Lead in Lipstick: A Safety Argument Made in Public

In the autumn of 2007 the lead that worried American shoppers was in toys: lead paint had been used on toys made in China for Mattel’s brands. On 11 October 2007 a coalition called the Campaign for Safe Cosmetics published a report that began from them. “Toys made in China aren’t the only products laced with dangerous heavy metals,” it opened.^[1]

Its subject was the red lipstick, and the argument it started was conducted, from the first day, where customers could follow it.

In August 2007 members of the campaign in Boston, Hartford, Minneapolis and San Francisco bought red lipsticks at every price, from drugstores, discount chains, high-end shops and department stores. Thirty-three unopened tubes went to an accredited laboratory in California, which measured their lead by inductively coupled plasma mass spectrometry.^[2]

Twenty of them, 61 per cent, had detectable lead, at between 0.03 and 0.65 parts per million, and none listed lead as an ingredient. A third were above 0.1 parts per million, the maximum the Food and Drug Administration had recommended in 2006 for lead in sweets eaten by children.^[2] The highest readings were for two shades of L’Oréal Colour Riche, True Red and Classic Wine, and for Cover Girl Incredifull Lipcolor in Maximum Red. Dior Addict in Positive Red, at $24.50 a tube, read 0.21; a Revlon lipstick at $7.49 had no detectable lead at all.^[2]

The comparison with sweets was the report’s sharpest point. “Lipstick, like candy, is ingested directly,” it argued, and it quoted a magazine’s tip that women “inadvertently (but harmlessly) eat about 4 lbs of lipstick” in a lifetime, a figure it called commonly quoted, before rejecting the word in brackets: “the latest science shows that no level of lead is ‘harmless.’”^[3]

It was careful about what the figure for sweets was. The 0.1 parts per million had been set, the report noted, not as a safe level but as one “consistent with the FDA’s longstanding goal of reducing lead levels in the food supply” to the lowest practicable amount.^[3] And it said what it wanted: companies should test their full product lines, reformulate, require suppliers to guarantee their raw materials free of lead, and join the campaign in demanding that the FDA regulate personal care products more strictly.^[3]

The campaign was a coalition of women’s, public-health, labour, environmental and consumer groups, among them the Breast Cancer Fund, the Environmental Working Group and Friends of the Earth. It asked its readers to write to L’Oréal, to their local newspapers and to their state legislators.^[3] The argument was meant to be had in public, and it was.

The FDA’s response was to measure for itself. Reports of lead in lipstick were not new — in the 1990s the agency had found that a commercial laboratory’s method had not been validated for lipstick — and it said it could not tell whether the campaign’s laboratory had used a validated method. Its own scientists developed one, and the agency bought lipsticks of the campaign’s brands and shades between October and December 2007.^[5][6]

It found lead in every one, at between 0.09 and 3.06 parts per million, with an average of 1.07: more than the campaign had found.^[5] The campaign’s own report had warned that its figures might be low, since some samples had not fully dissolved and its laboratory had recovered, on average, only 53 per cent of a known added amount.^[7] The FDA’s method was published in the July/August 2009 issue of the Journal of Cosmetic Science, and the agency drew the opposite conclusion from the higher numbers: they were within the range expected of lipsticks made with permitted colour additives under good manufacturing practice, and not a safety concern.^[5]

The two sides agreed on more than their headlines suggested. Neither said lead had been put into lipstick on purpose. It could arrive, the campaign said, as a by-product of mined raw materials, zinc oxide and titanium dioxide among them; and the FDA limits lead as an impurity in the colour additives it approves, typically to no more than 20 parts per million for those used in cosmetics.^[8][9]

That is the difference from the older story of lead on the face, told elsewhere on this site. There, lead was the cosmetic. Here it was a trace inside one, counted in parts per million.

What grew was the scale of the inquiry. The FDA went on to buy 400 lipsticks between February and July 2010, finding an average of 1.11 parts per million; in all it analysed 685 cosmetics, found more than 99 per cent below 10 parts per million, and in December 2016 recommended that figure as a maximum for lead as an impurity in lip products and other cosmetics — in draft guidance, not a binding rule.^[10][11]

The sources disagree about what was tested. The campaign’s report counts 33 lipsticks; the FDA’s account of 2009 describes the campaign as reporting on “a selection of twenty-five lipsticks”; and the agency’s current page says it tested 20 from the campaign’s report that were still available.^[12][13][14] Some of the difference may lie in the duplicate tubes the campaign’s shoppers bought in different cities, but none of the sources says so.

Whether the amounts mattered is not settled here either. The campaign held, citing recent studies, that there was no safe level of lead; the FDA judged the levels it found too small to be a concern and the comparison with sweets invalid. This account reports both and adjudicates neither. And the four pounds of lipstick a woman is said to eat in a lifetime appears in the report only as a magazine’s tip, with no study behind it.^[12]