What’s in Your Makeup?

The beauty industry is changing. As consumers become more selective about what they put on their faces and bodies, terms like “clean,” “natural,” “organic,” and “free-from” are everywhere, promising safer and more sustainable options. But in a self-regulated industry with little oversight, what do these claims really mean?

The ABCs of cosmetics regulation

The Food and Drug Administration’s formal definition of cosmetics covers the spectrum of personal hygiene products¹United States Food and Drug Administration. Cosmetics & U.S. Law. Published February 4, 2020. https://www.fda.gov/cosmetics/cosmetics-laws-regulations/cosmetics-us-law:

“Articles intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance without affecting the body’s structure or functions.”

Everything from moisturizer and shaving cream to perfume and lipstick falls under this umbrella. However, unlike drugs or medical devices, cosmetics don’t require FDA approval before hitting store shelves.²United States Food and Drug Administration. FDA authority over cosmetics. Published 2024. https://www.fda.gov/cosmetics/cosmetics-laws-regulations/fda-authority-over-cosmetics-how-cosmetics-are-not-fda-approved-are-fda-regulated The onus is on companies to ensure their products are safe and accurately labeled, but marketing claims are often subject to interpretation.

As product label language has become increasingly murky, demand for transparency grows. Makeup marketed as “natural” might still contain synthetic preservatives, while “clean beauty” has different meanings from one brand to the next. Since each brand defines these terms according to its own standards, label information often tells us more about marketing strategy than formulation. Add rising costs and constant product innovation to the mix, and even the most informed shoppers are finding themselves confused at the beauty counter.

What does ‘clean beauty’ really mean?

Clean beauty is a concept gaining traction in cosmetics sales. Despite its growing influence on consumer choices, however, what qualifies a product as clean or natural has yet to be formally defined. Moreover, there is no designated governing body that regulates such claims.³“Natural” or “Organic” Cosmetics? Don’t Trust Marketing Claims. Environmental Working Group. https://www.ewg.org/news-insights/news/natural-or-organic-cosmetics-dont-trust-marketing-claims^,4Patrick S. H.R.5872 – 117th Congress (2021-2022): Natural Cosmetics Act. Congress.gov. Published 2021. Accessed April 30, 2025. https://www.congress.gov/bill/117th-congress/house-bill/5872^,5S.1289 – 118th Congress (2023-2024): Food Labeling Modernization Act of 2023. Published 2023. https://www.congress.gov/bill/118th-congress/senate-bill/1289

Various legislative efforts have sought to define parameters for natural cosmetics and other products. The momentum to create clearer guidelines reflects concerns about potentially misleading marketing claims.

All natural does not necessarily mean safe

Although there is a perception that “clean” products are safer, some natural ingredients, such as raw shea butter and unrefined oils, actually cause more reactions than their synthetic counterparts.⁶Lin TK, Zhong L, Santiago JL. Anti-inflammatory and skin barrier repair effects of topical application of some plant oils. Int J Mol Sci. 2017;19(1):70. https://pmc.ncbi.nlm.nih.gov/articles/PMC5796020 Even harmful substances like lead and arsenic occur naturally. What matters is understanding how the ingredients’ unique properties interact with your skin. 

What to look for with clean beauty

1. Research the brand’s definitions: Brands define “clean” differently. If the company provides its own definition or criteria, ensure they align with your needs.
2. Sourcing transparency: Look for products with detailed information on ingredient sourcing and processing.
3. Beware of potential toxins: Clean beauty advocates flag specific ingredients, including phthalates, synthetic fragrances, and PEG (polyethylene glycol) compounds, while others debate their safety. Most concerns are centered on potential links to hormone disruption, skin irritation, and environmental harm. Although some studies suggest these substances may pose minimal risk at low levels, others argue for a more precautionary approach, emphasizing the need for transparency, stricter regulation, and more independent research.

Understanding organic labels

The term “organic” in personal care products is far more complex than many realize. While the USDA regulates organic claims for food, its oversight of cosmetics focuses solely on agricultural ingredients.⁷Cosmetics, Body Care, and Personal Care Products. Agricultural Marketing Service. https://www.ams.usda.gov/grades-standards/cosmetics-body-care-and-personal-care-products?dDocName=STELPRDC5068442 This means a product can contain organic botanicals but still include synthetic preservatives or non-organic topical ingredients.

