In the course of my work in the California Safe Cosmetics Program, I find that most people I talk to are surprised that personal care products (generally referred to as “cosmetics” in this field) are not as thoroughly regulated in the U.S. as are most other products we use. The U.S. Food and Drug Administration (FDA) has broad authority over food and drugs but does not have the same authority over cosmetics. The FDA does not have authority to recall products and does not require pre-market testing of most ingredients. Some cosmetics ingredients regularly in use in the U.S. are carcinogens, endocrine disruptors, or other toxicants that are restricted or banned in other countries. Many ingredients are not required to be identified on cosmetic product labels and may simply be listed as “fragrance.” This loophole, along with a number of high-profile cases of products with safety and labeling violations (i.e. Brazilian Blowout mislabeled as “formaldehyde-free” and talc containing asbestos in baby powder), has led to rising concern about harmful ingredients that may be in common use in cosmetics and who is most affected.
In 2018, these questions led my team to partner with a group of community-based advocates and researchers to investigate racial and ethnic disparities in exposure to chemicals in cosmetics. The California Healthy Nail Salon Collaborative, the California Safe Cosmetics Program, CHAMACOS (Center for the Health Assessment of Mothers and Children of Salinas), CERCH (Center for Environmental Research & Children's Health), and the Healthy Heritage Movement collaborated on the CAPABLE (Chemicals and Personal Care: Asian, Black, and Latina Exposure) Project. This study is one of the first detailed assessments of chemicals of concern found in cosmetic products used by these demographic groups, and this article is the second published as a product of this collaboration (you can read the first article here).
Prior studies found differences in product use by race and ethnicity and suggest some women are disproportionately exposed to chemicals of concern (CoCs). The CAPABLE Project quantified chemicals linked to cancer, reproductive or developmental harm, or endocrine disruption in cosmetics used by women of color. CAPABLE community partners decided which products to analyze based on availability in their communities and their knowledge of what types of products were of most concern.
We found that over half of 546 labels included CoCs, and 74% of labels had undisclosed ingredients listed as “fragrance.” In addition, nearly all the products we tested in the lab (30 of 31) contained additional CoCs that were not listed on the label (see figure). Unlisted ingredients are presumably either part of the fragrance formula (listed under the generic term “fragrance” or “parfum”) or they are contaminants.
These findings contribute to consumer awareness and safety, can help estimate disparities in chemical exposure, and complement research on health inequities. They also highlight the importance of California’s newest cosmetics reporting law—the Cosmetics Fragrance and Flavor Ingredients Right to Know Act of 2020 (CFFIRKA). Prior to CFFIRKA, labels with undisclosed ingredients hidden behind the term “fragrance” were unknowable without the kind of expensive, sophisticated, inaccessible lab testing we used in this study. Now, companies are required to report to my program those hidden ingredients that may be harmful to human health. Product labels are still allowed to only list “fragrance” rather than identify the ingredient by name, but consumers anywhere can search for their products or specific ingredients on the California Safe Cosmetics Product Database website to learn if any of those hidden fragrance ingredients are reportable under CFFIRKA. People interested in this information can also access it via Clearya, a mobile phone app or browser extension that shows shoppers information reported to CDPH while shopping online at various retailers. Consumers can also use another new free tool to find products that do not contain ingredients linked to health concerns that disproportionately impact Black women, the Non-Toxic Black Beauty Database.
California has been the leader in legislated ingredient disclosure, and there are currently efforts at the federal level to increase cosmetics consumers’ awareness and protections. For the time being, there continues to be a lack of transparency in what goes into making cosmetics in the U.S. The onus is still largely on consumers to educate and protect ourselves. Fortunately, we have these great tools and information to assist in that task.