Heavy Metals in Cosmetics: Background to Regulations, Risks, and Testing

 

Heavy Metals in Cosmetics?

Heavy metals, such as lead, arsenic, cadmium, mercury, and others, are naturally occurring elements that can be found in the environment. They can make their way into cosmetics through contaminated raw materials or during the manufacturing process. These metals are not intentionally added to cosmetics but can be present as impurities. The presence of heavy metals in cosmetics has been talked about for many years. One of the most well-known stories involves lead in lipstick.

A Brief History of Lead in Lipstick

Concerns about lead in lipstick date back at least decades and probably centuries. The issue gained significant attention in the 1990s and early 2000s when various consumer advocacy groups and researchers began investigating the presence of heavy metals in cosmetics. In 2007, the Campaign for Safe Cosmetics released a report titled ‘A Poison Kiss,’ which found that over half of the 33 brand-name lipsticks tested contained detectable levels of lead. This report catalysed public concern and prompted further investigations by regulatory bodies. Stories like this are often used to convince consumers that some brands are safer than others, and there are even accreditation schemes companies can pay to verify that the products are safe independently.

FDA’s Stance on Heavy Metals

The U.S. Food and Drug Administration (FDA) conducted its own studies following the 2007 report. In 2010, the FDA released findings from an expanded survey of 400 lipsticks, which confirmed the presence of lead in all samples, albeit at levels considered safe by the agency. The metals examined were Arsenic, Cadmium, Chromium, Cobalt, Lead, Mercury, and Nickel. These metals were a good choice – they are all common enough to be a possible risk and have the kinds of properties that may pose health risks to consumers. This effectively debunked the whole story.

But anyone who thinks that a well-conducted study carried out by an authoritative body demonstrating that the public is at no risk would settle the matter probably hasn’t been paying attention to the rise of the internet. Public debate and concern continue to be stoked by scaremongering groups with a vested interest in alarming people, the highly cautious, and people who just enjoy passing on scary news.

China’s Reputation Regarding Heavy Metals in Cosmetics

In reality, heavy metals are not found in cosmetics at levels any higher than you would find in the general background. There’s no reason to use them and nothing about the way cosmetics are made would lead to heavy metals getting into them. It’s pretty much a non-story. But there are times when you might pick up unusually high levels. This has been the case in the past where cosmetic factories have been located near other industrial facilities, for example metal smelters, where the pollution from these could get into cosmetics. This was a concern for products made in China whose rapid industrial growth sometimes meant that things weren’t done in the way they would be elsewhere.

So there were cases where heavy metals of a significant level from the point of view of a chemist were found in lipsticks and similar.

Even in this case, I don’t recall ever hearing of levels that actually posed kind of realistic health risk being detected. The issue wasn’t that unsafe goods were being produced. It was more that the controls weren’t in place to ensure that unsafe good couldn’t be produced.

Breaking Down China’s Regulations on Heavy Metals

The Chinese took action in the light of the problem. I assume they moved production to less polluted locations – that being the best way to solve it. They also brought in regulations – which is usually helpful. They also instigated regular testing. So all in all a classic case of a problem arising and being solved. Countries and companies outside China also started testing Chinese products.

There was a slight twist on the story. The regulation of heavy metals in cosmetics is governed by the Cosmetics Supervision and Administration Regulation (CSAR), which came into effect in January 2021. This regulation focuses on ensuring the safety of cosmetics by imposing strict limits on hazardous substances like heavy metals.

Key heavy metals regulated are:

Lead: Limited to 10 mg/kg.
Arsenic: Limited to 2 mg/kg.
Cadmium: Limited to 5 mg/kg.
Mercury: Limited to 1 mg/kg.

These limits are designed to ensure that any trace amounts of these metals, which can sometimes be present as impurities in raw materials, are kept to safe levels. In addition to these limits, random sampling and testing of cosmetics for heavy metals and other contaminants are regularly conducted by Chinese regulatory bodies, especially for high-risk products such as children’s cosmetics and special cosmetics.

Manufacturers are also required to submit detailed safety information for cosmetic ingredients and raw materials, including tests for heavy metals, to the National Medical Products Administration (NMPA) as part of the product notification and registration process.

The NMPA conducts regular inspections and random testing of cosmetics, particularly for high-risk products such as children’s cosmetics, imported goods, and those sold online. Heavy metals, such as lead, mercury, arsenic, and cadmium, are among the substances targeted in these tests.

In 2023, the NMPA issued several new measures to optimise ingredient safety information submission, allowing for more efficient monitoring of cosmetic formulations, including heavy metal levels. Products found to exceed the heavy metal limits can face removal from the market, and companies responsible may face penalties, including fines and market bans.

The enforcement of these rules has become stricter in recent years as part of broader regulatory updates under the Cosmetic Supervision and Administration Regulation (CSAR). The random sampling of cosmetics is undertaken.

The Importance of Testing for Heavy Metals

Most countries have regulations banning or controlling heavy metals in cosmetics. Even if they didn’t, including toxic materials at dangerous levels in your products would be a bad idea both ethically and economically. You don’t want to hurt your customers, and it isn’t good for business if you do. But the practicalities of the way cosmetics and their ingredients are made is such that there really is no need to carry out routine testing of either raw materials or finished products. If there are sources of contamination, it is better to devote resources to eliminating the problem rather than measuring its extent.

When Should You Test for Heavy Metals?

But there might nonetheless be times when carrying out testing is necessary. If you are evaluating a new supplier for example, or if you are countering a scare story. And of course, if you supply goods to China it might be necessary both to comply with their data requirements and to make sure you can defend yourself if your products get tested in China itself.

If you need help with heavy metal testing – get in touch.

https://www.fda.gov/cosmetics/cosmetic-products/limiting-lead-lipstick-and-other-cosmetics

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