USDA–certified organic products must contain at least 95 percent organic ingredients and cannot include most synthetic pesticides or genetically modified organisms (GMOs).⁸United States Department of Agriculture. Organic Standards. Agricultural Marketing Service. Published 2019. https://www.ams.usda.gov/grades-standards/organic-standards Only these products can display the official USDA organic seal, ensuring a high standard of organic content. Other global certifications include COSMOS (Europe), Ecocert (International), and the Soil Association (UK).

On the other hand, products labeled organic without the USDA label often state that they are “made with organic ingredients.” Because this claim is not regulated, these products may contain minimal organic content, sometimes as few as one organic ingredient. Without third-party verification, such claims can be misleading, making it essential for consumers to carefully read the ingredient list. 

Organic certification is a lengthy and often costly process, particularly for smaller businesses, requiring extensive documentation and annual inspections.⁹United States Department of Agriculture. National Organic Program: How to become certified. Archived October 21, 2014. https://web.archive.org/web/20141021010613/http://www.ams.usda.gov/AMSv1.0/NOPFAQsHowCertified As a result, some products or ingredients may fully align with organic principles without carrying official certification, instead using alternative phrasing to reflect their standards.

How to shop organic

1. Check the percentage of organic ingredients: Look for products that fully disclose their organic content percentage, aiming for higher thresholds.
2. Look for the USDA organic seal: If certification is important to you, choose products with the USDA organic seal, which verifies strict standards.
3. Research the brand’s practices: Some small brands may adhere to organic principles but cannot afford certification. Look for transparency in sourcing and sustainability practices.
4. Think beyond organic: Evaluate sustainability and ethical practices, such as eco-friendly packaging or fair trade sourcing, which often accompany organic claims but are not guaranteed by them.

‘Free-from’ and ‘x-free’ marketing

The FDA doesn’t mandate pre-approval for cosmetic ingredients (except color additives), only requiring that cosmetics be safe when used as directed and properly labeled.¹⁰United States Food and Drug Administration. Cosmetics Labeling Claims. Published May 29, 2020. https://www.fda.gov/cosmetics/cosmetics-labeling/cosmetics-labeling-claims This minimal oversight lags far behind the European Union (EU), which has banned nearly 2,000 beauty product chemicals. Only 11 such restrictions apply in the United States.

Against this regulatory backdrop, many brands employ “free-from” marketing, highlighting the absence of certain ingredients that are considered controversial. However, this practice can mislead consumers who aren’t fully informed. When an ingredient is removed from a formulation, it’s typically replaced with an alternative that serves the same function. Substitutes often have less research supporting their efficacy and safety than the original ingredients they replace.

Common claims and their context

Paraben-free

Parabens are a controversial group of FDA–approved preservatives commonly found in water-based products such as shampoos, conditioners, and lotions.¹¹U.S. Food and Drug Administration. Parabens in Cosmetics. Published February 25, 2022. https://www.fda.gov/cosmetics/cosmetic-ingredients/parabens-cosmetics They are permitted in most countries, with industry guidelines recommending concentration limits (0.4 percent for single parabens, 0.8 percent total).¹²Cherian P, Zhu J, Bergfeld WF, et al. Amended safety assessment of parabens as used in cosmetics. Int J Toxicol. 2020;39(1_suppl):5S-97S. https://doi.org/10.1177/1091581820925001 In 2014, the EU lowered maximum allowable concentrations of butyl- and propylparaben in cosmetics to 0.14 percent and banned them entirely for children’s products.

