Published March 2026

Introduction

In 2011, Victoria St. Martin, a Black woman and a journalist, was diagnosed with breast cancer. She was only thirty years old when she discovered a lump. After seeking medical care and having surgery, St. Martin searched for more information about breast cancer and how this had happened to her, given that no one in her family had breast cancer. She soon found and volunteered for a study on Black women and breast cancer. The researcher asked her a series of questions during the survey:

Have you ever permed your hair? Yes
How old were you when you had your first perm? About ten years old.
How often did you perm your hair? About once a month.
Did you ever have burns? Yes, every time.

St. Martin paused and asked why the researcher was posing such detailed questions about personal care products in a study about Black women and breast cancer. At the end of the survey, the researcher explained that they were looking into the possible connection between hair products and cancer—a connection they later discussed in published studies.¹

St. Martin’s participation in that study began her personal and professional journey into researching the link between personal care products and breast cancer. As she connected with a community of other young breast cancer survivors, she learned that everyone was talking about personal care products—which ones were safer and which ones should be tossed because of toxic chemicals. She quickly made several changes: she stopped using relaxers, threw out products containing harmful chemicals, and began carefully reading product labels. She wondered, however, why it seemed like only breast cancer survivors were talking about these products when everyone should know about the health risks. Using her journalistic skills, she started to extensively research and write about this issue to inform others of the risks associated with everyday personal care products, particularly those marketed to Black women.²

This Brief discusses how toxic chemical exposure from hair care products marketed and available to Black women contributes to racial health disparities. It aims to help consumers make informed choices and to encourage policymakers to fund further research and strengthen regulations. Environmental exposure to toxic chemicals, particularly exposure from personal care products, is an often-overlooked contributor to health disparities. A growing body of research has found that many personal care products have concerning ingredients that can negatively impact health, from carcinogens and endocrine-disrupting chemicals to unknown ingredients masked under the label of “fragrance.”³ Researchers have also found that repeated exposure to these chemicals through regularly used products can lead to serious health consequences.⁴ While further research is needed, studies suggest that environmental exposure to these chemicals is heightened for Black women, who purchase nine times more beauty products than other racial groups;⁵ disproportionately use some of the most concerning products, like hair relaxers; and have fewer safe products marketed and available to them.

Given the potential adverse health effects, there is an urgent need for both greater scrutiny of these widely and regularly used products and greater government regulation to protect Black women’s health and safety. For decades, however, the federal government has under-regulated personal care products, failing to take steps to restrict toxic chemical ingredients or to recall harmful products. While recent changes in federal law are a step in the right direction, and many states are now passing their own cosmetics regulations to fill in the gaps, much more is needed to adequately protect all consumers from harmful chemicals in products.

This Brief argues that further cosmetics regulation is necessary to improve consumer access to safe choices, protect public health, and reduce racial health disparities. Part I of the Brief provides an overview of racial health disparities that harm Black women. Part II addresses how both individual choices and external forces contribute to racial disparities in the risks from personal care products, particularly hair products. Part III describes how certain hair products regularly used by Black women increase their exposure to harmful chemicals that are linked to adverse health outcomes. Part IV summarizes the current state of government regulation of personal care products, including recent reforms. Finally, Part V provides recommendations for policymakers and consumers to improve the safety of personal care products and public health.

Part I

Racial Health Disparities Affecting Black Women

Racial and ethnic health disparities persist in the United States,⁶ particularly around reproductive health. Compared to white women, Black women face worse outcomes for breast cancer and uterine cancer;⁷ higher rates of hormone-mediated health problems, like early puberty and uterine fibroids;⁸ and a higher prevalence of pregnancy-related morbidity and mortality, even when accounting for differences in socioeconomic status.⁹

Fig. 1

To effectively address these health disparities harming Black women, it is important to understand the factors driving them. This includes environmental exposure from personal care products. The American College of Obstetricians and Gynecologists (ACOG) has acknowledged the connection between reproductive health concerns and personal care products marketed to communities of color. ACOG stated in opinions issued in 2013 and 2021 that exposure to toxic environmental chemicals, including through personal care products, threatens reproductive and developmental health, with marked vulnerabilities for communities of color.¹⁰

