First-ever study unveils unlisted harmful chemicals in personal care and cleaning products…including some labeled as “natural” and “organic.”

First-ever study unveils unlisted harmful chemicals in personal care and cleaning products…including some labeled as “natural” and “organic.”

Alarmingly, many commercially-used chemicals, such as phthalates and parabens, have been linked to infertility, type 2 diabetes, breast cancer, and other chronic illnesses. Consumers are exposed to these chemicals through inhalation, ingestion, or through the skin. 

We used non-targeted testing to evaluate 67 products for thousands of potential chemicals, including endocrine disruptors, carcinogens, and irritants. 88% of products were contaminated by at least one harmful chemical. We detected 251 harmful chemicals total, with some that were intended ingredients and others that were chemicals not disclosed on labels. Of these unlabeled ingredients, some were due to contamination–not added on purpose (known as "contaminants"), and some were likely added on purpose but were not disclosed on the label (known as "adulterants").

Consumers absorb chemicals through:

Some of these adulterants and contaminants were expected. We discovered some products that claimed to have "natural" or "botanical" ingredients contained other, potentially harmful plant-based ingredients that weren't listed. Additionally, some products that contained "fragrance" in their ingredients also contained phthalates, which were not explicitly listed. Such chemicals are often undisclosed due to "trade secret" protections or are by-products of natural plant extracts.

Others were unexpected, such as several fluorinated compounds, adhesives, and chemical intermediates. Some of these chemicals are potentially harmful, including 2,6-diisocyanatotoluene, a potential carcinogen that is used as a sealant in water-resistant packaging. We found unlisted parabens, likely due to contamination of ingredients. 

While the exact reason for unlisted chemicals is not always clear, we suspect an array of factors that include contamination and adulteration while sourcing or manufacturing ingredients, chemical reactions between ingredients, botanical by-products, and leaching of storage containers and/or packaging.

Surprisingly, there were several products with “clean” ingredients, or products labeled as “non-toxic” or “natural,” that were contaminated with toxic chemicals. Some of these products contained synthetic chemicals, such as parabens or phthalates, without listing them on their labels. In fact, many claimed to be “phthalate-free” or “paraben-free” despite containing those chemicals Therefore, brands may be contaminating their products during production, either knowingly or unknowingly. In some cases, they might also be using ingredients from suppliers that are already contaminated. This can result in products being mislabeled.

These findings highlight a major flaw in the current labeling system administered by the Food and Drug Administration (FDA). While some chemicals are banned, programs like the California Safe Cosmetics Program rely on voluntary reporting rather than mandatory testing. Because of this lack of oversight of individual companies, there is no incentive for producers to minimize contamination in the manufacturing process or to disclose certain ingredients. Implementing stricter testing protocols and/or providing transparency through third-party testing is crucial for keeping people safe. These protocols would help identify harmful chemicals in products, whether they were added on purpose or by accident. This information will inform regulators and companies on how to better protect consumers from serious health risks

Definition

Are they regulated?

Endocrine Disrupting 
Chemical (EDC)

Natural or human-made chemicals that may mimic or interfere with the body's hormones.

Not as a whole. There are some regulations/bans on individual chemicals or chemical classes.

Environmental Contaminant

Present due to environmental pollution or contamination of the ingredients or products.

Regulatory bodies don’t always require labeling of trace contaminants unless they are classified as hazardous.

Endocrine Disrupting 
Chemical (EDC)

Natural or human-made chemicals that may mimic or interfere with the body's hormones.

Not as a whole. There are some regulations/bans on individual chemicals or chemical classes.

Incidental Contaminant

Compounds that were not deliberately added but present due to manufacturing methods.

Must be controlled under Good Manufacturing Practices; some have regulatory limits. 
May be exempt from labeling.

Adulterant

Unexpected, synthetic, or banned compounds. Likely added intentionally for product efficacy.

Illegal — not permitted under FDA, EU, or Health Canada rules.

Botanical

Essential oils, extracts, plant material, natural flavor when specified, natural fragrance. Excludes fixed oils (vegetable) and butters (ex. shea), aloe.

