps advertised. Same spend for you. Still a lot of friction.
Friction
Frictionless checkout, frictionless payments, one-click, shoppable video, buy it in the TikTok livestream without leaving the app. The whole machine is engineered to remove resistance between wanting and owning.
And what that frictionless pipeline delivers is friction. On your skin, the barrier damage from clashing actives. On your morning. On your money. On your attention.
They removed every gram of friction from the buying. You are holding the rest of it on your skin and we hold it collectively in public health hazards and contaminated drinking water.
Market Outlook
The latest McKinsey "State of Beauty" report, titled From Aisle to Algorithm, reveals that the global beauty market is projected to reach $590 billion by 2030, maintaining a steady and resilient 5% annual growth rate (CAGR).
While some celebrate a $590 billion market, this aggressive, algorithmically driven growth is exactly what fuels the invisible toxicity tsunami.
When a market is projected to grow by 5% year over year in a market that already has enough soap and lotion, that growth cannot come from basic human cleanliness and hygiene need. It has to be manufactured through algorithmic addiction, and chemical engineering that actively damages public health.
Where the growth is actually coming from, some examples:
Fragrance has officially overtaken colour cosmetics to become the third-largest category in global beauty. Unlike other segments, fragrance is showing consistent growth across all price tiers, from luxury niche perfumes to mass-market scents, driven by consumers using fragrance as a frequent, expressive, daily sensory ritual.
Where people buy is shifting rapidly toward e-commerce which McKinsey now defines to include social and agentic commerce, is the single largest beauty channel globally at 28% of sales, ahead of grocery at 19% and specialty beauty retail at 18%.
The new imperative for beauty brands is transitioning from SEO to GEO (Generative Engine Optimisation), ensuring their formulations, scientific claims, and ingredients are structured so AI bots can easily read and recommend them. McKinsey reckons AI platforms could drive up to 35% of e-commerce transactions within three to five years. Note what that means: brands are now optimising for the machine you ask what to avoid.
The formulation rush. To catch a viral wave before the algorithm shifts, brands rush products from concept to digital shelves in months rather than years. It is hard to see where long-term toxicological screening fits into that timeline.
Cheap, toxic feedstocks. Brands achieve low prices by sourcing raw chemical ingredients from the cheapest global suppliers. Budget raw materials are a genuine route for contamination to enter a batch (refer back to above mentioned study).
But the bigger problem is not contamination. PFAS and phthalates are mostly not contaminants. They are ingredients. PFAS are added on purpose to make foundation, mascara and long-wear lipstick water-resistant. The FDA's 2024 review found more than 50 PFAS ingredients deliberately added across nearly 1,700 products, while independent testing found high fluorine in over half of 200 cosmetics with fewer than 8% declaring any PFAS at all. Diethyl phthalate is added to make fragrance last, and then disappears into the single word "fragrance" on the label. This is not secret pollution. It is legal non-disclosure.
Downstream. Synthetic fragrances, chemical UV filters and silicones go down the drain every day in quantities measured in thousands of tonnes a year. Municipal treatment was never designed for them and removal is partial and compound-specific: synthetic musks from fragrances and UV filters such as oxybenzone and octocrylene pass through. What is removed mostly ends up in sewage sludge, which gets spread on farmland and gets into groundwater. What passes through reaches rivers, where UV filters have been measured accumulating in wild fish. And the exposure that matters most is still the most direct one: what you put on your skin every morning and wash off every evening, and vice versa (these are called leave on and rinse-off products).
The illusion of "wellness"
The most dangerous trick of modern beauty consumerism is its rebranding as "self-care" and "wellness". By expanding into supplements, ingestibles, and clinic procedures, the industry has successfully medicalised everyday appearance. It frames the endless consumption of synthetic chemicals as an act of health preservation, when biologically, the opposite is true.
Meanwhile, further upstream.
Two things are happening at once in Brussels, and they point in opposite directions.
The bans are real. Under REACH, a targeted restriction (Commission Regulation (EU) 2024/2462, Annex XVII entry 79) covers PFHxA, its salts and PFHxA-related substances. From 10 October 2026, cosmetics containing these above 25 parts per billion cannot be placed on the EU market.
That is nine days away.