The toxic environmental chemicals found in personal care products include endocrine-disrupting chemicals (EDCs), formaldehyde, fragrance, and heavy metals.¹¹ While each of these chemicals can have adverse health effects, EDCs are of particular concern as a potential driver of racial disparities in women’s health. Nationally representative data of reproductive-aged women in the United States suggest that women of color have higher levels of certain EDCs, such as phthalates and parabens, in their bodies compared to white women.¹² The difference in exposure to these chemicals across a lifetime may contribute to the disparities in health outcomes.¹³

EDCs are natural or synthetic chemicals that may mimic, block, or interfere with the body’s hormones. Even extremely small changes to hormone signaling and regulation from EDCs can lead to significant adverse health effects, including immune disorders, metabolic issues, weight gain and obesity, and reproductive effects (such as earlier menarche and endometriosis), and they may contribute to some cancers.¹⁴ Examples of EDCs found in personal care products include phthalates, parabens, and per- and polyfluoroalkyl substances (PFAS).

Formaldehyde is a highly toxic, known carcinogen that can be absorbed through the skin or inhaled during product use. Formaldehyde and formaldehyde-releasing preservatives are used in many personal care products to prevent microbial growth and extend shelf life.¹⁵ Formaldehyde exposure from personal care products often occurs through nail products and hair straighteners, but it is not limited to those types of products.

Fragrance in personal care products is not a single ingredient, but a mixture of unknown chemicals. The widespread prevalence of undisclosed fragrance ingredients is a health concern because product testing reveals that some of the chemicals used to create fragrances can be irritants, exacerbate asthma and allergies, and disrupt the endocrine system.¹⁶ A July 2025 study by Breast Cancer Prevention Partners found that over ninety-eight percent of fragrance chemicals either lack basic safety data or are classified as high or potentially high concern by scientific authorities.¹⁷

Heavy metals such as mercury, lead, and cadmium can be found in many places, including personal care products. People may experience significant health issues following prolonged exposure to certain heavy metals. For example, prolonged exposure to lead has been linked to damage to the brain and nervous system, immune system suppression, reproductive issues, kidney damage, and hypertension.¹⁸

Part II

Drivers of Racial Disparities in Exposure to Harmful Chemicals in Personal Care Products

Two factors contributing to racial disparities in exposure to harmful chemicals in personal care products are: (1) Black women consumers’ personal care product usage patterns; and (2) the products marketed to and available to Black women consumers.

Black Women Consumers’ Hair Product Usage Patterns

Black women purchase nine times more hair products than other groups of women in the United States.¹⁹ Black women also use different types of hair products than other racial groups: they disproportionately purchase hair relaxers and use more hair oil, hair shine, hair styling gel and edge control gel, leave-in curl products, detanglers, pomade/grease/wax, and hair glue than other women.²⁰

The types of hair products used by Black women to achieve specific hairstyles are influenced by individual, cultural, and societal factors. Decisions to wear hair chemically relaxed, in braids or locs, or in a natural style, for example, may be based on aesthetic preferences, cultural identity, peer and family influences, political beliefs, career opportunities, and efforts to maintain healthy hair and prevent breakage or to make hair styling more manageable and less time-consuming.²¹

The role of social and career pressure in Black women’s hair choices is well documented. Studies have found that Black women perceive a level of social stigma against textured hair.²² One survey found that respondents who perceived that others associated straight hair with beauty and professionalism were more likely to straighten their own hair.²³ Indeed, one in five Black women feel social pressure to straighten their hair for work—twice as many as white women²⁴—and Black women are fifty-four percent more likely to feel that they have to wear their hair straight to a job interview to be successful.²⁵ The “Good Hair” Study found that white participants showed explicit bias against Black women’s textured hair, rating it as less beautiful, less sexy/attractive, and less professional than straight hair.²⁶

Fig. 2

In the “Good Hair” Study, 502 women in the national sample and 688 women from the natural hair community rated each hairstyle on a scale from one to five in terms of how beautiful, sexy/attractive, and professional they thought it was. Figure 2 represents the average ratings toward the afro hairstyle, by racial group. The findings demonstrate that Black women overall rate the afro significantly more positively on each of the characteristics than white women (p<.001).

