Dangerous cosmetics, and what the record actually shows
The pattern is consistent enough to be predictive. The workers are harmed first, the users second, the regulation arrives third, and the market moves somewhere without regulation.
Documented cases of serious harm from cosmetic products include lead and mercury preparations over centuries, radium containing products in the 1920s and 1930s, thallium based depilatories, and a coal tar lash and brow dye that caused eye injuries including blindness and contributed to the 1938 United States federal legislation. The recurring pattern is that manufacturing workers are harmed first and most visibly, regulation follows a specific documented injury, and unregulated supply chains remain the persistent risk.
This magazine spends a good deal of its time correcting exaggerated stories about historical cosmetic harm. It would be a poor showing to leave the impression that there was none. There was a great deal, it is well documented, and the documented cases are considerably grimmer than the invented ones, because they come with names, dates, court records and post mortem findings.
What follows is a set of cases that are established. The point of assembling them is not horror. It is that they have a shape, and the shape recurs.
Lead and mercury, the long ones
Lead white on the face is covered at length in its own essay. The short version is that a known poison was used as a cosmetic for around two thousand years, that its dangers were described in antiquity and repeatedly afterwards, and that it was displaced by industrial alternatives and factory regulation rather than by moral argument.
Mercury runs alongside it and lasted longer in some applications. Mercury compounds appeared in skin preparations, particularly for lightening and for treating blemishes, and in the manufacture of mirrors, where the amalgam process poisoned the workers who applied it, as noted in the mirror essay. Mercury is now a prohibited substance in cosmetics in regulated markets. It continues to be found in skin lightening products supplied outside those markets, and public health authorities including in the United Kingdom have issued repeated warnings and taken enforcement action.
Radium
The most notorious episode in the history of cosmetic harm is radium, and it divides into two distinct stories that are often conflated.
The first is occupational. Women employed to paint luminous radium based paint onto watch and instrument dials, principally in the United States in the 1910s and 1920s, were instructed or permitted to shape their brushes with their lips, ingesting radium. The consequences included severe bone necrosis, particularly of the jaw, anaemia and cancers. The resulting litigation is a landmark in occupational health law and the case is extensively documented in court records, medical literature and subsequent historical work.
The second is consumer. Radium and thorium containing preparations were marketed for health and beauty in several countries during the 1920s and 1930s, on the strength of radioactivity's association with energy and vitality. A French range of face creams and powders containing radioactive materials was sold under a brand explicitly referencing thorium and radium. Products of this type were withdrawn as the hazards became undeniable, and the regulatory response in the United States is bound up with the 1938 legislation described below.
What makes radium a clarifying case is the sequence. The occupational harm was visible, concentrated, attributable and litigated. The consumer harm was diffuse and much harder to demonstrate. Regulation followed the visible harm, which is the general rule.
Thallium
Depilatory preparations containing thallium acetate were sold in the early twentieth century. Thallium is acutely toxic and causes hair loss, which is precisely why it was used, and it also causes severe neurological damage, gastrointestinal injury and death. The harm caused by these products is documented in the medical literature of the period and in regulatory history.
Products of this kind featured in a display assembled by the American food and drug regulator in the 1930s, exhibited to demonstrate the inadequacy of the existing law, and known informally by a name referencing a chamber of horrors. It was, in effect, a lobbying exhibit, and an effective one.
The lash dye
The case with the clearest legislative consequence is the coal tar derived eyelash and eyebrow dye sold in the United States in the 1930s, discussed in the colour regulation essay. It contained a paraphenylenediamine derivative, users suffered severe eye injury including ulceration and reported blindness, and the federal regulator had no authority over cosmetics at all under the 1906 law.
The episode was a central exhibit in the campaign for the Federal Food, Drug, and Cosmetic Act of 1938, which brought cosmetics within federal jurisdiction and established colour additive certification. It is one of the best documented instances anywhere of a specific injury producing a specific statute.
- The claim
- Modern cosmetics are full of dangerous chemicals, and regulation is essentially the same as it was a century ago because the industry is unregulated.
- Where it appears to come from
- A claim advanced in various forms by commercial actors selling alternatives, by campaigning organisations, and in general online discussion. It draws force from the genuinely appalling historical cases and from the real fact that cosmetics are regulated differently from medicines.
- What is actually established
- Established: serious harm occurred repeatedly before modern regulation, and the historical cases are real. Established: cosmetics in Great Britain and the European Union are subject to a positive list of permitted colourants, a list of prohibited substances, a list of restricted substances, mandatory safety assessment before placing on the market, responsible person requirements, mandatory ingredient labelling and post market surveillance. Established: this is a substantial regime, maintained by scientific committees whose published opinions can be read. Not established: that it is unregulated or unchanged. The genuine current problems are supply outside the regime, counterfeits, unlicensed procedures and imported traditional preparations, all of which are failures of enforcement and of supply chain control rather than of the rules.