FDA requires botanicals to be safe for use under labeled or customary conditions; properly identified; and free of harmful contaminants (e.g., pesticides, heavy metals, microbial contamination).

Natural

There is no legal definition of “natural,” but should reflect no synthetic or artificial ingredients.

FDA requires all ingredients to be safe and properly labeled. The FTC requires that “natural” claims should mean no synthetic or artificial ingredients.

Organic

Applies to how ingredients are grown (no synthetic pesticides/ fertilizers) and processed (no harsh chemicals or irradiation).

More tightly regulated than “natural.” Products/ingredients must comply with the National Organic Program. Synthetic preservatives, petrochemicals, or genetically modified ingredients disqualify a product from USDA certification. 

Non-Toxic/Toxin-free
Harsh chemical-free
Chemical-free
Eco-friendly

Terms with no formal definition, cannot be supported or disproved, and are often used to “greenwash” a product (i.e. make it seem environmentally friendly).

No legal definitions or regulations for these types of claims. The FTC regulates advertising and can take action against brands that make deceptive/unsubstantiated claims.

Endocrine Disrupting 
Chemical (EDC)

Definition 

Natural or human-made chemicals that may mimic or interfere with the body's hormones.

Are They Regulated?

Not as a whole. There are some regulations/bans on individual chemicals or chemical classes.

Environmental Contaminant

Definition 

Present due to environmental pollution or contamination of the ingredients or products.

Are They Regulated?

Regulatory bodies don’t always require labeling of trace contaminants unless they are classified as hazardous.

Endocrine Disrupting 
Chemical (EDC)

Definition 

Natural or human-made chemicals that may mimic or interfere with the body's hormones.

Are They Regulated?

Not as a whole. There are some regulations/bans on individual chemicals or chemical classes.

Incidental Contaminant

Definition 

Compounds that were not deliberately added but present due to manufacturing methods.

Are They Regulated?

Must be controlled under Good Manufacturing Practices; some have regulatory limits. 
May be exempt from labeling.

Adulterant

Definition 

Unexpected, synthetic, or banned compounds. Likely added intentionally for product efficacy.

Are They Regulated?

Illegal — not permitted under FDA, EU, or Health Canada rules.

Botanical

Definition 

Essential oils, extracts, plant material, natural flavor when specified, natural fragrance. Excludes fixed oils (vegetable) and butters (ex. shea), aloe.

Are They Regulated?

FDA requires botanicals to be safe for use under labeled or customary conditions; properly identified; and free of harmful contaminants (e.g., pesticides, heavy metals, microbial contamination).

Natural

Definition 

There is no legal definition of “natural,” but should reflect no synthetic or artificial ingredients.

Are They Regulated?

FDA requires all ingredients to be safe and properly labeled. The FTC requires that “natural” claims should mean no synthetic or artificial ingredients.

Organic

Definition 

Applies to how ingredients are grown (no synthetic pesticides/ fertilizers) and processed (no harsh chemicals or irradiation).

Are They Regulated?

More tightly regulated than “natural.” Products/ingredients must comply with the National Organic Program. Synthetic preservatives, petrochemicals, or genetically modified ingredients disqualify a product from USDA certification. 

Non-Toxic/Toxin-free
Harsh chemical-free
Chemical-free
Eco-friendly

Definition 

Terms with no formal definition, cannot be supported or disproved, and are often used to “greenwash” a product (i.e. make it seem environmentally friendly).

Are They Regulated?

No legal definitions or regulations for these types of claims. The FTC regulates advertising and can take action against brands that make deceptive/unsubstantiated claims.

Introduction 

Harmful chemicals like bisphenols, phthalates, and parabens are endocrine-disrupting chemicals (EDCs) that can interfere with the body's hormone system, leading to many health issues and chronic diseases, including breast cancer1,2, obesity3, diabetes4, miscarriage5, and infertility.6,7 Humans are exposed to these types of EDCs daily primarily through personal care products, household products, and food packaging. While some of these chemicals are present on product labels, it’s often unclear where EDC exposures come from and thus how to reduce exposure. To address this concern, Million Marker (MM) developed the Detect & Detox Test Kit, which measures EDC levels in urine and provides personalized recommendations for reducing exposure. MM also provides a product ingredient audit if users opt to disclose which products they use.

