The certification illusion: Why safety seals miss hidden chemical hazards

None of the certification programs consumers rely on to find safer personal care products require laboratory testing of the products they certify, according to a new peer-reviewed analysis. All of them judge chemical safety from ingredient lists and paperwork supplied by manufacturers, an approach that cannot catch contaminants, impurities, or anything else that was never meant to be in the bottle.

The finding comes on the heels of a companion study finding unlabeled chemicals in nearly all of 113 personal care and cleaning products tested. Most contained at least one unlabeled chemical with known or suspected health hazards, and one in four contained a chemical that contradicted claims on the package, including "phthalate-free" products that contained phthalates.

Certification programs check the recipe. Nobody checks the cake. What a company means to put in a product and what ends up in the bottle are two different things, and no one is checking the difference."

Johanna R. Rochester, PhD, lead author of the review and senior scientist at the Million Marker Research Institute

The researchers reviewed 18 certification and ingredient-screening programs operating in the United States and European markets, including third-party certifications such as MADE SAFE, Environmental Working Group, Cradle to Cradle, COSMOS, EU Ecolabel, and EPA Safer Choice, retailer standards such as Clean at Sephora and Target Clean, and consumer scoring apps such as Yuka and Think Dirty.

Sixteen of the programs are designed to evaluate chemical hazards and were compared directly. None of these required routine analytical measurement of finished products. None used non-targeted analysis, a laboratory method that can screen for thousands of chemicals at once without a predefined list. Six addressed contaminants or impurities as a defined category, and even then through ingredient restrictions or documentation rather than testing. A few require targeted testing for specific substances in specific situations, but that approach only finds chemicals that were anticipated in advance.

Regulation follows the same pattern. Across U.S. federal law, state laws in more than a dozen states, and the European Union framework, chemical safety rests on ingredient restrictions, disclosure requirements, and manufacturer documentation. Only a few states set concentration limits for a contaminant, such as the 1,4-dioxane limits in New York and Vermont. The 2022 Modernization of Cosmetics Regulation Act expanded FDA authority over cosmetics but did not create a routine testing requirement. The EU requires a premarket safety assessment and a legally accountable person for each product, which is stronger oversight than the U.S. system, though it still focuses on known and declared substances.

The authors propose adding analytical testing as a complementary layer to existing certification rather than replacing hazard screening. They suggest starting with voluntary programs and the highest-exposure categories, including products used by babies and pregnant women, leave-on products such as sunscreens and fragrances, and products used on sensitive areas such as feminine washes and menstrual products. Non-targeted screening could be used for batch or periodic surveillance, with targeted follow-up testing to confirm and quantify anything of concern.

There is a business case as well. Between 2011 and 2023, 334 skin care products were recalled in the United States, covering more than 77 million units. Companies that certify products on documentation alone remain exposed to recalls and litigation if later testing finds contamination.

"Shoppers read the label, they look for the seal, and they still can't know what's in the bottle," said Jenna Hua, PhD, MPH, senior author and founder of the Million Marker Research Institute. "Right now the only way to know what's in a product is to send it to a lab yourself. That's an unfair thing to ask of a consumer, but it's a reasonable thing to ask of a certifier."