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In March 2020, Ethical Consumer viewed a completed questionnaire it had received from Lush, which contained a link to Lush's '2019 Infographic Roundup', as well as Lush's website for details on the company's environmental policy's and practices.

The company discussed its key environmental impacts, including: packaging, waste, circularity, cotton, carbon, palm oil, deforestation, raw materials, energy and water.

For example, "Paper and card makes up 63% of all the packaging we use, of that 86% comes from recycled sources, saving nearly 42,000 trees by using recycled card and paper."
"Where we can choose the supplier, 100% of the electricity we use is with Ecotricity, whose direct carbon impact is 34 tonnes instead of 2251 tonnes from the grid (we use the grid coefficients)."

The company had put mechanisms in place to reduce its environmental impact. For example, in regard to reducing the use of raw materials Lush produced products with 'naked' (no) packaging and offered rewards to consumers who brought packaging back so it could be recycled.

Lush was considered to have a reasonable understanding of its main environmental impacts.

Lush UK disclosed figures on carbon relating to its UK operations. In its questionnaire the company stated that it had data for scope 1 and 2 emissions and was working towards scope 3.

The company had also conducted research into the carbon impact of cork, to be used as packaging: "After a full carbon study was carried out, the Carbon Trust have officially verified that our cork pots are sequestering carbon dioxide, making them Lush's first Carbon Positive pieces of Packaging!"

Although Lush clearly had a reasonable understanding of its main environmental impacts and had taken measures to reduce its environmental impact, Ethical Consumer expected every company to have at least two dated and quantifiable future targets and independent verification of data, which could not be found in the case of Lush.

Overall, Lush received Ethical Consumer's worst rating for Environmental Reporting and lost a whole mark under this category.


Completed Quesionnaire March 2020 (March 2020)

In November 2020 Ethical Consumer viewed received a completed questionnaire from Lush containing a response to a question on what the company was doing to tackle climate change. Ethical Consumer was looking for the following:

1. For the company to discuss its areas of climate impact, and to discuss plausible ways it has cut them in the past, and ways that it will cut them in the future.

For the company to not be involved in any particularly damaging projects like tar sands, oil or aviation, to not be subject to damning secondary criticism regarding it’s climate actions, and to have relevant sector-specific climate policies in place.

2. For the company to report annually on its scope 1&2 greenhouse gas emissions (direct emissions by the company), and,

3. to go some way towards reporting on its scope 3 emissions (emissions from the supply chain, investments and sold products).

4. For the company to have a target to reduce its greenhouse gas emissions in line with international agreements (counted as the equivalent of at least 2.5% cut per year in scope 1&2 emissions), and to not count offsetting towards this target.

If a company met all of these criteria it would receive a best rating. If it met parts 1&2 (impacts and annual reporting CO2e) it would receive a middle rating. Otherwise it would receive a worst rating.

Lush provided a link to a website where they reported their climate impacts and actions. It stated that the company was aiming to become carbon positive. It stated that ten years ago it had bought and protected 6,000ha of Amazonian Rainforest in Peru, it also discussed a similar project in Sumatra. It stated that it supplied all its energy in the UK from Ecotricity and that Lush operations abroad also opt for renewable suppliers. It stated that it had just purchased an electric bus to replace all taxi journeys in Poole (where its head office is located) and that this would save 10-20 car journeys a day. It also discussed packaging and stated that it cork pots had been officially declared carbon positive by the Carbon Trust meaning that they lead to the sequestration of carbon. It also discussed deforestation and laid out goals for zero deforestation in its supply chain. The company also had an Air Travel and Carbon Tax Scheme. It stated "When Lush UK people use air travel, we calculate the Carbon generated. We ‘tax’ ourselves at a rate of £50 per metric tonne. The money from our Carbon Tax is used to fund climate change and transport campaign groups". A page titled "Environment Policy" stated that the company would: "Commit to reducing air-freight of products and ingredients and use green transport to distribute it to stores wherever available. Choose trains over planes for staff transport. Set targets for saving energy. Pledge to use green energy suppliers if available and buy energy-saving equipment". The company was considered to have met part 1.

The website reported the company’s Scope 1 and 2 CO2e emissions and also stated that it was working towards calculating its Scope 3 emissions. However, these figures were for the UK only and did not cover the company’s global operations. It was therefore not considered to have met parts 2 and 3.

In answer to a question on carbon reduction targets the company stated: "We are looking into committing to science based targets for our global business. Currently Lush NA has committed. Our new policy also includes a goal for zero carbon across the Lush Group by 2030". The company acknowledged that “we have never been too keen on long-term targets, we believe we all know what needs doing – moving away from fossil fuels, using cleaner transport, protect and plant forests, divesting our money from climate destroying funds”. The company was not yet considered to have an absolute carbon reduction target in line with international agreements and it was therefore not considered to have met part 4.

Overall, Lush received Ethical Consumer's worst rating for carbon management and reporting and lost a whole mark under Climate Change.


Completed questionnaire (November 2020)

In November 2020 Ethical Consumer received a completed questionnaire from Lush containing a response to a question on the company's policy on the use of the hazardous chemicals parabens, triclosan and phthalates.

Some forms or uses of these chemicals were banned or restricted in the EU or the USA. Triclosan is an antibacterial and a suspected endocrine disruptor. Parabens are also endocrine disruptors and have been linked to breast cancer. They are used as preservatives. Phthalates, usually DEP or DBP, are used in fragrances and are endocrine disruptors.