The pattern
Assemble the cases and a sequence emerges that holds across three centuries.
One: the workers first. White lead scrapers, mirror silverers, radium dial painters, matchmakers, dye workers. Occupational harm is concentrated, attributable and visible, which makes it the first thing anyone can act on.
Two: the users second, and less legibly. Consumer harm is diffuse, delayed and easy to attribute to something else, which is why it took two thousand years for lead cosmetics to disappear.
Three: regulation follows a named injury. Not a theory, not a risk assessment, not a general concern. A specific documented harm with identifiable victims. Every major step in cosmetic regulation traces back to one.
Four: the market relocates. When a substance is prohibited in a regulated market, production and sale move to channels the regulator cannot reach. This is the current position with mercury in skin lightening products and lead in traditional eye preparations, and it is the reason the present tense of this history is a customs and enforcement problem rather than a chemistry one.
Regulation has never followed a theory. It has followed a named person with a documented injury, every single time.
Where the risk actually sits now
Four places, in rough order of significance, and none of them is the ingredient list of a product bought from a mainstream retailer in a regulated market.
Products supplied outside the regime. Imported traditional cosmetics, unregulated skin lightening preparations and goods bought from sellers outside the jurisdiction. This is where the documented contamination cases have been found.
Counterfeits. Fake versions of branded cosmetics have been found to contain contaminants and to be manufactured without any hygiene control.
Procedures rather than products. Injectable and device based cosmetic treatments performed by untrained operators sit in a regulatory space that has been reviewed repeatedly in the United Kingdom and remains less controlled than the products regime.
Individual sensitisation. Allergic contact dermatitis, particularly to hair dye components and to fragrance allergens, is common, is not prevented by a permitted list, and is the most likely adverse event any individual reader will actually encounter.
That is a duller list than radium face cream. It is also the one that matters, and getting from the first to the second took a century of people being harmed while the record was assembled.
Where to look
Readers who want to go further should start with the holdings themselves rather than with summaries of them. The Wellcome Collection and the US Food and Drug Administration both publish catalogue and research material relevant to this article. Both links are given for reference only. Neither institution has been assessed by us, neither has any connection to this magazine, and nothing here is an endorsement of any organisation.
Questions readers send us
What happened to the radium dial painters?
Women employed to paint luminous radium based paint onto dials, principally in the United States in the 1910s and 1920s, ingested radium by shaping brushes with their lips. The consequences included severe bone necrosis, anaemia and cancers. The resulting litigation is a landmark in occupational health law and is extensively documented.
Were radium cosmetics really sold?
Yes. Radium and thorium containing preparations were marketed for health and beauty in several countries during the 1920s and 1930s, on the strength of radioactivity's association with vitality. They were withdrawn as the hazards became undeniable.
What was the lash dye case?
A coal tar derived eyelash and eyebrow dye sold in the United States in the 1930s containing a paraphenylenediamine derivative. Users suffered severe eye injuries including reported blindness, and the regulator had no authority over cosmetics. The case featured prominently in the campaign that produced the Federal Food, Drug, and Cosmetic Act of 1938.
Are cosmetics regulated today?
Substantially. In Great Britain and the European Union there are positive lists of permitted colourants, lists of prohibited and restricted substances, mandatory safety assessment before a product is placed on the market, responsible person requirements, mandatory ingredient labelling and post market surveillance. The scientific committee opinions behind restrictions are published.
Where is the real risk now?
In products supplied outside the regulated system, including imported traditional preparations and unregulated skin lightening products; in counterfeits; in procedures performed by untrained operators; and in individual allergic sensitisation, particularly to hair dye components and fragrance allergens, which no permitted list can prevent.
- Wellcome Collection History of occupational disease, toxicology and industrial medicine.
- US Food and Drug Administration Regulatory history of cosmetics in the United States, including the events preceding the 1938 Act.
- legislation.gov.uk Cosmetic product safety regulation as it applies in Great Britain.
- Medicines and Healthcare products Regulatory Agency Guidance and enforcement relating to unlicensed and unsafe products.
- PubMed Indexes the toxicology and dermatology literature on cosmetic adverse effects and contact allergy.
The Gazette, four times a year
One long letter a quarter: what we have been reading, what turned out to be untrue, and what is worth going to see. No selling, because we have nothing to sell you.
Sponsor lineEach issue carries one sponsor line, labelled as such and set apart from the writing. Sponsors are shown the rate card, never the copy. See the rate card.