Natural hair discrimination, or prejudice against natural styles and textures, also plays out through overt policies at work and school.²⁷ For example, the U.S. Army historically banned several hairstyles traditionally used by Black women, including twists and braids, in favor of styles that encouraged straightening or other practices to change hair texture.²⁸ Additionally, some schools have policies banning natural and protective hairstyles, and they may discipline or remove a student from school for such grooming code violations.²⁹

Scholarship by Dr. Ami Zota and Dr. Bhavna Shamasunder has described the relationship between racialized beauty standards, the unequal distribution of chemical exposures, and adverse health outcomes as the “environmental injustice of beauty.”³⁰ Their framework acknowledges that multiple interconnected systems of oppression, including racism and sexism, shape societal beauty standards. This creates a society that preferences straight hair and discriminates against Black women for wearing natural hair styles. To achieve these beauty standards, individuals use personal care products that can also lead to exposure to more harmful chemicals, as discussed further below. In this way, racialized societal beauty standards can contribute to racially disparate chemical exposure, and ultimately racial disparities in health outcomes.

Personal Care Products Marketed and Available to Black Women Have More Harmful Chemicals

“The fact that products that are marketed to Black and brown women have more chemicals in them than products marketed to other women is an injustice that needs to be righted.”

—Victoria St. Martin³¹

Racial differences in environmental exposure to chemicals from personal care products are also influenced by the products marketed to and available to Black women. The Environmental Working Group (EWG) published two reports analyzing the ingredients in more than 1,000 personal care products marketed to Black women, checking more than sixty toxicity and regulatory databases and scientific studies. In its first report in 2016, EWG ranked one in twelve of the products marketed to Black womenⁱ as highly hazardous.ⁱⁱ EWG found that fewer than one-quarter of the products marketed to Black women were deemed to be low in potentially hazardous ingredients, compared to about forty percent of the items marketed to the general public.³² The worst-scoring products marketed to Black women were hair relaxers, hair colors, and bleaching products.³³ In its 2025 follow-up report, EWG found that policy and product formulation changes had spurred some safety improvements, but there were still fewer low-hazard products marketed to Black women compared to the market as a whole.³⁴ While these reports are not peer-reviewed studies, EWG’s findings are concerning and warrant greater investigation into the potential hazards of personal care products marketed to Black women.

In addition to differences in products marketed to Black women, there may also be differences in the safety of products available to Black women in local stores. A Harvard University study found that stores in Boston, Massachusetts, neighborhoods with a higher percentage of residents of color were more likely to sell higher-hazard products (based on EWG ratings) compared to Boston neighborhoods with a higher percentage of white residents.³⁵ The researchers concluded that these geographic differences in the availability of safer personal care products may contribute to chemical exposure disparities for people of color.³⁶

Together, these studies indicate that Black women consumers have fewer safe hair product options, which may contribute to their higher exposure to harmful chemicals.

Fig. 3

Fig. 4

ⁱ The study categorized “products marketed to Black women” based on their brand name, use instructions, and/or marketing language. Brand names used to identify products marketed to Black women included Africa’s Best, African Pride, Black Girl Sunscreen, and Nubian Heritage. Use instructions included mentioning hairstyles such as locs, twists, and braids, or specific curl patterns like 4C curls. Marketing language on products or brand websites included phrasing like “for melanated skin,” “for melanin-rich skin,” “fostering a community of Black women,” “natural hair,” “ethnic,” and “multicultural.”

ⁱⁱ For more information on EWG’s methodology to determine hazard ratings, see EWG, Learn How Skin Deep® works, https://www.ewg.org/skindeep/learn_more/about/. While EWG has been subject to criticism for overstating the health risk of chemicals (see Ctr. for Med. & Pub. Affs., The Media and Chemical Risk: Toxicologists’ Opinions on Chemical Risk and Media Coverage, 23:2 Media Monitor (Summer 2009), https://cmpa.gmu.edu/wp-content/uploads/2013/10/2009-1.pdf), this Brief cites the reports for their findings on racial disparities in exposure to chemicals, rather than for their analyses of the hazards of those chemicals.

Part III

Health Concerns from Hair Products Commonly Used by Black Women

This section discusses four types of hair products commonly used by Black women that may be contributing to their increased exposure to harmful chemicals: hair relaxers, hair dyes, natural hair styling products, and synthetic braiding hair. It is important to study and understand the risks of exposure to chemicals in these products to improve Black women consumers’ health and safety.

