• Alexandra Townsley, Evelyne Tantry, Rajani Katta MD

Warning: The labels on your personal care products don’t always mean what you think they do


With allergic skin reactions reaching all new highs in recent years, it is becoming increasingly important for consumers to carefully read the labels on their personal care products. I’m a dermatologist, and every week I see multiple patients who have developed rashes due to their personal care products.


In fact, these products frequently contain ingredients that have the potential to trigger skin rashes. And, unfortunately, many of the labels found on the front of the packages just aren’t helpful.



What are “personal care products”?


While there is no legal definition of “personal care products”, this category generally consists of cosmetics, drugs, medical devices, dietary supplements, and other consumer goods.


In this post, we’re going to focus on those products that may be used on the skin. We’ll break down what you as a consumer need to be aware of when it comes to certain labels and certain categories of products.


It’s very important to learn more about the products that come in contact with your skin. In 2018, the North American Contact Dermatitis Group found that 9 of the 10 most allergenic ingredients can be found in personal care products. Unfortunately, labeling laws typically aren’t very helpful when it comes to consumer protection, and understanding what your label really means is more difficult than you think.


Keep reading to learn more about “hypoallergenic” products, “fragrance free” products, baby products, natural and organic products, sunscreens, insect repellants, and hair dyes.



The labeling laws for personal care products are vague and often favor the manufacturer


The FDA (the Food and Drug Administration) is the agency that governs cosmetics and personal care products in the US.


Here are the basics of what you need to know about the laws surrounding labels on these products:


  • “Cosmetic products and other ingredients, other than color additives, do not need FDA approval before they go on the market”

  • There is no requirement for cosmetic companies to file their “safety data” or “product formulations with the FDA”

  • Participation in the FDA Voluntary Cosmetic Registration Program is voluntary. Here, companies provide “best estimates” of their ingredients and business relations for use by the FDA to review safety.


It is also important to note that the FDA does not require “specific tests to demonstrate the safety of individual products or ingredients.” Rather, the manufacturers are free to do “whatever testing is necessary to ensure safety” with no further specifics.


When products are found to be allergic or irritating, there are no recall procedures in the law either. In fact, the “FDA is not authorized to order recalls of cosmetics,” leaving it up to manufacturers to voluntarily remove their products from shelves.



Infographic describing the myths and misconceptions about how personal care products are regulated in the US.
There are many myths and misconceptions about how personal care products are regulated in the US.


Are “fragrance free” products really fragrance free?


It is well known that fragrance is often very irritating to sensitive skin, and moreover, many types of fragrances have been found to cause a type of allergic skin reaction known as allergic contact dermatitis.


With this in mind, many people are now trying to go “fragrance free”...but it may surprise you to learn what this term really means under FDA regulations.


  • The FDA defines fragrance as “any natural or synthetic substance used solely to impart an odor to a cosmetic product.”

  • This means that if a fragrance is used for another function, then it can be included in “fragrance free” labeled products. This is huge loophole in the labeling laws, and one that products make use of all the time.

  • For example, benzyl alcohol may be found in supposedly “fragrance-free products, even though it serves as a fragrance. That’s because it can also be used as a preservative. Benzyl alcohol is just one example of ingredients that can use this loophole.

  • Products containing fragrance additives that act to mask natural smells and that are present in “insignificant levels” do not need to be listed on the label

  • Additionally, these “ingredients may be listed generally as ‘fragrance’ or ‘perfume’” with no further specifics

  • Products not for sale to the general public do not need to list ingredients at all, meaning that free samples, hotel amenities, and products used in your hair salon all do not require ingredient listings.


What does this mean for you as a consumer?


It means that “fragrance free” and “unscented” products may actually contain varying amounts and types of fragrance.



What does “Hypoallergenic” really mean?


The term “hypoallergenic” has become very common among personal care and cosmetic products. In reality, this term really doesn’t mean anything because there is no FDA definition or testing standards for the term “hypoallergenic.”


This means that companies are free to put this term on any product. The term does not indicate anything about the actual safety of the product.


The same can be said for products labeled “for sensitive skin” or “baby product”.


In fact, one study found that out of 187 cosmetic products, 89% “contained at least 1 contact allergen” and 63% had 2 or more, despite being marketed as “hypoallergenic”, “dermatologist recommended/tested”, “fragrance free”, or “paraben free”.



What makes a product “all natural”?


Many people with sensitive and allergy-prone skin look for products free of chemical preservatives and synthetic ingredients. But what does it mean when you see the terms “all natural” or “organic” on personal care and cosmetic labels?


