Cosmetics & Makeup

Lead in lipstick, PFAS in foundations, the EU vs US regulatory gap, and navigating clean beauty

Cosmetics and makeup occupy a unique regulatory blind spot. In the United States, the FDA does not require pre-market safety testing for cosmetic ingredients. Companies can put virtually anything in a product, and unless consumers are visibly harmed in large enough numbers to trigger action, the ingredients remain on shelves. The result is a marketplace where known toxic substances persist in everyday products applied to the face, lips, and eyes — some of the most absorbent skin on the body.

Lead in Lipstick

In 2012, the FDA tested 400 lipsticks from major US brands and found detectable lead in every single one [1]. Concentrations ranged from 0.026 to 7.19 parts per million. While the FDA stated these levels were "not a safety concern," there is no established safe level of lead exposure. Lead is a cumulative neurotoxin — it builds up in the body over time and does not break down.

Consider the exposure math: the average lipstick user applies the product 2-14 times per day, ingesting a portion with every meal, drink, and lip-lick. Over a lifetime, this adds up. Lead is not an intentional ingredient — it enters as a contaminant in color additives — but the fact that it is present at all in a product designed to be worn on the mouth reflects the lack of purity standards in US cosmetics.

PFAS: The "Forever Chemicals" in Your Foundation

A landmark 2021 study tested 231 cosmetic products purchased in the US and Canada and found high fluorine levels — a marker for PFAS (per- and polyfluoroalkyl substances) — in 56% of foundations, 48% of eye products, and 47% of lip products [2]. Waterproof, long-wear, and smudge-proof formulations were the most likely to contain PFAS, because these chemicals provide the water and oil resistance that makes products "last all day."

PFAS are called "forever chemicals" because they do not break down in the environment or the human body. They accumulate over a lifetime. Exposure has been linked to thyroid disease, immune suppression, reproductive harm, and increased cancer risk [4]. When you apply a PFAS-containing foundation to your face daily, you are adding to a body burden that never decreases.

Other Ingredients of Concern

Talc has been used in face powders, blush, and eyeshadow for decades. The concern is contamination with asbestos, which occurs naturally alongside talc in mineral deposits. While cosmetic-grade talc is supposed to be asbestos-free, testing has periodically found asbestos fibers in consumer products, most notably leading to major recalls and lawsuits. Johnson & Johnson discontinued talc-based baby powder in 2023 amid thousands of cancer lawsuits.

Formaldehyde-releasing preservatives (DMDM hydantoin, quaternium-15, imidazolidinyl urea, diazolidinyl urea) are used in mascaras, foundations, and other liquid cosmetics. They slowly release small amounts of formaldehyde — a known human carcinogen — to prevent microbial growth. While each individual release is small, daily application means continuous low-level exposure.

Coal tar dyes are used as colorants in eyeshadows, lipsticks, and other color cosmetics. Identified on labels as "FD&C" or "D&C" followed by a color and number, many are derived from petroleum and have been linked to cancer in animal studies. Some coal tar dyes are contaminated with heavy metals.

Mineral oil and petroleum-derived ingredients (petrolatum, paraffin) are comedogenic occlusive agents used as cheap moisturizing bases. They can be contaminated with polycyclic aromatic hydrocarbons (PAHs), and there is evidence that mineral oil is the largest contaminant in the human body [3].

The Regulatory Gap: EU vs United States

The contrast between European and American cosmetic regulation is staggering. The European Union has banned or restricted over 1,600 substances from cosmetic products. The United States has banned or restricted 11. This is not a typo.

The EU operates on the precautionary principle: if there is reasonable evidence that a substance may cause harm, it is restricted until proven safe. The US operates on the opposite assumption: ingredients are permitted until proven dangerous, and the burden of proof falls on regulators (or harmed consumers), not manufacturers. The result is that European consumers are protected from hundreds of chemicals that American consumers apply to their skin daily.

The 2022 Modernization of Cosmetics Regulation Act (MoCRA) was the first major update to US cosmetics law since 1938, giving the FDA slightly more authority over cosmetic safety. But it still does not require pre-market safety testing and relies heavily on industry self-regulation.

Navigating Clean Beauty vs Greenwashing

The term "clean beauty" is not regulated. Any brand can call itself clean, natural, or non-toxic without meeting any standard. This has created a massive greenwashing problem where brands use earthy packaging, plant imagery, and buzzwords while still formulating with many of the same problematic ingredients.

Red flags for greenwashing:

Using terms like "natural," "clean," "pure," or "green" prominently on packaging with no third-party certification to back it up
Highlighting one "free-from" claim (e.g., "paraben-free") while still using other problematic ingredients
"Fragrance" still appearing in the ingredient list despite clean branding
Vague phrases like "dermatologist tested" (which does not mean approved or recommended)

What actually indicates a safer product:

Full ingredient transparency (every component listed, no "fragrance" catch-all)
Third-party certifications like EWG Verified, MADE SAFE, or COSMOS/ECOCERT for organic claims
Short ingredient lists with recognizable components
Compliance with EU cosmetic regulations (some US brands voluntarily formulate to EU standards)

Genuinely cleaner brands tend to share full ingredient lists on their websites, use naturally-derived colorants (iron oxides, mica, fruit pigments), avoid PFAS by skipping waterproof claims, and use plant-based preservatives like rosemary extract or tocopherol (vitamin E).

The most practical approach is not to overhaul everything at once but to prioritize products by exposure: lipstick and lip products first (you ingest them), then foundation and daily-wear products (large skin surface area, daily use), then occasional-use items. Check the EWG Skin Deep database before repurchasing your current products, and swap the worst offenders first.

References

Lead content in 400 lipsticks on the US marketFDA (US Food and Drug Administration). US FDA Expanded Survey, 2012. PubMed 22245147 →
Fluorinated compounds in US cosmetics: implications for human exposureWhitehead HD, Venier M, Wu Y, Eastman E, Urbanik S, Diamond ML, Shalin A, Schwartz-Narbonne H, Bruton TA, Blum A, Wang Z, Green M, Peaslee GF. Environmental Science & Technology Letters, 2021. PubMed 34100279 →
Cosmetics as a source of mineral oil contamination in humansConcin N, Hofstetter G, Plattner B, Tomovski C, Fiselier K, Gerritzen K, Fessler S, Piendle G, Grob K, Vennos C. Food and Chemical Toxicology, 2011. PubMed 27418420 →
Exposure to per- and polyfluoroalkyl substances (PFAS) and their associations with human healthSunderland EM, Hu XC, Dassuncao C, Tokranov AK, Wagner CC, Allen JG. Journal of Exposure Science & Environmental Epidemiology, 2019. PubMed 30074245 →