Research and analysis

Action limits for heavy metal impurities in cosmetic products

An independent research report.

Documents

Details

This research was carried out when OPSS was within the Department for Business, Energy and Industrial Strategy.

Summary

This study was commissioned by the Office for Product Safety and Standards (OPSS) from LGC. It investigates the feasibility of developing UK guidance for technically unavoidable levels of antimony, arsenic, cadmium, lead and mercury impurities in cosmetic products. It comprises a literature review and the results of the testing of 91 cosmetic products purchased from high street and online retailers.

Details

While the existing regulations prohibit antimony, arsenic, cadmium, lead and mercury in cosmetic products, small trace quantities of these heavy metals are exempt if they are technically unavoidable under good manufacturing practice and not harmful to the health of the user. They can arise due to impurities of the natural or synthetic ingredients, or from the production process, storage, or migration from packaging.

Guidance on technically unavoidable levels of traces, otherwise known as ‘action limits’, can aid businesses in quality assurance of their products by providing target concentrations that manufacturers can ensure they do not exceed. To date, OPSS has not produced official guidance specifying target concentrations for certain elements or product types, and this report does not propose specific levels of heavy metal contamination to be taken as action limits from the testing performed.

This research provides several key outputs:

  1. An analysis of a range of methods available to determine the trace concentrations of antimony, arsenic, cadmium, lead and mercury in a range of cosmetic products.
  2. A validated method to measure the concentrations of these elements in cosmetic products.
  3. A review of action limits, and the methodologies used to obtain them, in other jurisdictions.

The report identifies that very low concentrations of heavy metals are obtainable in cosmetic products across the world. Standards are available in the UK for both heavy metal measurement, and for achieving and maintaining good manufacturing practices.

Manufacturers of cosmetic products for the UK market should always be aware of trace contamination to meet their responsibilities in demonstrating the safety of cosmetic products with respect to such contaminants through the cosmetic product safety report.

If further official guidance for action limits for heavy metals in cosmetics is proposed, OPSS will engage with industry and enforcement authorities to ensure the route to establishing such limit values is clear to all stakeholders.

Published 16 March 2023