Ulta Beauty

Policy:Adopted a retailer safer chemicals policy

7.5 out of 23.5 points

Since 2014, Ulta Beauty has utilized a beyond restricted substance list (BRSL), which the company refers to as a “Do Not Use” list, for private-label products sold everywhere it operates. Other than noting the existence of the list on its website, other details of it are not publicly disclosed. However, Ulta staff informed us that the list is applied to new products added to the company’s private label and to existing products as they are reformulated. As “specific facts and circumstances” warrant, Ulta staff indicated they may take action on existing products. They also informed us that since 2017, the “Do Not Use” list has included prohibitions on toluene and xylene in nail products, parabens, formaldehyde-releasing preservatives, BHA & BHT, and alkylphenol ethoxylates. The retailer noted to us the process for updating and maintaining the list. We are considering the process and list, taken together, to be a safer chemicals policy.

Ulta announced in July 2020 that it was launching a voluntary program for brand-name products to be certified as free from certain chemicals, called “Conscious Beauty at Ulta Beauty.” Ulta is expanding this program, adding additional chemicals to the program’s “Made Without List” to be effective in January 2022, with additional updates planned for later in 2022 and 2023. While this is a positive step towards addressing chemicals of high concern (CHCs) in branded products, since it does not impose requirements on any category, it does not earn additional points.

Ulta has not set public quantifiable goals for reducing and eliminating CHCs, and does not have a publicly available manufacturing restricted substance list (MRSL), or beyond restricted material list (BRML) for plastics of environmental health concern (PEHC). The company’s policy does not specifically apply to beauty products of environmental justice concern (BPEJC), although private-label products in that category may be subject to the same restrictions for such.

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Oversight: Established management responsibilities and incentives

2.5 out of 5 points

Based upon documentation provided by Ulta, a senior manager oversees the company’s private-label products, as well as the voluntary program for brands, and key staff in that division have the responsibility to ensure that the “Do Not Use” list is adhered to.

Ulta does not appear to offer financial incentives for senior management to implement its safer chemicals policy.

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Accountability: Ensures supply chain accountability

5 out of 15 points

Ulta shared information with us noting that they conduct training on their safer chemicals policy with suppliers for their private label products, and that “core products participate in third-party safety testing.” It is unclear if the retailer includes these requirements in contracts with suppliers or if they conduct their own testing.

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Disclosure: Requires suppliers to report use of chemicals in products to retailer

8.5 out of 17.5 points

Ulta notes that it requires suppliers of its private-label formulated products to disclose to it ingredients and has internal staff who review the submissions for compliance against the retailers BRSL. The retailer informed us that this disclosure includes both fragrance ingredients and known impurities, sharing an image from a training presentation for their suppliers that specifies this requirement. A bonus point is also awarded for this disclosure being applicable to all private-label products rather than only one major category.

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Action: Reduced or eliminated chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs) within the last three years

3 out of 26 points

Ulta has noted that it added additional chemicals to its private label BRSL since 2017, which has resulted in at least some reduction in the use of chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs). The retailer also noted to us in January of 2021 that since its “Conscious Beauty at Ulta Beauty” program launched in October of 2020, it was not yet prepared to share metrics on the number of brands participating or chemicals reduced or eliminated as a result, but that it anticipates expanding it to include additional brands, which will be publicly listed later in 2021.

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Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

2 out of 16 points

Ulta shared information with us stating that when the company is identifying alternative formulations for products that previously contained a “Do Not Use” chemical or when reformulating products, replacement ingredients are “cross checked against global lists and published literature,” and that staff work closely with suppliers to evaluate the new ingredients.

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Transparency: Demonstrates a commitment to transparency and public disclosure

5.5 out of 20 points

Ulta has not publicized its safer chemicals policy or BRSL, has no public BRML, and has not committed to disclosing any of those items in 2021. It has also disclosed some, but not all, of the chemicals that are prohibited under its voluntary program for brands. However, we have awarded partial credit for the partial disclosure of its BRSL to us as noted in the discussion of its safer chemicals policy.

Ulta has started to disclose fragrance ingredients in its private-label products, which goes beyond the regulatory requirements for ingredient disclosure on cosmetics.

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