'Certified Safe' Personal Care Labels Skip Lab Testing of the Actual Product, Analysis Finds

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

"Certification programs check the recipe. Nobody checks the cake," said Johanna R. Rochester, the review's lead author and a senior scientist at the Million Marker Research Institute. Researchers reviewed 18 certification and ingredient-screening programs used in the US and European markets, including MADE SAFE, the Environmental Working Group, COSMOS, the EU Ecolabel and EPA Safer Choice, plus retailer standards like Clean at Sephora, and consumer apps such as Yuka. Of the 16 programs designed to evaluate chemical hazards, none required routine testing of finished products, and none used non-targeted analysis, a lab method that can screen for thousands of chemicals at once.

The gap matters: a companion study found unlabeled chemicals in nearly all 113 personal care and cleaning products it tested, most with at least one carrying a known or suspected health hazard, and one in four contradicting a package claim — including "phthalate-free" products that contained phthalates. Regulators follow a similar pattern: US and EU rules rest mainly on ingredient restrictions and manufacturer documentation rather than routine finished-product testing, though the EU requires a premarket safety assessment and a legally accountable person for each product.

The authors propose adding laboratory testing as a complementary layer, starting with voluntary programs and high-exposure products such as those used by babies and pregnant women. Between 2011 and 2023, 334 skin care products covering more than 77 million units were recalled in the US. "The only way to know what's in a product is to send it to a lab yourself," said Jenna Hua, the study's senior author and founder of the Million Marker Research Institute. "That's unfair to ask of a consumer, but reasonable to ask of a certifier."