Hair Relaxers

A robust body of research documents the substantial health risks associated with hair relaxers. Hair relaxers have been linked to an elevated risk of uterine fibroids,³⁷ breast cancer,³⁸ ovarian cancer,³⁹ and uterine cancer,⁴⁰ as well as some reduction in fertility.⁴¹ These health risks are especially pronounced for those who use hair relaxers regularly over a long period of time. Because hair relaxers are marketed to and disproportionately used by Black women consumers, the health risks associated with these products fall heavily on Black women.

Research indicates that these health risks are due to both the ingredients in many hair relaxers as well as the way such products are used. Studies have found that products designed to straighten or relax hair texture often contain a range of toxic chemicals, including formaldehyde, EDCs, and heavy metals.⁴² Furthermore, because consumers place hair relaxers on the roots of their hair, they may get product directly on their scalp. This is particularly concerning because the scalp is more susceptible than skin on other parts of the body to absorbing the chemicals in these products.⁴³ Hair relaxers can also cause scalp lesions and burns, making it easier for the skin to absorb any product on the scalp.⁴⁴ In addition to absorption, consumers may also inhale these chemicals when hair is heated during the straightening treatment, releasing the chemicals into the air.⁴⁵

Hair Dyes

While chemicals in certain hair dyes pose risks for all users, hair dyes may also contribute to disproportionate chemical exposure for Black women because they more commonly use darker dyes that contain more of the concerning chemicals. Additionally, one report found that hair dyes marketed to Black women had more hazardous ingredients than those marketed to a general audience.⁴⁶

The most widely used form of hair dye, permanent dye, contains the strongest chemicals and poses the greatest risks of allergic reaction, hormone disruption, and cancer.⁴⁷ When people dye their hair, the chemicals can be absorbed in small amounts through the skin or inhaled from fumes in the air.⁴⁸ Numerous studies have documented the health risks associated with hair dyes, including an increased risk of breast cancer⁴⁹ and ovarian cancer.⁵⁰ The Sister Study found notably stronger associations between permanent dye use and breast cancer for Black women than for white women.⁵¹ For example, the use of permanent dyes at least every five to eight weeks correlated with a sixty percent increase in the risk of breast cancer for Black women.⁵² For white women, the risk increased by eight percent.⁵³ Similarly, the Women’s Circle of Health Study observed a fifty percent increase in breast cancer risk among Black women who used dark dyes, with a higher risk associated with increased frequency of permanent dye use.⁵⁴

Natural Hair Styling Products

Although some Black women opt for natural hair to avoid products that may be harmful to their hair or health, these consumers are not entirely protected from the risks associated with personal care products. Natural hair products presumably have fewer toxic ingredients than hair relaxers, but these products may still contain potentially harmful ingredients. One report found that many of the “natural” hair products marketed to Black women have higher rates of harmful chemicals (such as EDCs and fragrance) than the products marketed to a general audience.⁵⁵

For example, cleansing conditioners or co-washes, which are often used for natural styles, have been the subject of many complaints for their adverse effects.⁵⁶ Between 2011 and 2016, the Food and Drug Administration (FDA) received more than 1,400 complaints about cleansing conditioners, including reports of hair loss.⁵⁷ An FDA study confirmed that mice treated with these cleansing conditioners over a prolonged period of time displayed abnormal hair growth cycles.⁵⁸ Unfortunately, the FDA determined that further investigation was needed before taking additional regulatory action. In the absence of sufficient federal regulation, consumers turned to litigation. Class action lawsuits against two hair care companies, DevaCurl and WEN, reached multi-million-dollar settlement agreements.⁵⁹

Synthetic Braiding Hair

Black women are also the primary users of synthetic hair products, including for braiding, extensions, and wigs.⁶⁰ Although braids are often seen as a protective style for natural hair, recent studies have raised concerns about the chemicals used to create synthetic braiding hair. Synthetic hair is typically composed of nonrenewable plastic fibers and modacrylic fiber. Many well-known brands use modacrylic fiber, which is commonly recommended by professional braiders due to its resemblance to textured hair and resistance to unraveling.⁶¹ However, modacrylic fiber is composed of ingredients that are toxic to humans.⁶² Both the Environmental Protection Agency and the Department of Health and Human Services have classified a component of modacrylic fiber as a probable carcinogen.⁶³

Multiple recent studies have found that widely used synthetic braiding hair contains many other concerning chemicals, including heavy metals, carcinogens, and even ingredients that the FDA prohibits in personal care products.⁶⁴ These findings underscore the need for greater research into these products and their potential health risks, particularly as the popularity of synthetic hair products grows. Unfortunately, synthetic braiding hair is in a regulatory black hole: many hair extension products do not disclose their chemical ingredients on packaging,⁶⁵ and when Consumer Reports investigated the issue, the FDA did not indicate that it even has jurisdiction over synthetic braiding hair.⁶⁶

Part IV

Government Regulation of Personal Care Products

Given the significant potential adverse health effects of these widely used personal care products, government regulation is essential to protect consumers’ health and safety and to address the particular risks faced by Black women consumers.

