The Whole Foods Banned Ingredient List is Wholly Flawed

I intend these posts to be a multi-part series focusing on different parts of the nebulous Whole Foods banned ingredient list. The list I’ll be referring to is from their Premium Body Care Standards section. They also have banned lists for foods, which will not be addressed. You’ll notice when you visit the page that the document is cut in half so you have to scroll halfway down to read the right side of the page.

Spoiler alert, the right side just features the other half of the document title and the word “unacceptable” which would be in the same row as the ingredient on the left. You’re welcome. Unfortunately, that was the least of my concerns about the list and its 400+ ingredients that cannot be used if you want your product in Whole Foods.

Betaine maddness

The topic for this article is a class of chemicals called betaines, which many cosmetic formulators will find familiar. They are the most common secondary surfactant used in shampoos and body washes, as well as other foaming products. I used to make betaines so they are of particular interest for me. Let’s take a look at the specific products with the word “betaine” in the name on the list.

• babassuamidopropyl betaine
• betaine
• cetyl betaine
• coco betaine
• Lauryl Amidopropyl Betaine
• Lauryl betaine
• lauryl glucoside betaine
• oleyl betaine
• Wheat germamidopropyl betaine

I copied these exactly as they appear on their list on purpose to give you a feel for the level of thought and/or effort that went into the creation of their document. Most people will notice they don’t use INCI nomenclature for every ingredient, so there’s a clue about the level of knowledge the person/people had that put it together. I will also make some assumptions about how the list was created which I’ll get into later.

Babassuamidopropyl Betaine

Let’s go through these from the start. Babassuamidopropyl betaine at first glance seems really random. Only a handful of products even contain that material. According to GNPD, there have never been more than eight launches per year that contain it. Upon further inspection, the major company using it is Aveda. Aveda is “natural” product competition for Whole Foods. If Whole Foods can find a way to make it look like the competition is using something unnatural or unsafe, that *might* give them an advantage. Hopefully, that helps in understanding at least partly how the list was created.

Betaine

Next on the list is betaine. I don’t know what they mean here. Is this any product of that class of materials, which would eliminate the need for any other products on the list? Or do they mean the simplest form of betaine, which is trimethylglycine? As I will write about in future articles, some of the ingredients on the list seem to be an entire class of products vs. one molecule. A good example of that is “certified colors” that appears on the list. I guess we will assume for now they mean just the molecule.

Betaine chains

The next one can be grouped with others on the list so we’ll tackle them all at once. Cetyl betaine, coco betaine, lauryl betaine, and oleyl betaine are all the simplest form of betaine with varying fat chains for the lipophilic portion. Coco betaine is a mixture of all the others on this list, with the predominant species being lauryl betaine. Does Whole Foods have some reasoning that other betaines are not on the list because they vary by a few carbons? I’m guessing they just didn’t find any of those on a label of competitive products. A few examples you can feel free to formulate with are stearyl betaine, behenyl betaine, decyl betaine, or myristyl betaine to get around these restrictions if you really want to use this class of molecule. I’m not saying these are all readily available, only they could be made and would be just fine for Whole Foods.

The same but different

The next class is the amidopropyl type. There are three on the list (the first was already discussed) and I’ll group them together here - they are babassuamidopropyl betaine, lauryl amidopropyl betaine and wheat germamidopropyl betaine. The first thing to note is they have the INCI name wrong for one. It should be lauramidopropyl betaine. Is it OK if I just use it because it’s not technically on the list? Also, conspicuously missing is the ubiquitous betaine of this type, cocamidopropyl betaine (CAPB). Was there a major problem with their suppliers not being able to formulate without CAPB, or was it just an oversight? The funny part is the major component of CAPB is lauramidopropyl betaine. The same formulation trick applies as the previous paragraph. Feel free to use any number of amidopropyl betaines of varying carbon chain lengths not on their list to get around it.

Phantom ingredients - Lauryl glucoside betaine

The last one is lauryl glucoside betaine. This is a real head scratcher. I don’t even know what that is. It’s not in the INCI dictionary. There is one product available they may be referring to, which is sodium bis-hydroxyethylglycinate lauryl-glucosides crosspolymer. That’s the only thing that could even be close to what they cite, but feel free to use it because it’s not technically what Whole Foods banned. Could they have included it because a product they looked at was lacking a comma on the ingredient label? There are a lot of “natural” product lists of ingredients and sometimes they leave a bit to be desired. There are often mistakes on these smaller volume products that fly under the radar. We’ll probably never know.

Betaine Safety

In conclusion, betaines as a class of molecule have been used for many years in the cosmetic industry and have been studied extensively for safety, biodegradability, and overall environmental impact. If made from a source such as coconut oil they are relatively “natural”. There are a whole slew of products less “natural” than betaines that aren’t on the banned list. Betaines are proven safe and relatively mild surfactants. The CIR has a report on CAPB (and their like) and found them to be safe as used. The full report is available from PCPC and if you’d like to read the full 275 pages. The question of why any betaines made their list is something that would be interesting to ask them, and I doubt they would be able to provide a logical data driven, coherent answer.

-The Underground Formulator