As with many other popular labeling terms, there are no FDA regulations or definitions for these terms


  • The federal trade commission has reported several incidences where “companies pitched their products as ‘all natural’ or ‘100% natural’ but included synthetic ingredients.”

  • This resulted in a settlement that requires “proof” of “all natural” claims, although unfortunately the nature of that proof is not specified.


The bottom line: Products marketed as “natural” still may contain synthetic ingredients, although “all natural” requires no synthetic ingredients.



What makes a product “organic”?

  • When it comes to “organic” labels, the FDA has no regulation.

  • The US Department of Agriculture (USDA) has strict guidelines when it comes to food and agricultural products.

  • Their guidelines are minimal when it comes to personal care products.

  • The USDA has stated that personal care products “may be certified to other private standards” besides the USDA standards for food and agricultural products.

  • These standards “might include foreign organic standards, eco-labels, earth friendly, etc.”


The bottom line: Without knowing what standard is being used by the manufacturer, you have little information on what the term “organic” actually means when it is used on a personal care product.



How much SPF do I need in my sunscreen?


Sunscreen labels are often confusing for consumers as they debate how much SPF should be in their sunscreen. SPF stands for sun protection factor and is defined as the ratio of the amount of ultraviolet (UV) light required to harm unprotected skin to the amount of UV light required to harm protected skin.


Although many people think that higher SPF means more protection from UV light, the reality is that SPF over 30 offers only a minimal increase in UV protection. In fact, SPF 30 shields 97% of UV rays while SPF 50 shields 98%.


Another important point about SPF: these values only specify protection from UVB light, the wavelength of UV radiation which is responsible for sunburns. The SPF does not actually tell you anything about protection from UVA light, which is also dangerous and which may contribute to skin cancer.


You also need to watch out for marketing terms on sunscreens. Terms like “dermatologist recommended” are very common on sunscreen bottles, although these terms are not approved or regulated by the FDA.



Your insect repellant is leaving you in the dark


Insect repellant is unique in this category of personal care products, as it is governed and regulated by the Environmental Protection Agency (EPA).


Insect repellant is unique in this category of personal care products, as it is governed and regulated by the Environmental Protection Agency (EPA).


  • Under EPA regulations, insect repellants are required to list active ingredients only.

  • “Inactive” or “inert” ingredients need not be listed or identified on product labels.

  • Only the percent composition of inert ingredients are required.


This means that those with fragrance sensitivity should be concerned about fragrance additives being used as inactive ingredients in these products. In fact, there have been multiple reported cases of contact dermatitis resulting from insect repellents with various botanical and chemical fragrance ingredients such as citronellol, lemon oil, and eucalyptus oil.



What should I look for on labels if I have a hair dye allergy?


Hair dye allergies are common, and most often due to a hair dye ingredient called PPDA (P-paraphenylenediamine). In fact, PPDA is the 10th most frequent allergen in North America.


Although hair dyes do require ingredients to be listed, active ingredients are not required to be highlighted on the label.

Instead, they often appear lost in a long list of confusing chemical names in the ingredients list. This can make it challenging if you have a hair dye allergy.


For more information on what alternatives are available for those with a PPDA allergy, see our blog post on this topic.


Infographic describing the potential pitfalls of personal care product labels.
There are certain trends to look out for when reading labels for personal care porducts.


The bottom line: There is little to no regulation for many of the claims that appear on cosmetic and personal care products.


Unfortunately, there are serious loopholes in the regulations and standards governing the cosmetic and personal care products in the United States. One important point is that the regulations leave safety reporting to manufacturers on a voluntary basis. Most of the information and reports of serious adverse events that we have available have in fact been provided by consumers.


Although we have a long way to go, there have been recents efforts to change this lack of oversight through the Safe Cosmetics and Personal Care Products Act of 2019 and the Personal Care Products Safety Act of 2019. These bills seek to increase the regulation of cosmetic labeling and allow the FDA to suspend and recall the sale of products that cause “adverse health reactions.” This legislation has yet to be passed into law, however.


Until these changes are made, it is up to you, as a consumer, to stay informed of the current regulations and to learn how to understand the information found on personal care product labels.


If you’d like to learn more, please see this article we wrote for a medical journal.


For a list of skin and hair care products that we consider to be hypoallergenic, please see this webpage.



 


Dr. Rajani Katta is the author of Glow: The Dermatologist's Guide to a Whole Foods Younger Skin Diet. To receive future updates on preventive dermatology and the role of diet, sign up here.


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