The FDA’s Historically Limited Power to Regulate Cosmetics

Federal oversight of personal care products has long been characterized by under-regulation by the government and an over-reliance on the cosmetics industry to regulate itself. For decades, the FDA had no authority to recall harmful products and only prohibited a tiny fraction of the many concerning chemicals included in personal care products. The FDA also allowed for product labeling exceptions that favored the cosmetics industry and relied on industry-led safety testing and voluntary reporting. Historically, the federal government’s weak regulatory scheme for cosmetics failed to fully protect consumers from potentially harmful products, including the hair products used disproportionately by Black women that pose significant health risks.

The two primary statutes that govern cosmetics are the Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act. These laws prohibit the marketing of “adulterated” or “misbranded” products. “Adulteration” refers to a problem with a product’s composition, which can stem from issues with ingredients, contaminants, processing, packaging, shipping, or handling. “Misbranding” refers to improperly labeled or deceptively packaged products. However, until recently, when a product was adulterated or misbranded, the FDA could only issue warning letters and press releases, not recall the harmful product.⁶⁷ Therefore, even with significant reports of adverse health outcomes associated with hair products, the FDA lacked the authority to require that a manufacturer recall a product.

Only a limited list of cosmetic ingredients are prohibited and automatically make a product adulterated. Compared to the hundreds of chemicals banned or restricted in the European Union and Canada,⁶⁸ the United States has banned merely eleven substances from cosmetics.⁶⁹ Even some of the prohibited ingredients are still found in products sold in the United States, including synthetic braiding hair. This short list does not include all the harmful chemicals found in cosmetics, including many known carcinogens, EDCs, and irritants. Notably absent from this list of prohibited ingredients is formaldehyde, a known carcinogen. One study found that a substance that generates formaldehyde is present in one in five cosmetics,⁷⁰ including many hair-straightening products used by Black women.

Another factor contributing to the under-regulation of cosmetics is a loophole in federal law that allows manufacturers to omit “fragrance” ingredients from product labels.⁷¹ As a result, thousands of unknown chemicals can be hidden under the terms “fragrance” or “parfum.” Many products, particularly hair products, used by and marketed to Black women have fragrance, which contributes to their exposure to many unknown and potentially harmful chemicals.⁷²

Rather than enacting stringent laws and regulations, the federal government has relied heavily on voluntary actions by cosmetics companies. The Personal Care Products Council, the cosmetics industry’s powerful lobbying group, worked with the FDA in the 1970s to develop a system of monitoring cosmetic ingredients.⁷³ They reached an agreement to create the self-monitoring Cosmetic Ingredient Review (CIR) panel, funded by the Personal Care Products Council, in lieu of standardized toxicology testing.⁷⁴ As a voluntary industry measure, the CIR has not been particularly effective at identifying harmful chemicals in cosmetics. Over a thirty-three-year period, the CIR evaluated only about eleven percent of the 10,500 cosmetic ingredients catalogued by the FDA.⁷⁵ When the CIR does review ingredients, it generally focuses on the ingredients’ potential to cause short-term dermatological reactions such as rashes and eye irritation, not their potential to cause long-term health problems such as cancer or reproductive harm.⁷⁶ This focus ignores many of the adverse health outcomes disproportionately affecting Black women from prolonged exposure to products like hair relaxers or synthetic hair. Furthermore, for many decades, the FDA maintained only a Voluntary Cosmetic Registration Program for manufacturers and distributors to register their facilities and report products,⁷⁷ unlike the mandatory registration for other FDA-regulated products.

