Yesterday, the official FDA Cosmetics Twitter account tweeted the following:
My initial reaction was… SHOULDN’T YOU MAYBE REGULATE THAT???
However, I quickly stumbled upon something more concerning than the United States Food & Drug Administration celebrating #NationalCottonCandyDay with a red-lipsticked lead warning. It was this Twitter user’s reply to the FDA: “What is it with this account lately, fearmongering? You know as well as I do that it's *illegal* to use dangerous ingredients in cosmetics.”
This is an excellent example of how the anti-clean beauty agenda being pushed by Big Beauty, industry “watchdog” accounts, popular influencers, and even journalists is rotting people’s brains. The literal FDA tells its followers that there’s “harmful” lead in lip gloss, links to an official government website referencing that data, and gets accused of “fearmongering.”
Sometimes facts — especially facts about how the American government protects (or doesn’t protect) its people — sound scary. Citing these facts is not fearmongering! It is sharing basic health and safety information. (Also, in regards to this person’s “illegal” comment… that’s a little like saying murder isn’t an issue because murder is illegal. Individuals, corporations, and government agencies do illegal things all the time.)
The fact is, cosmetics are not sufficiently regulated. The FDA operates on a post-market regulatory system, meaning cosmetics don’t need to be screened or tested before they’re sold to consumers. Just this year, studies detected carcinogens, endocrine disruptors, environmental pollutants, and more in mainstream makeup and skincare products — often, like lead, as contaminants or impurities not listed on the products’ ingredient labels. (It’s worth noting that Congress limits what kinds of guidelines the FDA can create and enforce, although even in cases where the FDA can take action against a harmful ingredient, it can also choose not to. See: This investigation into formaldehyde in hair straightening treatments.)
To be clear, I am not defending the “clean” contingent of the industry. “Clean beauty” has its own fuck-ton of issues. It’s mostly made-up marketing bullshit. Scores of “clean beauty” claims are incorrect. Sadly, that’s what happens when basic human safety becomes a for-profit sales grab.
But the ethos behind “clean beauty” — that some products are currently not as safe as they could be and should be safer — is sound. It’s common sense. The FDA is tweeting it, people! Except instead of taking responsibility, it’s suggesting that consumers stop licking their lips so as not to consume trace amounts of lead. Cool.
If you’re tempted to make excuses for the FDA or the beauty industry here, consider this: Dismissing the need for safer beauty products is to dismiss the experiences of marginalized communities, who often have higher chemical body burdens and are more affected by cosmetic contaminants due to a lack of government protection and regulation elsewhere: the workplace, the environment, the medical system, the culture.
Diving deep into the science on this would make for a very different, very long article — this is more of a spur-of-the-moment rant! — so I’ll keep it high-level for now. Basically, it comes down to co-exposures. Marginalized folks are statistically more likely to be exposed to potentially harmful chemicals via tap water, air pollution, proximity to waste sites, and occupational hazards, and these co-exposures can have cumulative effects on overall health. Exposure to the same chemical from different sources (personal care products and air pollution, for example) might add up to the legendary “dose that makes the poison,” or one chemical may alter and amplify the effects of another, according to the Environmental Defense Fund. Research published in the American Journal of Obstetrics and Gynecology, as reported by the American Association for the Advancement of Science, states: “For women who live in already polluted neighborhoods, beauty product chemicals may add to their overall burden of exposures to toxic chemicals.” Social stressors can increase individuals’ susceptibility chemical exposure, too, including the social stressor of systemic racism.
In other words, a particular cosmetic chemical might not be harmful to a privileged, healthy, white person… but it could be harmful to a person experiencing racial injustice or environmental injustice, a person from a low-income community, a person who lives near a landfill, a person who works in an industrial factory, a person without access to quality healthcare, a person with chronic health issues, a person who is pregnant, a person who feels the effects of systemic racism daily.
Additionally, “Pressure to meet Western standards of beauty means Black, Latina and Asian American women are using more beauty products and thus are exposed to higher levels of chemicals known to be harmful to health,” says Ami Zota, ScD, MS, an assistant professor of environmental and occupational health at Milken Institute School of Public Health at George Washington University. Disproportionate harm occurs via skin lightening creams, hair straightening treatments and permanent hair dyes, nail products, or simply everyday cosmetic use. “Beauty product use is a critical but under-appreciated source of reproductive harm and environmental injustice.”
(I also want to point out that the potential for physical harm goes beyond a beauty ingredient’s ability to absorb into the bloodstream. [And most beauty ingredients don’t.] Cosmetic chemicals can also end up in the water supply or evaporate into the air and affect human bodies through those channels later on, long after they’re applied to the skin.)
To deny this reality — to deny the common sense of practicing precaution and regulating potentially harmful cosmetic chemicals just in case they could keep harming people of color and other marginalized folks — is to contribute to the well-documented institutional prejudice in healthcare and beauty. Like, why are we even debating this?
I have no idea how we got to this point in beauty influencing and reporting, where loud, “liberal” voices seem to… stan the FDA. They cover these subjects as if beauty is somehow the one area where government agencies and corporate interests are totally pure and innocent and honest; as if beauty is somehow the only industry that puts people before profits. I mean it! I truly do not understand how someone can see how the US government and US corporations are handling life- and species-threatening issues like Covid and climate change and say, “But surely cosmetic policies are safe and thorough!”
This shit is systemic.
The beauty industry is no exception.
Just ask the social media manager at the FDA.
Thanks for this explanation - I follow a couple of those insta accounts that are critical of clean beauty and they are sometimes helpful but the tone of "Come ON guys, this is REGULATED, wake UP!" really annoys me. What you say about cumulative exposure makes so much sense.
I followed the FDA link and am confused. They write that they tested "hundreds" of lip products and found lead levels from below detectable to 7 ppm (and up to 14 ppm in applied cosmetics generally). They also say "Our data show that over 99% of the cosmetic lip products and externally applied cosmetics on the U.S. market contain lead at levels below 10 ppm" and "We have issued guidance to industry on limiting lead as an impurity in cosmetic lip products and externally applied cosmetics to a maximum of 10 ppm." I read this as saying not that 99% have lead, but that possibly they ALL have lead (??) but 99% are under the recommended "maximum" level. Does what you point out about cumulative exposure mean that even those levels are not acceptable? Can we believe the FDA that 99% are below at least that level even though they don't actually regulate it? The anti clean beauty influencers often say something along the lines of "EVERYTHING has tiny trace amounts of potentially harmful things, it's all about levels" - so is it a matter of researching every contaminate and understanding your own possible risk level?
Thanks so much for your work!