Ingredient safety is becoming a sharper competitive line for indie beauty, especially as brands navigate a patchwork of global standards. As a result, some are choosing to hold themselves to stricter rules than the U.S. requires.
In this month’s Indie Insights, Kiyomi Skin CEO Daniel Struve explains why the brand adheres to EU regulations across all markets, how that decision shapes sourcing and product development, and what stronger safety benchmarks could mean for indie innovation in the years ahead.
CDU: Kiyomi Skin formulates exclusively to EU ingredient standards, even while operating in a market that doesn’t require it. What were the biggest formulation and sourcing challenges you faced taking that approach, and what advantages has it brought your brand?
Daniel Struve: Formulating to EU standards was a deliberate decision that reflects both our German roots and our commitment to uncompromising quality. Because our products are developed and manufactured in Germany, they are based on EU Cosmetic Regulation (EC) No. 1223/2009 and this is built into every stage, from raw material sourcing to safety assessment and stability testing.
As we started with Kiyomi Skin in the EU we already solved the greatest challenges in sourcing compliant actives and excipients that met the EU’s strict purity, toxicological, and environmental criteria, as well as reformulating around commonly used materials restricted under EU law. This required close collaboration with suppliers and continuous evaluation of ingredient traceability and safety data.
However, the benefits are clear: Formulating within one of the world’s most rigorous regulatory frameworks ensures every Kiyomi Skin product meets the highest standards of safety, efficacy, and transparency. Operating to EU standards, even in a market that doesn’t require it, also builds an additional layer of trust with consumers.
They can feel confident that what they’re putting on their skin has been held to the strictest global benchmarks. In the long run, this discipline strengthens our brand integrity and consumer loyalty, because people recognize that our commitment to safety and science isn’t a marketing claim - it’s a standard we’ve set for ourselves.
CDU: You’ve also excluded ingredients like mineral oil, siloxanes, and sulfates that are still legally allowed in the U.S. What criteria or philosophy guides those decisions, and how do you balance safety with performance when reformulating around such exclusions?
Daniel Struve: It is true that these are still legally allowed in the U.S., but when we planned our U.S. launch, it was clear to us that we stick to our European formulations and principles instead of using these ingredients, which are much cheaper compared to plant-derived esters or milder, sulfate-free surfactant systems like glucoside surfactants and could have reduced our COGS.
Every ingredient we exclude is guided by one question: Does it benefit the skin, or is it just there to improve texture or reduce cost?
We avoid mineral oils, siloxanes, and sulfates not only because they’re “villains” or forbidden in the EU but because they don’t offer meaningful benefit to skin health or integrity. Instead, we invest in biocompatible alternatives that perform better while respecting the skin barrier and microbiome.
There is a lot of innovation happening in emollients, texture enhancers, and surfactants, which are safe and performing much better than the old traditional mineral oils, solixanes and sulfates.
CDU: Can you share how the 5-ALA amino acid works on a cellular level, and what drove your decision to make it the cornerstone of your formulations?
Daniel Struve: 5-ALA, or 5-aminolevulinic acid, is a naturally occurring amino acid crucial in the cellular energy cycle. It serves as a precursor to heme, which supports mitochondrial function, essentially fueling the cell’s ability to renew and repair itself.
In this energy cycle, there is a side product that is huge for our skin – metabolic water. This is great, as it is the purest water from within to support our skin and increase moisturization, which reduces signs of aging.
When we age, the body’s own production of 5-ALA is declining, resulting in a lack of energy production in our cells. This leads to increasing signs of aging, and this is why it makes a lot of sense to enhance our skin’s ability to remain energized. We love the term Skin Energy, because the energy is needed to slow down signs of aging.
We use 5-ALA because it aligns perfectly with our mission: to support the skin’s inner intelligence rather than override it. Instead of providing superficial results, it enhances the skin’s own regenerative processes.
Making 5-ALA our cornerstone was a science-driven choice - it’s one of the few actives that enhances visible vitality while working harmoniously with the skin’s biology.