Recent Statutory Changes Improving the FDA’s Ability to Regulate Cosmetics

In 2022, the Modernization of Cosmetics Regulation Act (MoCRA) was signed into law, the most significant update to federal cosmetics regulation in more than eighty years.⁷⁸ By making several important improvements to the FDA’s ability to regulate cosmetics, MoCRA laid the groundwork to improve the health and safety of all consumers, including Black women. Five important reforms are detailed below.

First, MoCRA finally gave the FDA the authority to issue a mandatory recall of products that are adulterated or misbranded. This recall authority is an important tool to improve health and safety by removing unsafe products from the market.

Second, MoCRA requires manufacturers to report serious adverse events to the FDA within fifteen days, rather than the previous voluntary reporting, and thus increases transparency and accountability. Unfortunately, the requirement to report “serious” adverse events only flags the most extreme injuries associated with cosmetics use. A manufacturer must only maintain records of other adverse events that are not “serious” for possible inspection by the FDA. Mandating reporting of only the most extreme health events does not capture the full extent of cosmetics harm in ordinary use, which is often cumulative and chronic, as opposed to severe and acute. This is particularly true for hair products used by Black women.

Third, manufacturers must now register their facilities with the FDA and renew their registration every two years. The FDA may suspend a facility’s registration if it determines that a product created at the facility may cause serious health problems or death. Manufacturers are also now required to disclose their products and ingredients to the FDA, including specifying fragrance ingredients. This increased transparency is a step toward improved product safety.

Fourth, professional salon products (those designed for specific use in salons) are now subject to the same ingredient disclosure requirements as cosmetics marketed directly to consumers. This will allow salon professionals and their clients to have greater awareness of potential chemical exposures.

Finally, MoCRA requires the FDA to promulgate new regulations related to: (1) fragrance allergens; (2) good manufacturing practices; and (3) PFAS in cosmetics. These regulations are designed to improve the safety of personal care products and reduce consumers’ exposure to fragrance allergens and EDCs.

MoCra Implementation Status

Adverse Event Reporting⁷⁹

Companies are required to report serious adverse events associated with the use of cosmetic products within fifteen days of receiving a report.

Status: In effect as of 2023.

Safety Substantiation⁸⁰

Companies are required to obtain and maintain records supporting adequate safety substantiation for each cosmetic product.

Status: In effect as of 2023.

Mandatory Recall Authority⁸¹

The FDA can issue a mandatory recall order if a company fails to voluntarily recall products that are adulterated, misbranded, or the cause of serious adverse health events or death.

Status: In effect as of 2023.

Facility Registration⁸²

Facilities that manufacture, distribute, or process cosmetics must register their facility with the FDA and update the registration every two years.

Status: In effect as of 2023.

Product Listing⁸³

All manufacturers, packers, and distributors of cosmetics whose names appear on product labels must submit a list of all cosmetic products and their ingredients to the FDA.

Status: In effect as of 2023.

Labeling⁸⁴

All cosmetic products must have labels with the domestic address, phone number, or electronic contact information of the people responsible for adverse event reporting.

Status: In effect as of 2024.

Standardized Testing for Talc Products⁸⁵

The FDA must issue a regulation establishing mandatory standardized testing methods for detecting asbestos in cosmetic products containing talc.

Status: Proposed rule published in December 2024, withdrawn in November 2025.⁸⁶

Fragrance Allergen Rule⁸⁷

The FDA must issue a regulation establishing fragrance allergen labeling requirements for cosmetic products.

Status: Deadline for proposed rule moved from June 2024 to May 2026.⁸⁸

Good Manufacturing Practices⁸⁹

The FDA must issue a regulation regarding good manufacturing practices for facilities.

Status: Deadline for proposed rule delayed from December 2024 to unknown date.⁹⁰

Report on PFAS in Cosmetics⁹¹

The FDA must assess and report on the use and safety of PFAS in cosmetic products.

Status: Published on December 29, 2025.⁹²

The Need for More Cosmetics Regulation to Protect Consumers and Improve Public Health

While MoCRA made many important changes, it did not do enough to protect consumers from harmful products. For example, there are still no pre-approval regulatory standards for cosmetics that would ensure their safety before they are sold on the market, as there are with drugs.⁹³ Instead, cosmetics companies can sell products without meeting any specific safety standards.⁹⁴ MoCRA also does nothing to change the current guidelines about which chemical substances are safe to use in beauty products. It thus does not prohibit ingredients like formaldehyde that are prevalent in the hair products linked to racial health disparities described above. Additionally, more than three years after MoCRA passed, the FDA has yet to implement any rules or regulations to give MoCRA teeth, and the current administration has withdrawn or delayed many of the proposed rules.