The Million Marker Test Kit Process

Methods

Product Selection

A total of 67 products from six categories were tested: shampoo (15), sunscreen (11), lotion (12), body/fragrance oil (10), hand/body wash (10), and cleaning products (9). Products were selected from Million Marker Detect & Detox Test Kit customer audits and split into three levels based on ingredients listed on the labels: Go (best choice, contains safe ingredients), Slow (use sparingly, contains ingredients with health concerns), and Stop (not recommended, contains harmful ingredients). 

To obtain the initial Stop/Slow/Go designations, ingredient lists were screened based on known and/or potential chemical health hazard ratings compiled from dozens of resources, including the US Environmental Protection Agency CompTox Database,9 the California Safe Cosmetics Program (CSCP) Product Database,10 the US National Library of Medicine PubChem Database,11 and the US Environmental Protection Agency Safer Choice Program.12 Each of these primary resources provides hazard ratings based on dozens of other sources of information on hazardous chemicals. 

The “Go” products had a large number of safe ingredients, including seed oils and butters (coconut, avocado, almond, shea, etc.). Go products were more likely to be fragrance-free or, along with Slow products, used essential oils and botanical extracts for fragrance rather than synthetic ingredients. Slow products contained ingredients of low to moderate concern, such as allergens from synthetic fragrance and some essential oils. The Stop products generally included the generic term “fragrance,” hazardous preservatives, as well as ethoxylated chemicals or petroleum-derived chemicals with contamination concerns

Sample Analysis
Products were purchased in 2021/2022 from major retailers, including Target, Amazon, Walmart, and Dollar Tree. Those not available from these retailers were purchased directly from the company website. All products were shipped to an accredited, internationally recognized third-party analytical laboratory for processing and analysis. We used a non-targeted exposomics approach to identifying suspect chemicals in consumer products. Samples were analyzed by high-resolution two-dimensional gas chromatography time-of-flight mass spectrometry (GC-MS). The output GC-MS data was processed using Highlight™, a machine-learning-based software, to identify compounds of concern.13

Results and Discussion

Our study of 67 personal care and cleaning products revealed some surprising findings about product ingredient disclosure and safety. We found many harmful ingredients that were not on product labels. Further, even products with “clean” ingredients, according to their labels, had some undisclosed, potentially harmful ingredients.   

We detected 251 chemicals total, with some that were intended ingredients and others that were chemicals not disclosed on labels. For the majority of products, the number of chemicals found in the products was far more than the number of chemicals listed on the label. While the average number of ingredients across all products was 18, the average number of chemicals found per product via non-targeted testing was 46. 

88% of the tested products contained at least one harmful chemical that wasn't mentioned on the label. This included products labeled as "natural" or "organic." In one product category (Body Oil), 100% of the products contained at least one chemical not on the label. Of the 18 initially rated “Go” products, several of which were marked “organic” or “natural,” 11 (61%) had harmful chemicals that were not on the label. These chemicals included fragrances, harmful botanicals, parabens, UV filters, and chemical contaminants (e.g. cyclopentasiloxane (D5) and cyclohexasiloxane (D6), which are silicone contaminants). On average, there were four unlisted harmful chemicals per product, across all categories.

Examples of unlabeled harmful chemicals

  • Bis(2-ethylhexyl) phthalate
  • Diethyl Phthalate
  • Bis(2-ethylhexyl) adipate
  • Benzyl chloride
  • Methylparaben
  • Propylparaben
  • Cyclopentasiloxane
  • Cyclohexasiloxane
  • Butylated Hydroxytoluene
  • 1,4-Dioxane
     

From the Stop and Slow categories, Lotions generally had fewer harmful chemicals, while Cleaning Products often had a higher percentage concerning ingredients. 