CDU: Ingredient safety is increasingly part of a brand’s storytelling. How do you approach transparency and education around complex topics like chemical safety without overwhelming or alienating your audience?
Daniel Struve: Transparency is only meaningful when it empowers — not overwhelms. At KIYOMI SKIN, we see education as a bridge between science and self-care.
Rather than overloading consumers with chemical jargon, we focus on translating complex topics like ingredient safety into clear, relatable insights.
As a young brand, transparency and education are areas we’re continuously refining. We’ve experimented with different formats and learned that true connection happens when information feels human, not clinical.
Social media has been our starting point, but with attention spans lasting only a few seconds, it’s challenging to convey the depth of innovation behind an ingredient like 5-ALA. That’s why our strategy focuses on short, engaging content that sparks curiosity and leads consumers to more in-depth educational touchpoints, such as our website or product material,s where we can share science in a more meaningful way.
Rather than overwhelming people with technical information, we focus on translating what truly matters: how each ingredient works, why it was chosen, and how it benefits the skin. We center our messaging on evidence-based safety and efficacy.
Our community doesn’t have to decode ingredient lists or worry about hidden compromises. They know that with KIYOMI SKIN, efficacy never comes at the expense of safety.
For us, education builds trust, but empathy sustains it. Our goal is to make science not only understandable, but relatable and human.
CDU: As indie brands like yours scale, maintaining compliance across multiple regulatory regions can get complex. What lessons have you learned in navigating those frameworks, and how do you see harmonization, or the lack thereof, influencing indie innovation?
Daniel Struve: As we‘ve started in Europe, we’ve been prepared to fulfill strict requirements compared to the U.S. and formulated our products accordingly. That is why we did not face strong challenges going international.
However, assuming starting in the U.S., going to Europe might be a completely different story, as you would need to reformulate if you used forbidden ingredients (which is often the case for U.S. or even Japanese cosmetics going to Europe).
I’ve learned that regulations exist for a reason, and even when they drive you a little crazy (like why purified water is called “aqua” in the EU but “water” in the US), you have to respect the system and learn to work within it.
I think that regulations and staying ahead of emerging regulatory topics can actually serve as opportunities that drive innovation for indie brands. They can help us stand out from large corporations and global brands.
On a bigger scale, many mainstream formulations are often shaped by production efficiencies or cost-saving technologies, focusing on firmness or other technical aspects rather than benefits for skin and consumer needs.
Indie brands, on the other hand, have the chance to take a more meaningful approach: to educate consumers and create formulations that truly matter and put their needs at the center.
CDU: Looking ahead, do you believe the U.S. will ever move closer to EU-level ingredient oversight? And how can indie brands like Kiyomi Skin help push that conversation forward through formulation leadership?
Daniel Struve: I’m optimistic that the U.S. will continue moving toward stronger ingredient oversight, and that’s great for consumers. The momentum is already visible, especially with the introduction of the Modernization of Cosmetics Regulation Act (MoCRA), which marks a meaningful step toward deeper cosmetic regulation in the U.S.
Consumer awareness is rising, and independent research is looking more into ingredient safety and long-term skin health. However, meaningful change often starts from the ground up, and indie brands play an important role in setting those new standards.
We’re already seeing larger companies, such as E.L.F., aligning more closely with EU ingredient restrictions, which shows how consumer expectations are reshaping the market.
As mentioned earlier, there’s tremendous innovation happening in the ingredient space right now, and more and more studies showing, for example, that sulfates like Sodium Lauryl Sulfate are too harsh for the skin, resulting in irritation.
That gives indie brands a good opportunity to differentiate ourselves not by being bigger, but by being more thoughtful, more agile, and more science-driven in how we formulate.
And part of that leadership goes beyond formulation itself. It’s about how we communicate science to consumers. Indie brands have the opportunity to make complex topics like ingredient safety and efficacy both transparent and approachable.
By clearly explaining what ingredients do, why they’re chosen, and how they benefit different skin types, smaller brands can bridge the gap between science and everyday self-care - making transparency not just a responsibility, but a foundation for long-term trust and loyalty.
