Letter to the Editors of Scientific American, on the Scientific Rigor and Regulation of the Cosmetics Industry

Dear Editor,

The Scientific American editorial team has seriously mischaracterized the scientific rigor and regulation of the cosmetics industry. Cosmetics and personal care products are among the safest product category regulated by the Food & Drug Administration (FDA).  Today, the Agency has clear authority to regulate the safety of these products under the Federal Food, Drug & Cosmetic Act, which requires that every product and its individual ingredients be substantiated for safety before they are put on the market, and that the labeling of those products be truthful and not misleading.

It’s important for readers to know the following facts:

  • No studies show that formaldehyde releasing ingredients are dangerous at the levels found in cosmetics. The amount of formaldehyde exposure from shampooing your hair is about the same amount as what is found in a medium-sized apple.
  • A simple examination of the list of ingredients banned in the EU would have shown that a vast majority of those banned ingredients are not used and never have been used in cosmetics. The EU list includes substances such as jet aircraft fuel, various petroleum refinery byproducts, and carbon monoxide, to name a few.
  • Stating that cosmetics are unsafe because “the number of studies on cosmetics is limited” is inaccurate because the ingredients used in our products, by law, must be substantiated for safety prior to marketing.  In addition, many of the ingredients used in cosmetics are not unique to our industry and have been widely tested for decades for use in foods and over the counter medicines.
  • Lead acetate is not readily absorbed through the skin. Studies show no elevation in blood levels when used in hair dyes (the only cosmetic product type in which it is used).
  • Parabens are important preservatives that are added to enhance the safety and shelf life of a product.  Parabens are permitted for use by government agencies across the globe, including the EU.

Despite the very strong safety record of cosmetic products, the Personal Care Products Council (PCPC) and its member companies believe more can be done to ensure that FDA has the appropriate authority and resources to regulate our industry in the 21st century.

We believe it is important for readers of Scientific American to know that, for nearly a decade, PCPC and its member companies have worked with a bipartisan group of leaders in Congress and a diverse group of interested parties to modernize federal regulatory oversight for our sector. This includes advocating for funding for FDA’s Office of Cosmetics and Colors to ensure the Agency has the resources needed to regulate our industry. That strong commitment has not waivered.

We have advocated for required reporting by manufacturers to FDA of serious and unexpected adverse health events. We also support mandatory registration with FDA of manufacturing facilities and ingredient statements; requiring FDA to issue Good Manufacturing Practices for cosmetics; we support and creating a program for FDA to review the safety of cosmetic ingredients, and we support FDA to have mandatory recall authority.  

Cosmetics and personal care products companies take seriously the responsibility for the safety of their products and those who trust and enjoy them.  We remain steadfast in our support of comprehensive reform to modernize cosmetics regulation.

Decades of positive consumer experience with our products demonstrate that they are one of the safest categories regulated by FDA.

Beth Jonas, PhD,

Chief Scientist

Personal Care Products Council