Percent Harmful Ingredients 
in the STOP and SLOW Products

For certain chemical categories, such as fragrances or botanicals, companies do not legally have to disclose all chemicals in the product. In the case of “fragrance,” many chemicals can be umbrellaed under the term and are not disclosed due to “trade secrets.” In our study, 39% of products (across all categories) contained harmful fragrance ingredients not on the labels. In the case of botanicals, plant products can contain hundreds of individual chemicals that, although they may be “naturally-derived,” can still be harmful and should be disclosed. In our study, 42% of products contained harmful botanical chemicals across all categories.

Contamination can occur at many stages of product manufacturing, storage, machinery, chemical reactions, and leaching from packaging. Contamination can come from environmental pollution (“environmental contamination), or the manufacturing process itself (“incidental contamination”). Product companies may unknowingly receive contaminated ingredients or introduce contamination in their own facilities. Additionally, companies or ingredient suppliers can intentionally add chemicals for functionality, that are not listed on the label (i.e. “adulterants”). Because we were unable to determine if unlabeled chemicals were present intentionally or not, we combined all these non-fragrance and non-botanical chemicals under the term “contaminants.” In our study, 55% of products contained contaminants across all categories.

 

 

Our initial ratings (Go/Slow/Stop) based on the product labels were changed after product testing. Seven “Go” products were downgraded to “Stop,” and five were downgraded to “Slow.” Ten “Slow” products were downgraded to “Stop.” Interestingly, one “Slow” product was upgraded to “Go,” and three “Stop” products were upgraded to “Slow.” Clearly, product testing provided a much more comprehensive picture of product safety, including contaminants and adulterants that were not listed on product labels.

Number of Go/Slow/Stop Products Before and After Testing

To analyze the products in terms of brand size, we divided up the companies into big, medium, and small, based on brand distribution (i.e. big companies are distributed by large, national retailers, medium by smaller and more localized retailers, and small companies are mainly boutique or online). We found that smaller companies had more “Go” products based on testing, while the biggest brands had mostly “Stop” and no “Go” products at all. However, small, medium, and large companies all had products that had contamination, indicating that any sized company would benefit from product testing and efforts to source from clean suppliers. 

In all, the majority of the products tested had unlisted harmful chemicals, and thus, many were rated lower than the initial ratings determined by the product label. A few products increased their rating after testing. These findings highlight why product testing is so important. It is the only way to truly know what is in the products we use. 

Percent of Products with Contamination by Company Size

Lastly, we compared the label and website claims of the individual products with what we discovered during untargeted testing. We found that out of the 67 products, 22% had ingredients that went against the claims of the company. The most common reason was that synthetic chemicals were present in products that claimed they were “100% natural.” The next were products that contained specific chemicals/chemical classes that were labeled as not present in the product, for example, phthalate-free, paraben-free, and oxybenzone-free. Lastly, several products were labeled “non-toxic” but contained synthetic, harmful chemicals. While claims like “natural” and “non-toxic” are not regulated, the Federal Trade Commission (FTC) requires these claims to be accurate. For a product to be “natural,” it must contain no synthetic or artificial ingredients. Although there is no legal definition for the phrase “non-toxic” or “free of toxins,” the FTC can take action against brands that make deceptive or unsubstantiated claims.

Also problematic are the products that claim there are no specific ingredients (such as phthalates or parabens) when, in fact, they are present in many. Not only does it make it difficult for the general population to avoid these chemicals, but it can be especially problematic for people who have allergies or sensitivities to such chemicals and need to avoid them. Further, misleading labeling such as this is illegal, and companies can be fined or penalized.

Most of these chemicals were likely introduced to the product as ingredient contaminants, unbeknownst to the product manufacturers. Parabens are preservatives and are often used in ingredients with high water content. Phthalates are very commonly used in personal care ingredients, so the chance of contamination is high. It is extremely important that companies understand what is in the ingredients they use to avoid misleading consumers and incurring possible legal action. The most effective way to do this is through ingredient testing.

Limitations and Future Steps 

Our extensive product testing revealed a significant presence of harmful ingredients, contaminants, and adulterants in various products, which were not disclosed on their labels. These findings underscore the critical importance of rigorous quality control and transparency in consumer goods. However, it is crucial to contextualize these results within the unique circumstances of their procurement in 2021, during the second year of the COVID-19 pandemic.