With the slow pace of change at the federal level, states are taking the lead in efforts to protect consumers from harmful chemicals in cosmetics. MoCRA preempts states from enacting new laws related to registration and product listing, good manufacturing practices, records, recalls, adverse event reporting, or safety substantiation. However, MoCRA permits states to ban or restrict the use of certain ingredients in cosmetic products, which many states have since done. To date, sixteen states have adopted policies related to toxic chemicals in personal care products, including three bills specific to hair products.⁹⁵ Several new state laws went into effect on January 1, 2025, including California’s Toxic-Free Cosmetics Act (A.B. 2762), Colorado’s law restricting PFAS from personal care products (S.B. 24-081), Maryland’s Cosmetic Products Ingredient Prohibition Act (Md. Code Ann., Health–Gen. § 21-259.2), and Washington’s Toxic-Free Cosmetics Act (Wash. Rev. Code Ann. § 70A.560). On August 28, 2025, Washington became the first state to adopt a comprehensive ban on formaldehyde-releasing chemicals in cosmetics, which will take effect in January 2027.

Part V

Recommendations and Conclusion

“As a mom of a five-year-old Black girl, I hope one day my daughter will walk into a store and she will be able to buy products that are safe. I want to make sure every little girl, every man, every woman has safe products they can use on their body.”

—Victoria St. Martin⁹⁶

While it is ultimately the responsibility of the cosmetics industry and the government to research and test products and to ensure that non-toxic products are available to the public, consumers still have power to make changes to protect themselves, their families, and their communities. Below are recommendations for policymakers and consumers to redress the potential adverse health consequences of chemical exposures from personal care products, and in turn remedy the racial health disparities affecting Black women.

Policymakers

Pass the federal Safer Beauty Bill Package

The federal government should expand consumer health and safety protections beyond the reforms in MoCRA. The Safer Beauty Bill Package, endorsed by more than 150 nongovernmental organizations and businesses, is a suite of four bills designed to address gaps in the federal regulation of cosmetics by banning the worst chemicals, requiring the disclosure of hazardous chemicals (including fragrance ingredients), protecting women of color and salon workers, and mandating supply chain transparency.⁹⁷

Issue a rule banning formaldehyde in hair products

The FDA should use its authority to issue a rule banning formaldehyde and formaldehyde-releasing preservatives in hair products.

Pass state laws prohibiting or restricting harmful chemical ingredients

Notwithstanding MoCRA’s preemptions, states may still ban or restrict the use of harmful ingredients in personal care products. States should focus on ingredients that have documented health risks, such as formaldehyde and formaldehyde-releasing preservatives, heavy metals, and EDCs. To make a meaningful impact, states should also allocate resources and implement enforcement mechanisms to hold the manufacturers and retailers in their states accountable.

Fund further research

The government should fund continued research on the health effects of chemical exposures from personal care products. This should include long-term studies on the health effects of repeated and prolonged cosmetics use, studies on how the body absorbs personal care products under conditions of regular use, studies across racially diverse groups, and granular analyses of the potential health risks of certain chemicals. Some of the largest studies on these topics, including the Sister Study, were sponsored by the National Institutes of Health (NIH). Unfortunately, future research in this area is threatened by the Trump administration’s opposition to environmental justice or anything perceived as related to diversity, equity, and inclusion, along with its restructuring and withholding of NIH funds.⁹⁸

Photo via Getty Images

Safer Beauty Bill Package

Toxic-Free Beauty Act

Bans eighteen toxic chemicals.

Cosmetic Safety Protections for Communities of Color and Salon Workers Act

Funds research, resources, education, outreach, and the development of safer chemicals to protect the health of women of color and salon workers.

Cosmetic Hazardous Ingredient Right to Know Act

Requires disclosure on product labels and websites of the fragrance and flavor ingredients in both retail consumer cosmetics and professional salon products.

Cosmetic Supply Chain Transparency Act

Requires suppliers, manufacturers, and formulators of cosmetic ingredients, raw materials, products, or packaging to provide cosmetics companies with full ingredient disclosure and safety data so they can make safer products.

