Safety Guide To Children's Personal Care Products
Parent's buying guide
Printable PDF guide
Brand buying guide
Ingredients to avoid

EWG Report
Summary
Exposures add up
Children are vulnerable
Why aren't all products safe?
Methodology
Survey results
References
News release

Most Americans believe the government ensures the safety of personal care products before they are sold. Most also assume products marketed for babies and children are necessarily milder, gentler, and safer. Wrong on both counts.

In fact, the Food and Drug Administration (FDA) has no authority to require premarket testing of personal care product ingredients for safety. Instead, FDA states that the manufacturers of personal care products, with few exceptions, "may use essentially any raw material as a cosmetic ingredient and market the product without an approval from FDA" (FDA 1995). Worse, FDA does not have the power to require the recall of a harmful product – recalls are voluntary company actions, and the mere act of FDA suggesting a recall requires that the Agency have firm evidence of potential human harm.

In place of government authority to ensure safety, the personal care products industry polices itself through an industry panel called the Cosmetic Ingredient Review (CIR). This industry-funded panel of scientists has reviewed just 11% of all ingredients in cosmetics, including many no longer in regular use. An EWG investigation found that the panel chooses criteria regarding sensitivity and irritation for 80 percent of its safety recommendations, ignoring more serious health concerns such as cancer, birth defects, and hormone disruption, and as a result finds more than 99 percent of ingredients reviewed safe as used. What's more, companies are not bound by the panel's restrictions or recommendations – compliance is entirely voluntary.

As it stands, it's up to individual cosmetic companies to make decisions about safety – for us, and for our children. Some companies make personal care products safe enough to eat; others make products using ingredients with documented links to birth defects in humans, or ingredients laced with cancer-causing impurities.

Companies are also free to represent their products in any way they choose - marketing claims for personal care products are entirely unregulated. For example, 19% of the children's products we examined were labeled "natural." There is no legal definition for the term "natural," and many parents might be shocked to learn that 35% of all children's products labelled this way are not fully natural at all, but contain one or more artificial preservatives linked to allergic reactions, hormone disruption, or nervous system problems in laboratory studies. And 80% of children's products described as gentle, soothing, non-irritating, hypoallergenic, dermatologist approved, or free of harsh ingredients contain ingredients linked to allergies and skin irritation.

FDA tried establishing official definitions for terms like "natural" and "hypoallergenic," but these protections were overturned in court (FDA 2000). As a result, personal care product manufacturers can use marketing claims "to mean anything or nothing at all." According to FDA, "Image is what the cosmetics industry sells through its products, and it's up to the consumer to believe the claims or not."

Products made and marketed especially for babies and children are not required to meet any additional health and safety standards. In fact, at least 41% of all products identified in our survey or made especially for children warn parents to "keep out of reach of children." These products contain ingredients that may harm children if not used according to directions, allowing children to absorb more than typical amounts though the skin or lungs, or through swallowing the product. Product safety is any company's choice, and any parent's guess.

Personal care products provide an appalling example of the inadequacy of current chemical regulations in the U.S. The Federal Food, Drug, and Cosmetic Act, the law governing cosmetics safety, does not require companies to test products for safety before they are sold. The Toxic Substances Control Act, the law that regulates all industrial chemicals in the United States, was created over 3 decades ago, and assumes chemicals in everyday products are innocent until proven guilty. The products we use each day on ourselves and our children can contain thousands of ingredients that have never been tested for safety. Worse, they can contain impurities - contaminants formed when a raw material was manufactured, or when it breaks down within a product - which never appear on a product's ingredient list.

We cannot continue to allow a self-regulating industry to make decisions about the health of our children. Health protective reform of chemical standards must include:

• Premarket testing of products and their ingredients for safety.
• Protective purity standards for ingredients.
• Attention to the effects of mixtures of chemicals on human health.
• Safety standards that protect babies and children – our most sensitive populations.