The global supply chain faced unprecedented challenges during this period, forcing many brands and formulators to source ingredients and products from alternative suppliers. This sudden shift in supply networks likely contributed to the presence of undisclosed substances in the tested products. 

In fact, one of the brands we consulted with confirmed they had to switch to a different supplier during this time, highlighting the far-reaching impact of these supply chain disruptions on product consistency and quality. While these findings are concerning, it's important to recognize that brands were not solely to blame, as the entire supply chain ecosystem was under immense strain.

Moving forward, we are committed to publishing our results, including brand names, to promote transparency and accountability. However, we are first reaching out to the affected brands to ensure they are aware of our findings and can take appropriate action. 

To address these challenges systematically, we have established the Million Marker Research Institute (MMRI), a non-profit dedicated to testing products and sharing results with consumers. Our science team is developing an innovative scoring method that combines ingredient screening with comprehensive product testing to provide a more accurate assessment of product safety. The scoring system rates chemicals on a scale from 0 to 100, with 'Slow' and 'Stop' ratings assigned to potentially harmful substances. We plan to take our findings from this testing to incorporate our scoring system and plan to share our results in a future report.

Our goal is to help people make informed choices about the products they use and encourage companies to make safer items. MMRI aims to streamline transparency from supply chain to consumer through comprehensive product testing and by sharing results in a consumer-facing portal. 

We are currently accepting donations to support the creation of this portal and fund ongoing initiatives. Immediate plans are to test invisible orthodontics, diaper rash creams, and prenatal supplements, with many other consumer products and food categories planned. Our goal is to empower consumers, brands, and suppliers alike to make informed decisions about product safety and quality. 

Invisible Orthodontics Testing

Invisible orthodontics, while offering discreet treatment, may release microplastics and chemicals like BPA into patients' bodies. 

Million Marker will test 20 invisible orthodontic appliances sourced from both dental practices and direct-to-consumer online markets safety.

Diaper Rash Cream Testing

The $1.9 billion diaper cream market is growing at 5.9% CAGR, but formulations often contain harmful chemicals like formaldehyde and parabens. These chemicals can impact infant development, potentially leading to neurodevelopmental and fertility issues. 

We're testing 30 products for dangerous contaminants to protect babies' health and future well-being. Your support will expand this crucial research.

Donate

Conclusion

Our study revealed that ingredient screening alone is insufficient to guarantee product safety. We found instances where products with seemingly safe ingredient lists still contained contaminants or adulterations, highlighting the need for comprehensive testing beyond ingredient analysis.

Surprisingly, even some products marketed as "clean" or environmentally friendly contained unlisted harmful chemicals. Although smaller brands had the most “Go” Products, products from all company sizes had contamination, emphasizing the importance of ongoing testing across the industry.

Recent regulatory changes reflect growing efforts to ensure consumer safety and minimize health risks. The U.S. Environmental Protection Agency (EPA) has proposed amendments to the Toxic Substances Control Act (TSCA) to strengthen the regulation of potentially hazardous chemicals in consumer products. The Lautenberg Chemical Safety Act requires the EPA to evaluate the safety of existing chemicals in commerce. However, the United States is far behind other nations when it comes to regulating harmful substances, especially in personal care products. 

In the European Union, the REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) program aims to protect human health and the environment from risks posed by chemicals. The EU has also committed to banning the most harmful chemicals from products like toys, cosmetics, and detergents.

These global efforts signify a growing recognition of the importance of regulating toxic substances in consumer goods and promoting the use of safer ingredients. However, our findings underscore the need for continued vigilance and comprehensive testing to ensure product safety beyond what is listed on the label.

MMRI will help streamline transparency from supply chain to consumer. We are in the process of creating a consumer-facing portal that will provide a “Purity” score based on test results and ingredients analysis, indicating the presence or absence of harmful chemicals. This will enable consumers to make educated decisions about the products they use. 

As part of this process, MMRI will reach out to the brands whose products were tested, fostering collaboration to improve product safety and quality. By streamlining transparency from supply chain to consumer, MMRI is working towards a future where consumers can trust the products they use and brands can ensure the integrity of their offering.

 

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