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."
Facts Only
* Sixteen certification programs were reviewed in the U.S. and European markets.
* None of the evaluated programs required routine analytical measurement of finished products.
* None used non-targeted analysis during the evaluation.
* Most programs addressed contaminants through ingredient restrictions or documentation rather than testing.
* Some programs require targeted testing for specific substances in specific situations, which only finds anticipated chemicals.
* U.S. federal law and EU frameworks base chemical safety on ingredient restrictions and manufacturer documentation.
* The 2022 Modernization of Cosmetics Regulation Act expanded FDA authority but did not create a routine testing requirement.
* A business case exists where companies relying solely on documentation remain exposed to recalls and litigation if later testing finds contamination.
Executive Summary
Certification programs for personal care products do not require laboratory testing of the products they certify; they assess chemical safety based on ingredient lists and manufacturer documentation. This approach is criticized because it cannot detect contaminants, impurities, or unintended substances in the final product. A companion study found unlabeled chemicals in nearly all of 113 tested personal care and cleaning products, with one in four containing a substance that contradicted package claims, such as "phthalate-free" products actually containing phthalates. The analysis suggests that certification programs evaluate only the recipe while the final product may differ, pointing out a gap between documentation and actual contents.
The research suggests that current regulatory frameworks focus on ingredient restrictions and disclosure rather than routine analytical testing of finished products. While some jurisdictions, like New York and Vermont, set specific concentration limits for contaminants, broader oversight relies on manufacturer documentation. The researchers propose adding analytical testing as a complementary layer to existing hazard screening, focusing initial efforts on high-exposure categories like baby and pregnant women's products. This approach seeks to use non-targeted screening for periodic surveillance, supplemented by targeted testing for substances of concern.
Full Take
The narrative highlights a structural gap between regulatory oversight/certification systems and actual product reality. The pattern observed is that reliance on retrospective or documentation-based checks fails to address dynamic chemical realities, which is evidenced by the discovery of unlabeled chemicals in tested products. This suggests a systemic weakness where control shifts from testing the material itself to policing the paperwork describing it. The proposal to layer analytical testing onto existing frameworks—starting with high-risk categories and non-targeted surveillance—addresses this gap by introducing measurable data into the certification process. This move reflects a transition from purely declarative compliance (what is written) to empirical validation (what is actually present).
The underlying implication for human agency is that consumer trust, built on certifications, operates outside verifiable physical reality unless direct, rigorous testing is implemented. The cost structure shifts exposure onto the consumer if current systems are maintained, as demonstrated by product recalls and litigation risks related to documentation alone. This points toward a necessary evolution in governance: acknowledging that safety assurance requires both transparent disclosure and empirical verification. The missing piece is the institutional shift from relying on declared intent (the recipe) to validating physical outcomes (the bottle).
Bridge questions: What regulatory or legal mechanism could be established to mandate standardized non-targeted screening for all certified products? How can voluntary certification bodies be incentivized to integrate rigorous analytical surveillance without imposing undue financial burdens? If testing is implemented, how should the results from broad, non-targeted screens be translated into actionable, targeted consumer safety information?
Sentinel — Human
This text presents an analysis of current regulatory gaps in personal care product safety by synthesizing peer-reviewed findings, providing context on existing certification systems, and proposing a data-driven path forward.