On parabens it stated " Lush prefers to use natural preservatives and we are working hard on eliminating all synthetic preservatives from our products. In the meantime, however, we use a maximum of two synthetic preservatives in any one product: generally either a team consisting of two types of paraben: methylparaben and propylparaben, or a team consisting of the chemical compound phenoxyethanol/2-phenoxyethanol and an alcohol called benzyl alcohol. We use as little as possible, equating to a much smaller percentage than the maximum amount allowed by the EU." It also stated that in every range there were paraben-free products and that 65% of the products were 'self-preserving' and did not have synthetic preservatives added. Lush did not provide a clear date for ending the use parabens

In the questionnaire the company stated that it did not use triclosan or phthalates.

Given that the company did not use triclosan or phthalates, but used parabens without a clear date for ending their use, Lush received Ethical Consumer's middle rating for toxic chemicals and lost half a mark under the Pollution and Toxics category.


Completed questionnaire (November 2020)

In November 2020, Ethical Consumer searched Lush’s website for the company's policy on the use of microplastics and non-biodegradable liquid polymers. The company stated that it did not use solid polymers such as microbeads in their products. Lush also acknowledged the issue of liquid polymers, and stated that they do use some liquid polymers in their products. These included styrene/acrylates/ammonium methacrylate copolymer and sodium polyacrylate. As the company stated clearly that it used no solid microplastics but some poorly bidegradable liquid polymers it was considered to have an inadequate policy.

According to Beat the Microbead, there are more than 500 known microplastics ingredients that can be found in our personal care products such as toothpastes, face washes, scrubs and shower gels. They are tiny plastic particles that are added for their exfoliating properties, but sometimes purely for aesthetic purposes only.

A recent report by Code Check found that non-biodegradable liquid polymers were also prevalent across a wide range of cosmetic products. Like microplastics, these materials degrade with a similar difficulty in the environment and may cause similar harm.

In 2018, the UK government banned the use of microbeads in toothpastes, shower gels and facial scrubs. However, some products classified as “leave on” were not subject to the ban, this would include lotions, sun cream and makeup, as well as abrasive cleaning products. This ban did not extend to non-biodegradable liquid polymers.

Given that the company’s policy covered all of its products but stated that it used non-biodegradable liquid polymers, the company lost half a mark under Pollution & Toxics.

Reference: (16 November 2020)

In November 2020 Ethical Consumer received a completed questionnaire from Lush Cosmetics, part of which described the company's palm oil policy, and contained a web-link to the company's 'Palm Progress Report', published in 2020. A page on the company's website, titled, 'Does Lush use palm oil?' was also viewed.

The questionnaire stated, "Our direction is towards zero deforestation and regeneration throughout our entire supply chain, not just in relation to palm. However, the expansion of palm is responsible for mass deforestation...Due to the lack of transparency which synthetic manufacturers can offer around growing practices, we have taken a political stance to remove all palm traces from our supply chains."

It further stated: "Lush does not use palm or palm kernel oil in its products but does use some palm kernel derived synthetics."

Regarding the use of some palm derived ingredients, the company stated, "for a few of the palm derived ingredients there is no easy switch over to a palm free version (animal tested materials being the biggest problem and/or the alternatives were completely changing the product to something unusable)."
The company also stated that, "Another big hurdle is the transparency which the synthetics manufacturing sites can offer us i.e. which feedstocks are used and where they originate from." The company further stated that the creation of such synthetics was too complex to be done 'in house'.

The company was not a member of the RSPO. In the questionnaire, it stated, "As we don't have confidence in the implementation of RSPO policies on the ground, we have taken the decision to move away from palm kernel derivatives within our supply chain.

In the questionnaire Lush disclosed the companies from which it sources palm-oil derivatives. On the page 'Does Lush use palm oil?' it also disclosed which of its ingredients contained derivatives of palm oil. On its Palm Oil Progress Report it disclosed all the volumes of palm oil derivatives which it used.

Another page on the company's website, titled 'SOS Sumatra: A new life for an ex-palm plantation" reported on the company's fundraising work that was helping to regenerate 100 hectares of ex-palm plantation in North Sumatra, one of the most biodiverse forest areas in the world and the last natural place on Earth where the Sumatran rhino, orangutan, tiger and elephant could be found together.

Under the project, the oil palm trees had been cut down and half of the area was to be reforested with plants from the forest, while the remaining 50 hectares were to be managed as environmentally-friendly agricultural land using a permaculture system for growing high-value crops such as patchouli, citronella, coffee, and cocoa.

In regard to its future plans around palm oil, the Palm Progress Report stated, "Whilst we continue to look at new alternative materials to switch over to, as they are manufactured, we have decided to move towards developing a bigger picture solution to shape the whole industry surrounding palm derived synthetics. This is the only real way Lush will be able to go palm free. We believe we have the beginnings of a solution but we will need the collaboration of other companies and investment in order to provide a range of palm free synthetics that will work in our products and that are not tested on animals."

Although Lush did not report to the RSPO, it had reduced its palm oil use to only palm oil derivatives in some products and was clearly working to become palm free in a way that did not compromise other ethical factors, e.g. their policy around non-animal testing. Lush disclosed the volumes of palm derivatives it was using and also had positive policies around regenerating land that was affected by palm cultivation. Overall, Lush received Ethical Consumer's best rating for palm oil.


Completed questionnaire (November 2020)