Do you think that the beauty and personal care products on the shelves at your local drugstore or department store are safe? Do you think they are tested for safety by an independent agency before they are marketed?
If you think the answer is yes, you’re not alone. Most of us believe that the products we buy are safe, and that they are rigorously tested to address safety concerns before they are placed on store shelves. Various national surveys have found that a majority of us agree with statements such as “currently, the government carefully tests chemicals used in all major consumer products to make sure they are safe for people to use.”
Unfortunately, it isn’t true.
The US Food and Drug Administration (FDA) is responsible for cosmetics, as well as other products such as prescription medications. But, the FDA’s authority over cosmetics is relatively limited. As explained on the FDA’s website, “FDA’s legal authority over cosmetics is different from other products regulated by the agency, such as drugs, biologics, and medical devices.”
Importantly, except for color additives, the FDA does not approve cosmetics ingredients before they are placed on the market. In fact, the FDA explains that “[i]n general, except for color additives and those ingredients which are prohibited or restricted from use in cosmetics by regulation, a manufacturer may use any ingredient in the formulation of a cosmetic provided that the ingredient and the finished cosmetic are safe, the product is properly labeled, and the use of the ingredient does not otherwise cause the cosmetic to be adulterated or misbranded under the laws that FDA enforces.” The list of prohibited or restricted ingredients is amazingly short. The FDA has banned 9 ingredients, and restricts certain color additives. In comparison, the European Union list of prohibited or restricted chemicals is over 1,100 chemicals (although some of the chemicals would never be found in cosmetics).
Who determines whether a cosmetic is safe? As explained on the FDA’s website, “[c]osmetic firms are responsible for substantiating the safety of their products and ingredients before marketing,” and not the FDA. That’s right – not the FDA. In other words, no independent agency determines whether a product is safe.
And what is safe? The FDA doesn’t even define the criteria. While the regulations provide that each ingredient must be adequately substantiated for safety prior to marketing, the FDA doesn’t provide clear guidance as to the meaning of “adequately substantiated” or “safety” for cosmetics. If cosmetic companies don’t adequately substantiate a cosmetic product’s safety before marketing it, they are required to include on the label the following statement: “Warning – The safety of this product has not been determined.” But if there are no definitions or guidance, how does a company even determine whether a product complies? In fact, the Environmental Working Group (EWG) states that it reviewed more than 20,000 cosmetic product labels and did not find a single one with the statement. In my limited personal review, I’ve never seen such a statement either.
Of course, this doesn’t mean that cosmetics are inherently unsafe. But, the EWG asserts that approximately 89% of the ingredients routinely used in cosmetics have not been assessed by the FDA or the industry. And, according to the EWG, 98% of all personal care products contain one or more ingredients never publicly assessed for safety.
I don’t think that this is what most of us expect. We expect the ingredients in the products we slather on our bodies and paint on our eyes and lips to be safe. But it doesn’t seem like we really know. And if you take the time to look up the ingredients listed on those cosmetics we buy, you find out that cosmetics routinely contain ingredients that are hormone disruptors, cancer-causing, or reproductive toxicants. Almost universally, conventional cosmetics contain fragrance (or parfum). Fragrance almost always contains phthalates to sustain the fragrance and help it adsorb into the skin–and phthalates are hormone disruptors.
Who reviews cosmetics ingredients? The companies may privately conduct their own assessments. The cosmetics industry also relies upon the Cosmetic Ingredient Review (CIR). The CIR was created by the cosmetic industry trade group to police the industry. The CIR is funded by the member companies of the Cosmetic, Toiletry and Fragrance Association and its recommendations regarding safety are just that, recommendations, not requirements, and can be ignored. Also, the CIR’s focus is whether a cosmetic ingredient causes irritation or allergic reactions, not carcinogenicity or reproductive or developmental toxicity.
There are several ingredients that most environmental health advocates will recommend you avoid. I’ll be posting those soon. In the meantime, if you are concerned about the ingredients in beauty products, you can check out the EWG’s cosmetic database Skin Deep. When shopping, you can look up companies that have signed the Campaign for Safe Cosmetic pledge.