Note: It is one subgroup, not all PFAS. The EU-wide PFAS restriction has been proposed and was still working through ECHA's committees through 2026. It is not law yet. Separately, ECHA's Candidate List of Substances of Very High Concern reached 253 entries at its February 2026 update, and the agency's remit keeps widening, into end-of-life vehicles under Regulation (EU) 2026/1738, and into water, where new quality standards now cover the sum of 25 PFAS in surface water.
And the fragrance loophole is narrowing. Since 31 July 2026, under Commission Regulation (EU) 2023/1545, 82 fragrance allergens must be named individually on the label, up from 26. But: Brands can still write "parfum" and leave the rest unsaid.
And then there is the fight nobody outside the industry is watching.
It turns on one question: should a substance be banned from cosmetics because of what it is, or because of what we calculate it will do to you?
Hazard-based regulation says: it causes cancer, it is out. Risk-based regulation says: it causes cancer, but we have modelled how much of it crosses your skin, and that figure is small enough, so it stays. The second sounds more scientific. It is also considerably more expensive to contest, requires data that only large manufacturers possess, and treats "we haven't proved harm at this dose" as equivalent to "there is no harm."
In July 2025 the European Commission proposed moving cosmetics some of the way to the second model: a substance classified as carcinogenic, mutagenic or toxic for reproduction would only be banned if those properties came from skin contact. That you might also swallow it or breathe it, for example by kissing someone who had applied the product, did not count as it’s not the “intended use” and the automatic ban would not apply. A second clause would have exempted substances extracted from plants, provided nobody had chemically modified them.
The consumer body BEUC called it what it was. Its director general Agustín Reyna said the proposal "flies in the face of consumers' concerns" and would "reduce incentives to innovate and bring less toxic alternatives to market."
Then it got unusual. In October 2025 the UN Special Rapporteur on toxics wrote to the EU warning that the package seemed to conflict with the rights to health and environmental protection. The UN human rights office in Europe went further, and defended the hazard-based principle directly: knowledge about toxic substances "will never be complete," and "lack of full scientific certainty must not be used as a reason for postponing preventative action."
Parliament killed the exposure-route exemption in April 2026, by 540 votes to 60. One MEP, Yvan Verougstraete, put it plainly: "If you ask citizens whether they are willing to apply to their skin a product that could give them cancer, the answer will always be no. So why should we accept what no one wants? To please lobbies?" (Link)
So the principle held. If it causes cancer, it is still out.
What industry got instead was time. The provisional deal struck on 17 June 2026 stretches the phase-out well beyond the current eighteen-month standard, and loosens the test for a derogation, whether a "suitable alternative" exists now turns substantially on whether one is technically and economically convenient. Critics point out the obvious incentive: the clock only starts running once a derogation has been ruled on, so applying for one buys time whether or not you expect to win.
BEUC's verdict on the final deal: "Sadly, this deal means that toothpastes, deodorants, or lipstick containing toxic ingredients will stay longer in consumers' homes." HEAL's executive director Genon Jensen: "so-called simplification does not deliver more protection for people's health." The French group Générations Futures called the extended deadlines "totally unacceptable."
Cosmetics Europe's director general John Chave, in September: "The Omnibus VI makes it easier for us to get derogations, and therefore makes it easier for us to continue to innovate." He also described it as "a pro-competitiveness measure, which does not in any aspect mean deregulation or dilution of consumer protection." Both of those things are, in their way, true.
None of it is law yet. The deal was still provisional at the end of September, awaiting a plenary vote and formal adoption.
Worth knowing, while this plays out, what "Safe by Design" actually is, it gets quoted as though it were binding. The EU framework is "safe and sustainable by design", and it is a Commission Recommendation, revised in March 2026, described by the Commission itself as a voluntary decision-making tool.
What does the money say?
The Investor Initiative on Hazardous Chemicals, coordinated by ChemSec, launched in February 2023 with 50-odd investors and $10 trillion behind it. It now has around 80 members representing over $23 trillion in assets under management. What they want from the world's largest chemical producers: disclose the revenue and volume share of products containing hazardous chemicals, publish timed plans with real KPIs to eliminate persistent chemicals including PFAS, shrink the hazardous portfolio, and set a 2030 target for revenue from safer alternatives.
$23 trillion is asking the questions the label won't answer.
