Should you be concerned about the chemicals in cosmetics?

“Consumers are often surprised to learn that most of the chemicals used in everyday cosmetics are not thoroughly tested for safety,” says Robin Dodson, a scientist at Silent Spring Institute. “No one is minding the store.”

“A 2004 survey estimated that women use about a dozen personal care products every day, which exposes them to more than 165 unique chemical ingredients,” says Janet Nudelman, director of the Campaign for Safe Cosmetics, a program of the Breast Cancer Prevention Partners that works to eliminate exposure to toxic chemicals. “And that’s probably an underestimate.”

(Don’t forget men: Sales of cosmetics for them are booming.)

“Cosmetics”—aka “personal care products”—are more than just makeup. They include shampoo, deodorant, lotion, perfume, nail polish, hair dye, and more.

Before a cosmetic comes to market, what hoops must it jump through?

“None whatsoever,” says Nudelman.

The Food and Drug Administration is tasked with regulating the cosmetics industry, but thanks to a 1938 law, the agency’s hands are essentially tied.

The European Union bans or limits cosmetic ingredients if a pre-market review shows that they may cause cancer or mutations or harm a fetus. Not so here.

“There is no required FDA pre-market safety testing or review on any of the personal care products that we use today,” says Nudelman. In contrast, drugs require extensive safety testing.

“There are about two pages of federal law that exist to regulate the $90 billion cosmetics industry,” notes Nudelman. “The FDA has no idea what constitutes the full universe of ingredients used in cosmetics or if they are safe.”

Label secrets

“The FDA requires that cosmetics be labeled with all intentionally added ingredients,” explains Silent Spring Institute’s Robin Dodson. (The nonprofit group studies how chemicals in the environment affect women’s health.)

“But we’ve found that some ingredient lists are incomplete. For example, phthalates are almost never listed.”

Phthalates (THAL-ates) are a family of chemicals primarily used to make plastics more flexible, though they are also used in nail polish, hairspray, and fragrances in cosmetics.

Studies suggest that some phthalates are hormone disruptors. (“Disrupt” means that a chemical can turn on, turn off, or change the signals sent by hormones like estrogen, testosterone, thyroid hormone, and insulin.)

Virtually all Americans have phthalates in their bodies—not just from cosmetics but from food, food packaging, household dust, shower liners, and more. In some studies, higher phthalate levels in urine have been linked to problems like lower sperm count in men and lower success rates in women undergoing in-vitro fertilization.

So why are phthalates often missing from the label? Ingredients used to make fragrances and flavors don’t have to be labeled, Nudelman explains. “That one word—‘fragrance’ or ‘flavor’—on a product label can hide dozens of chemicals, some of which are linked to cancer, hormone disruption, asthma, et cetera.”

Why do fragrances and flavors get a pass? “They’re protected as trade secrets. It’s a big black box of secrecy.”

A toothless FDA

If a cosmetic is unsafe, what can the FDA do about it?

“The FDA has no mandatory recall authority,” Nudelman explains. The agency can only ask a company to voluntarily recall a cosmetic, and that’s only if it’s adulterated or misbranded.

What’s more, she adds, “companies aren’t required to tell the FDA if they’re receiving complaints from their customers.”

Take WEN. As of November 2016, the FDA had logged nearly 1,400 adverse reaction reports from consumers about WEN Cleansing Conditioners. The complaints included hair loss, balding, itching, and rashes.

When the FDA inspected WEN’s manufacturing facilities, it discovered that Chaz Dean (WEN’s parent company) had received 21,000 similar complaints.

(In 2016, Chaz Dean settled a class action lawsuit for $26.3 million, though the company insisted that the conditioners—which are still being sold—are safe.)

Unsafe at low levels?

Are the levels of chemicals in personal care products too low to be harmful? After all, as toxicologists often argue, “the dose makes the poison.”

Dodson and others don’t buy it.

“That mantra doesn’t hold true when we’re talking about hormone disruptors,” she says. “Many hormone disruptors are active at very low levels.”

What’s more, “exposures can add up. Let’s say you use multiple products that contain chemicals that all act like estrogen. The effect may be larger than if you were to use only one product.”

For example, “when pregnant animals are exposed to a mixture of testosterone-disrupting phthalates, the effects are cumulative, meaning they work together to disrupt the development of the fetus.”

Go natural?

The FDA has received no adverse reaction reports about most cosmetics, and most ingredients are likely safe. But with labels that can hide ingredients and laws that don’t require safety data, people are justifiably wary.

“Consumers are demanding safe products that they can trust,” says Nudelman. In response, a “clean cosmetics” trend has taken off.

But don’t get swept away by claims like “clean,” “gentle,” or “natural.” Companies get to decide what they mean. Think a “hypoallergenic” lotion will be gentle on your skin? “There are no federal standards or definitions that govern the use of the term ‘hypoallergenic,’” says the FDA. “The term means whatever a particular company wants it to mean.”

CVS and others have banned parabens and phthalates from their store-brand products.

“This greenwashing can be confusing for consumers,” says Dodson. For example, there are no guarantees that “natural” ingredients are safer than those made in a lab.

Take essential oils, which are often seen as a natural alternative to synthetic fragrances. Some may be hormone disruptors. Others can cause allergic reactions.

What to do

“We cannot place the burden of selecting safer products completely on the consumer,” says Dodson. “We need to address the lack of regulations.”

Fortunately, change may be coming.

“Three big bills are being considered by Congress,” says Nudelman. They could give the FDA more authority to review the safety of cosmetics and recall unsafe products.

Until the law changes, these tips will help you navigate the cosmetics aisle:

Shop smart. CVS, Walgreens, and Sephora have banned or promised to ban most parabens, phthalates, and chemicals that release formaldehyde (a carcinogen) from their store-brand products. The same goes for all “Premium” body care products currently sold at Whole Foods. And Target is working on getting those chemicals out of all of the products it sells.

Beware of imports. Due to limited resources, the FDA says that it inspects less than 1 percent of imported personal care products. (The low inspection rates are not unique to cosmetics.) The agency has flagged some for bacterial and heavy metal contamination, as well as high levels of mercury in skin-lightening creams.

Watch out for fragrances. Avoid cosmetics that say “fragrance” or “parfum” in the ingredients list. And if a scented product doesn’t list fragrance or parfum, make sure it contains no phthalates.

Photos: jchizhe/stock.adobe.com, Kaamilah Mitchell/CSPI.

The information in this post originally appeared in the March 2020 issue of Nutrition Action Healthletter.


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