Types of parabens

• Methylparabens
• Ethylparabens
• Butylparabens
• Propylparabens

Potential health concerns

• Reproductive impacts, as indicated in some studies suggest on propyl- and butylparaben.¹³Darbre PD, Harvey PW. Paraben esters: review of recent studies of endocrine toxicity, absorption, esterase and human exposure, and discussion of potential human health risks. J Appl Toxicol. 2008 Jul;28(5):561-78. https://doi.org/10.1002/jat.1358
• Endocrine disruption is particularly linked to butyl- and propylparaben.¹⁴Hass U, Christiansen S, Andersen D, et al. List of Endocrine Disrupting Chemicals Final Report, December 21, 2017. Danish Centre on Endocrine Disrupters. http://cend.dk/files/DK_ED-list-final_2018.pdf^,15Overview Report I: Worldwide Initiatives to Identify Endocrine Disrupting Chemicals (EDCs) and Potential EDCs. The International Panel on Chemical Pollution. 2017. https://wedocs.unep.org/bitstream/handle/20.500.11822/25633/EDC_report1.pdf?sequence=1&isAllowed=y
• UV–induced skin damage is associated with methylparaben.¹⁶Handa O, Kokura S, Adachi S, et al. Methylparaben potentiates UV-induced damage of skin keratinocytes. Toxicology. 2006;227(1-2):62-72. https://doi.org/10.1016/j.tox.2006.07.018

Paraben-free products typically use alternative preservatives like phenoxyethanol and sodium benzoate. Before buying, make sure the item checks off these four musts:

1. Effectiveness in protecting against microbial growth
2. Safety testing and evaluation
3. Product stability
4. Reasonable expiration date

Phthalate-free

Phthalates are a group of chemicals used as plasticizers or fragrance stabilizers and commonly found in nail polish, perfumes, and eyelash glue. Phthalates are often hidden under the term “fragrance,” making it difficult for consumers to identify them.

Types of phthalates

• Dibutyl phthalate (DBP)*
• Diethyl phthalate (DEP)
• Di–2–ethylhexylphthalate (DEHP)*

*DBP and DEHP are banned in the EU but remain legal in the United States.¹⁷Monti M, Fasano M, Palandri L, Righi E. A review of European and international phthalates regulation: focus on daily use products. Eur J Public Health. 2022;32(Suppl 3):ckac131.226. https://doi.org/10.1093/eurpub/ckac131.226

Potential health concerns

• Endocrine disruption. DBP and DEHP are known to disrupt hormones, with effects on reproductive development.¹⁸Hlisníková H, Petrovičová I, Kolena B, Šidlovská M, Sirotkin A. Effects and mechanisms of phthalates’ action on reproductive processes and reproductive health: a literature review. Int J Environ Res Public Health. 2020;17(18):6811. https://doi.org/10.3390/ijerph17186811
• Reproductive toxicity. Increased male infertility and reduced sperm quality are associated with DEP and DEHP exposure.¹⁹Khasin LG, Della Rosa J, Petersen N, Moeller J, Kriegsfeld LJ, Lishko PV. The impact of di-2-ethylhexyl phthalate on sperm fertility. Front Cell Dev Biol. 2020;8:426. https://doi.org/10.3389/fcell.2020.00426
• Cancer. DEHP is classified as a possible human carcinogen, and DBP has been associated with breast tumor proliferation.²⁰Centers for Drug Control and Prevention. Agency for Toxic Substances and Disease Registry. ToxFAQs for phthalates. Published 2024. https://wwwn.cdc.gov/TSP/ToxFAQs/ToxFAQsDetails.aspx?faqid=377&toxid=65^,21Centers for Drug Control and Prevention. Agency for Toxic Substances and Disease Registry. Toxicological profile for phthalates. Published 2024. https://www.atsdr.cdc.gov/toxprofiles/tp9-c1-b.pdf^,22Chen FP, Chien MH. Lower concentrations of phthalates induce proliferation in human breast cancer cells. Climacteric. 2014;17(4):377-384. https://doi.org/10.3109/13697137.2013.865720^,23Hsieh TH, Tsai CF, Hsu CY, et al. Phthalates induce proliferation and invasiveness of estrogen receptor-negative breast cancer through the AhR/HDAC6/c-Myc signaling pathway. FASEB J. 2012;26(2):778-787. https://doi.org/10.1096/fj.11-191742

Phthalate-free products often replace these chemicals with safer alternatives. However, it is important to evaluate products for three key components:

1. Transparency in labeling, especially with fragrances
2. Safety profiles and regulatory compliance
3. Product stability and performance

Sulfate-free

Sulfates are a group of surfactants commonly used in shampoos, body washes, and cleansers for their foaming and cleansing properties.

Common sulfates

• Sodium lauryl sulfate (SLS)
• Sodium laureth sulfate (SLES)

Sulfates are approved for use globally but avoided by some consumers due to the potential for irritation.

