U.S. PIRG Education Fund
Every day, we use a multitude of beauty and personal care products on our bodies. But, contrary to popular belief, these products do not require pre-market approval by any U.S. government agency. While some legislation has attempted to regulate the ingredients in these products, cosmetic companies in the U.S. can put nearly any ingredient they want in their products, often without full ingredient disclosure, exposing consumers to potentially harmful chemicals that could contribute to serious health impacts.
Little federal legislation addressing the issue of cosmetic safety or ingredient disclosure has been passed6 by Congress since the Food, Drug, and Cosmetic Act was enacted in 1938. Meanwhile, some states have taken action. In 2013, Minnesota banned formaldehyde, a carcinogen, from children’s products. In 2019, New York banned cosmetics containing 1,4-Dioxane, a likely human carcinogen, according to the EPA. And in 2020, California passed two cosmetic safety laws. The first law bans 24 toxic cosmetics ingredients linked to endocrine disruption, cancer, and other health impacts. The second law requires the public disclosure of designated hazardous fragrance and flavor ingredients in beauty and personal care products sold in California.
In addition, some companies have voluntarily taken action to protect their customers’ health by reformulating products to eliminate toxic ingredients and disclosing all ingredients in their products. For example, U.S. PIRG, the Campaign for Safe Cosmetics and other advocacy groups convinced the cosmetic giants Procter & Gamble and Unilever to disclose more ingredients in a public database. In addition, Procter & Gamble announced that it would remove two hormone disruptors, triclosan and diethyl phthalate, from all its products by 2014. And in 2020, Johnson & Johnson announced it would stop selling its talc-based baby powder in the U.S. and Canada, after consumers raised concerns that the main ingredient might be dangerous or at risk of contamination with asbestos, which can cause cancer and other serious illnesses.
With only a patchwork of state legislation and voluntary action on the part of some companies, consumers may be wondering — how safe are cosmetic products today? This report seeks to address that question by evaluating current progress made by popular brands in eliminating unsafe chemicals and disclosing ingredients.
We surveyed nearly 1,000 products to evaluate 26 popular personal care brands on two criteria (see full report cards in the report):
1. Ingredient Safety: Based on the use of 24 toxic ingredients recently banned in California, and the use of 11 other related and potentially hazardous ingredients.
2. Ingredient Disclosure: Based on a consumer’s ability to find full product ingredient lists, including fragrance and flavor ingredients.
This report has three main findings:
1. 20 out of 26 brands surveyed are not adequately disclosing ingredients, and the average ingredient disclosure grade was an F. Ingredient disclosure is very poor across all brands studied, and is inadequate for ensuring that consumers can make informed decisions about the personal care products they purchase.
2. Of the mega-companies studied (including Unilever, Procter & Gamble, and L’Oréal), L’Oréal19 is significantly behind the others in terms of full ingredient disclosure. In 2018, L’Oréal made a commitment to disclose more ingredients in its products, but did not set a clear timeline, and we were not able to locate evidence that it has followed through on its commitment.20 L’Oréal controls nearly 40 brands21,22 and is the largest beauty company by revenue worldwide.23 Given its size, L’Oréal has the resources to follow through on commitments to ingredient disclosure.
3. Based on what was visible in the ingredient lists, only 11 products surveyed (1.1% of all surveyed products) contained at least one of the ingredients recently banned in California. In addition, only 4 of the 24 banned chemicals were found on ingredient lists surveyed. This suggests that companies should be able to reformulate products to eliminate these banned chemicals faster than required by the new California law.
In this report, we offer recommendations to L’Oréal and other companies for improvement of ingredient safety and disclosure.