I’ve accidentally bumped onto a research paper published in the Archives of Toxicology which writes about a very worrying concept. In this paper the authors claim that not all commercialised cosmetics in European countries follow the EU regulations for safety. They went as far as picking 163 samples, specifically skin whitening products, of which 40% of them contained a potent corticosteroid clobetasol propionate and about 12% were found to contain tretinoin or hydroquinone.
The mentioned substances are usually found in pharmaceuticals, not cosmetics, and therefore the regulations on how they are to be used, at what quantities and for what application are very different. Such ingredients should not be found in non-prescription cosmetics.
The authors conducted this study in the Belgian market but others reported similar results when they analysed the Dutch and French markets.[1, 2, 3] As a result, it is possible that this is a widespread EU phenomenon and perhaps even worldwide?
Bear in mind though that the regulations are different for non-EU countries and it might be that in other countries it is acceptable to find medical ingredients in cosmetics, at certain levels. I really hope that is not the case. Usage of medical compounds without any medical supervision or instruction can lead to serious side effects and in some cases even health problems. When such ingredients are found in cosmetic products that are used frequently (how many times a day would you use a cosmetic? 1-2? Everyday? And over how many years?) our exposure to such ingredients could even be higher than what it would be when they are contained in medicinal products.
In their paper titled “Illegal cosmetics on the EU market: a threat for human health?” the authors specifically targeted skin whitening products  so there is no need to panic about all the cosmetics you own. If you are using skin whitening products perhaps make sure to buy them from reputable brands, not that this guarantees they are safe but one would hope that the chances are higher as big cosmetic companies would have more resources, money, knowledge and wouldn’t really want to be sued for millions of pounds. Not only by the consumers but also by the EU for breaking the law.
In a further follow up research paper they looked into 163 suspected products in Belgium picked up from what they labelled as “high risk sites”, airports and ethnic cosmetic shops. From those 163 products a staggering 59% of them contained illegal compounds and are therefore illegally on the market. 
Legal whitening agents include salicylic acid and kojic acid and are also the two most commonly found in this study. However, the third most commonly found agent was clobetasol propionate, in 40% of samples, which is illegal.  Other agents found such as arbutin is legal however it’s safety status is still questionable and is being evaluated by the Scientific Committee on Consumer Safety.  Hydroquinone was found in 12% of the samples and tretinoin in 11%, both of which are illegal. 
Interestingly, this study showed that it was fairly common practise for whitening products to contain two illegal ingredients in combination instead of just one. Additionally, the quantities of these illegal substances contained in these products were found to be sometimes over the acceptable limits even if they were to be contained in medicinal products. For example, hydroquinone is illegal in cosmetics because it can cause side effects but is legal in medicinal products as it requires medical supervision. However, even in medicinal products it is usually found anywhere between 1-5% as opposed to the 5.22-11.86% found in some of the skin whitening products. 
These illegal cosmetics should either have those ingredients removed or go through medicinal evaluation processes and legality. It goes without saying that in order to be approved as a product for medicinal use, the process is much more complicated, long, detailed, time and money consuming and perhaps this is something that some of these companies are hoping to avoid.
Unfortunately, the authors also noticed that some skin bleacher products also contained allergic fragrances which obviously they shouldn’t and even worse they didn’t even include them in the ingredient list on the product labels.  The EU laws on cosmetics are fairly strict about not listing ingredients, it is based on % of compound contained (0.001% by weight for leave on products and 0.01% by weight for rinse off products), and it is otherwise illegal in the EU to not state all ingredients contained from a certain concentration level and above  and it might also fall under misleading and false advertising.
The authors express their concern about the presence of perhaps also other inappropriate ingredients which they haven’t yet tested for, such as banned preservatives and UV-filters, both of which are EU regulated compounds and are often used in skin whitening products.  The authors deem any cosmetics with inappropriate medicinal, allergic fragrances, banned preservatives and UV-filters as unsafe for public health and call for action and further analysis of the market.
As a professional chemist, abuse of chemical compounds in situations where they are not meant to be used saddens me greatly. Because of some peoples’ and companies’ irresponsible behaviour chemicals are stuck with the “dangerous label” which is not accurate. Like with everything in life, everything has its use and when misused or even abused it will have some negative effects. It’s a real shame and I hope this does not add any further to the chemical fear that our society seems to be paralysed from. The fault here lies with the irresponsible companies that are marketing products as cosmetics when they are clearly not quite that. The fault does not lie with “dangerous chemicals” etc. All compounds have their uses and these are meant to be medicinal, not cosmetic. Used less frequently and for certain conditions. This article is meant to inform and does not in any way intent to fuel the fear of chemicals trend.
If you are using skin whitening products perhaps it is better if you reconsider it all together. Not just because the products you are using might be unsafe but also one might argue that there is really no need for it. There is beauty in all skin colours, embrace it and perhaps invest your money in products than enhance and even out your skin tone in less aggressive ways, like for example the right foundation colour, a good concealer or a complimentary blush. But if you really must use such products because of your personal preference, cultural, political and socio-economic, aesthetic and sometimes even medical reasons [4, 5, 6] then select them carefully and choose a large known brand.
Unfortunately, the authors did not give a “name and shame” list of products and brands perhaps because as scientists it is not their job to discipline. I truly hope that the EU and local authorities are in a possession of such list and are working towards validating these scientists’ results and evaluating the situation.
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