Health concerns

• Skin and scalp irritation. SLS can strip the scalp and skin of natural oils, leading to dryness and irritation, especially for people with sensitive skin.²⁴Leoty-Okombi S, Gillaizeau F, Leuillet S, et al. Effect of sodium lauryl sulfate (SLS) applied as a patch on human skin physiology and its microbiota. Cosmetics. 2021;8(1):6. https://doi.org/10.3390/cosmetics8010006 
• Curl pattern disruption. SLS can also change the natural texture and definition of curly or coily hair, making it more prone to frizz and breakage.²⁵Gavazzoni Dias MFR. Hair cosmetics: an overview. Int J Trichology. 2015;7(1):2-15. https://pubmed.ncbi.nlm.nih.gov/25878443
• Environmental impact. Sulfates are not easily biodegradable and can pollute water.

Sulfate-free products typically use gentler surfactants, such as cocamidopropyl betaine or sodium cocoyl isethionate. Although these products are getting more and more effective at cleansing, some people feel they cannot build as much lather and aren’t as compatible with as many types of hair.

Silicone-free

Silicones are synthetic ingredients used in hair and skincare products to enhance spreadability, create a protective barrier, and provide a smooth, silky texture.

Common silicones

• Dimethicone
• Cyclopentasiloxane
• Cyclohexasiloxane
• Amodimethicone

Silicones are widely approved for use and considered safe; however, some consumers find them too heavy for daily use and are concerned about environmental effects. Silicones may inhibit the absorption of other beneficial ingredients in skincare products.

Silicone-free products often incorporate natural or plant-derived alternatives, such as argan oil, jojoba oil, shea butter, aloe vera, and glycerin, to provide similar benefits:

1. Smoothness and hydration
2. Detangling
3. Gentler environmental impact and biodegradability

How to avoid potentially harmful ingredients

1. Research alternatives. If a product claims to be “free” of a specific ingredient, determine which ingredients take its place and whether they meet your needs.
2. Download a consumer app. Tools like Yuka and EWG’s Skin Deep decode ingredient lists and define their safety and purpose.
3. Make your own! Formulating personal products like makeup and skincare at home allows full control over ingredients and eliminates unnecessary substitutions.

Building your toolkit

Navigating the world of cosmetic marketing can feel overwhelming, but knowledge is on your side. There’s no need to change everything overnight.  Consider a “slow swap” strategy, replacing products gradually as you finish them, and giving your skin the time it needs to adapt. With each small step, you’ll build deeper understanding, greater confidence, and a routine that truly works for you.