Where does this leave you and your bathroom shelf?
Expecting people to become amateur chemists and audit every bottle with a smartphone app is a failed strategy. It shifts the burden of systemic industrial pollution onto the individual consumer. The absolute fastest way to cut through the noise is to buy less.
Forward this to someone who’s still buying the 10-step skincare routine rule.
The Studio
PRACTICE
1. Less friction
By dropping from 10 products to 2 or 3 basic essentials, you exponentially lower your cumulative exposure to hidden manufacturing contaminants like PFAS and endocrine-disrupting phthalates.
Your skin is a self-renewing organ, not a sponge that needs constant feeding. Providing a gentle wash and simple moisture, allows your skin barrier to repair and function naturally. The best sun protection is to wear a hat and do not expose yourself to the sun from 11:30 to 4:30pm, during high UV hours. Think about how you design your day, and not how you compensate and “make an unhealthy rhythm work” with more sunscreen and more supplements.
2. Stop paying the "beauty tax"
Shifting to a bare-minimum routine cuts your personal care spending by hundreds, if not thousands, of pounds (or Euro) a year. Check your spending analytics and repurpose that amount.
Instead of buying separate eye creams, neck creams, night creams, and day lotions, a single tub of a well-formulated, unfragranced baseline moisturizer handles all of it for pennies (cents) per use. You also reduce packaging waste as many tubes are designed to dose too much product at once so you need to buy a new one frequently (i.e. shower gel).
3. Elimination
If you remove the products completely, you eliminate the risk of their hidden contaminants entirely. A freedom inspired, time-saving, low-exposure routine looks like this:
Wash your face with plain lukewarm water. Most skin types do not need a surfactant-based cleanser in the morning, which preserves your natural skin barrier and eliminates one product exposure entirely.
Get a soap bar instead of a shower gel as body wash. Traditional bars require fewer synthetic preservatives, emulsifiers, and plasticizers than liquid body washes.
On shampoo, let’s discuss. I have not yet concluded what the best option is. I currently use Ringana for soap bars, deodorant and moisturizer, but their shampoo does not do the trick.
Throw out air fresheners and scented candles. Fresh air should come from opening the window, not from burning toxic chemicals indoors.
Don’t buy liquid dishwasher and laundry detergent. I am currently with WeAreDip. https://wearedip.co.uk/ Charlie and his team truly care and do what they can to share what their mission is about.
Don't store creams in the bathroom. The constant fluctuation between hot steam and cool air causes condensation to form inside the bottle. This extra moisture dilutes the product's preservative system, creating a perfect breeding ground for mold, bacteria, and chemical breakdown.
You might say: “Clouds, but these must already be in my tap water then?” For a jug, faucet filter, or under sink installation, or shower filter, I recommend TAPP (Link), for a bespoke assessment and whole-home solution, send me an email to [email protected]
Rules of thumb for sourcing what's left
Look for "fragrance-free", not "unscented". "Unscented" products often contain masking chemicals to hide the smell of the base ingredients. This eliminates the largest legal loophole, where hundreds of undisclosed phthalates and synthetic musks hide.
Choose short ingredient lists. The fewer ingredients a product has, the fewer opportunities there are for a contaminated raw material to enter the batch during manufacturing.
Do not trust a brand's own "clean" or "natural" marketing unless you have really engaged with the specific brand and what they share.
If it says antibacterial, it is a biocide. You do not need that at home. Plain, fragrance-free soap and water do not kill bacteria; they physically detach dirt, viruses, and microbes from your skin and float them down the drain. This mechanical action is completely sufficient for daily hygiene. Widespread household use of biocides creates a massive public health risk by driving antimicrobial resistance. Just like misusing antibiotics, exposing domestic bacteria to low doses of biocides kills the weak germs but leaves the strongest, mutated strains alive to multiply.
A classic example of a household biocide is Triclosan, which was heavily used in antibacterial hand soaps, toothpastes, and cosmetics. Because studies proved it acts as a severe endocrine disruptor and accumulates in aquatic ecosystems, the EU banned it from the vast majority of personal care products, and the UK HSE heavily restricts its use.
The ultimate takeaway for you, your health, and your wallet comes down to one core truth: The personal care industry is built on manufactured overconsumption, but you can opt out by buying less.