Footnotes

• 1
  United States Food and Drug Administration. Cosmetics & U.S. Law. Published February 4, 2020. https://www.fda.gov/cosmetics/cosmetics-laws-regulations/cosmetics-us-law
• 2
  United States Food and Drug Administration. FDA authority over cosmetics. Published 2024. https://www.fda.gov/cosmetics/cosmetics-laws-regulations/fda-authority-over-cosmetics-how-cosmetics-are-not-fda-approved-are-fda-regulated
• 3
  “Natural” or “Organic” Cosmetics? Don’t Trust Marketing Claims. Environmental Working Group. https://www.ewg.org/news-insights/news/natural-or-organic-cosmetics-dont-trust-marketing-claims
• 4
  Patrick S. H.R.5872 – 117th Congress (2021-2022): Natural Cosmetics Act. Congress.gov. Published 2021. Accessed April 30, 2025. https://www.congress.gov/bill/117th-congress/house-bill/5872
• 5
  S.1289 – 118th Congress (2023-2024): Food Labeling Modernization Act of 2023. Published 2023. https://www.congress.gov/bill/118th-congress/senate-bill/1289
• 6
  Lin TK, Zhong L, Santiago JL. Anti-inflammatory and skin barrier repair effects of topical application of some plant oils. Int J Mol Sci. 2017;19(1):70. https://pmc.ncbi.nlm.nih.gov/articles/PMC5796020
• 7
  Cosmetics, Body Care, and Personal Care Products. Agricultural Marketing Service. https://www.ams.usda.gov/grades-standards/cosmetics-body-care-and-personal-care-products?dDocName=STELPRDC5068442
• 8
  United States Department of Agriculture. Organic Standards. Agricultural Marketing Service. Published 2019. https://www.ams.usda.gov/grades-standards/organic-standards
• 9
  United States Department of Agriculture. National Organic Program: How to become certified. Archived October 21, 2014. https://web.archive.org/web/20141021010613/http://www.ams.usda.gov/AMSv1.0/NOPFAQsHowCertified
• 10
  United States Food and Drug Administration. Cosmetics Labeling Claims. Published May 29, 2020. https://www.fda.gov/cosmetics/cosmetics-labeling/cosmetics-labeling-claims
• 11
  U.S. Food and Drug Administration. Parabens in Cosmetics. Published February 25, 2022. https://www.fda.gov/cosmetics/cosmetic-ingredients/parabens-cosmetics
• 12
  Cherian P, Zhu J, Bergfeld WF, et al. Amended safety assessment of parabens as used in cosmetics. Int J Toxicol. 2020;39(1_suppl):5S-97S. https://doi.org/10.1177/1091581820925001
• 13
  Darbre PD, Harvey PW. Paraben esters: review of recent studies of endocrine toxicity, absorption, esterase and human exposure, and discussion of potential human health risks. J Appl Toxicol. 2008 Jul;28(5):561-78. https://doi.org/10.1002/jat.1358
• 14
  Hass U, Christiansen S, Andersen D, et al. List of Endocrine Disrupting Chemicals Final Report, December 21, 2017. Danish Centre on Endocrine Disrupters. http://cend.dk/files/DK_ED-list-final_2018.pdf
• 15
  Overview Report I: Worldwide Initiatives to Identify Endocrine Disrupting Chemicals (EDCs) and Potential EDCs. The International Panel on Chemical Pollution. 2017. https://wedocs.unep.org/bitstream/handle/20.500.11822/25633/EDC_report1.pdf?sequence=1&isAllowed=y
• 16
  Handa O, Kokura S, Adachi S, et al. Methylparaben potentiates UV-induced damage of skin keratinocytes. Toxicology. 2006;227(1-2):62-72. https://doi.org/10.1016/j.tox.2006.07.018
• 17
  Monti M, Fasano M, Palandri L, Righi E. A review of European and international phthalates regulation: focus on daily use products. Eur J Public Health. 2022;32(Suppl 3):ckac131.226. https://doi.org/10.1093/eurpub/ckac131.226
• 18
  Hlisníková H, Petrovičová I, Kolena B, Šidlovská M, Sirotkin A. Effects and mechanisms of phthalates’ action on reproductive processes and reproductive health: a literature review. Int J Environ Res Public Health. 2020;17(18):6811. https://doi.org/10.3390/ijerph17186811
• 19
  Khasin LG, Della Rosa J, Petersen N, Moeller J, Kriegsfeld LJ, Lishko PV. The impact of di-2-ethylhexyl phthalate on sperm fertility. Front Cell Dev Biol. 2020;8:426. https://doi.org/10.3389/fcell.2020.00426
• 20
  Centers for Drug Control and Prevention. Agency for Toxic Substances and Disease Registry. ToxFAQs for phthalates. Published 2024. https://wwwn.cdc.gov/TSP/ToxFAQs/ToxFAQsDetails.aspx?faqid=377&toxid=65
• 21
  Centers for Drug Control and Prevention. Agency for Toxic Substances and Disease Registry. Toxicological profile for phthalates. Published 2024. https://www.atsdr.cdc.gov/toxprofiles/tp9-c1-b.pdf
• 22
  Chen FP, Chien MH. Lower concentrations of phthalates induce proliferation in human breast cancer cells. Climacteric. 2014;17(4):377-384. https://doi.org/10.3109/13697137.2013.865720
• 23
  Hsieh TH, Tsai CF, Hsu CY, et al. Phthalates induce proliferation and invasiveness of estrogen receptor-negative breast cancer through the AhR/HDAC6/c-Myc signaling pathway. FASEB J. 2012;26(2):778-787. https://doi.org/10.1096/fj.11-191742
• 24
  Leoty-Okombi S, Gillaizeau F, Leuillet S, et al. Effect of sodium lauryl sulfate (SLS) applied as a patch on human skin physiology and its microbiota. Cosmetics. 2021;8(1):6. https://doi.org/10.3390/cosmetics8010006
• 25
  Gavazzoni Dias MFR. Hair cosmetics: an overview. Int J Trichology. 2015;7(1):2-15. https://pubmed.ncbi.nlm.nih.gov/25878443