Consumers

Make informed choices and spread awareness

Consumers should learn about toxic chemicals and talk to their hairstylists about the products currently used and possible alternatives. They should also learn how to read and interpret labels for products they purchase, and seek medical advice about associated health risks. They should further discuss the information they have learned with their friends, family, and community members.

Demand government action

Consumers should use their voice to demand that policymakers take action to ban toxic chemicals in personal care products, such as by writing or calling their representative to express support for the Safer Beauty Bill Package.

Use their purchasing power to spur change

Greater product use means that Black women have tremendous spending power in the market. Black communities can use their power as consumers to demand change by shopping for products with transparent ingredient lists and without the most concerning chemicals. Unfortunately, sometimes non-toxic and fragrance-free products are more expensive or not available at local retailers.

Support Black-owned, non-toxic beauty brands

Although Black women are responsible for a large share of cosmetics spending, Black beauty brands represent only 2.5% of the cosmetics and personal care products market.⁹⁹ An even smaller percentage of these brands are part of the non-toxic beauty industry.¹⁰⁰ To address the need for research and development of products for Black consumers by Black researchers and developers, Spelman College launched a cosmetic science program in 2024, the first among historically Black colleges and universities.¹⁰¹ Building this pipeline of cosmetics industry professionals is important, especially as the Trump administration attacks diversity, equity, and inclusion efforts across the public and private sectors. Indeed, many Black-owned brands are being shut out of the capital and resources they need to take their companies to scale, despite their popularity.¹⁰²

Report adverse health reactions from personal care products

If a consumer has a bad reaction to a product, it is important to report it to hold the companies that make and sell personal care products responsible. Consumers can report adverse reactions to the FDA via MedWatch, on top of directly reporting to the retailer or manufacturer.

Seek legal advice

In the absence of sufficient regulatory action, many consumers have turned to litigation against the manufacturers of harmful products. Since 2022, thousands of women of color have filed lawsuits against hair relaxer companies in both state and federal courts. They argue that they were diagnosed with cancer, fibroids, infertility, and hormone disruption as a result of using hair relaxers. In 2023, several cases filed in federal court were consolidated so they could be heard together by one judge. As of August 2025, this multi-district litigation consisted of more than 10,500 hair relaxer cases.¹⁰³

Given the widespread use of hair products with concerning chemical ingredients and the serious adverse health effects that can occur with long-term exposure, this issue goes beyond individual consumer choice; rather, it is a public health concern. Policymakers, product developers and manufacturers, retailers, researchers, health care providers, salon professionals, advocates, and consumers all have roles to play in ensuring that everyone has access to safe and effective personal care products. Together, these efforts can reduce the racial disparities in health outcomes experienced by Black women.

Endnotes

Adana A. M. Llanos et al., Hair product use and breast cancer risk among African American and White women, 38 Carcinogenesis 883–92 (Sept. 2017), https://pubmed.ncbi.nlm.nih.gov/28605409/; Rohan Rao et al., Associations of hair dye and relaxer use with breast tumor clinicopathologic features: Findings from the Women’s circle of Health Study, 203 Env’t Rsch. 111863 (Jan. 2022), https://pubmed.ncbi.nlm.nih.gov/34390715/.
Victoria St. Martin, Dereliction of Beauty: How lax regulation of beauty care products victimizes women of color, Inside Climate News, https://insideclimatenews.org/project/dereliction-of-beauty/ (last visited Feb. 13, 2026).
See, e.g., Janelle Weaver et al., How personal care products may affect health of Black young adult women (Env’t Factor, Intramural Paper, July 2024), https://www.niehs.nih.gov/news/factor/2024/7/papers/dir#a1; Ami R. Zota et al., The Environmental Injustice of Beauty: Framing Chemical Exposures from Beauty Products as a Health Disparities Concern, 217 Am. J. Obstetrics & Gynecology 418e1–418e6 (Oct. 2017), https://pubmed.ncbi.nlm.nih.gov/28822238/; Tamarra M. James-Todd et al., Racial/ethnic disparities in environmental endocrine disrupting chemicals and women’s reproductive health outcomes: epidemiological examples across the life course, 3 Env’t Epidemiology 161–80 (2016), https://pubmed.ncbi.nlm.nih.gov/28497013/; Janet Nudelman et al., Right to Know: Exposing toxic fragrance chemicals in beauty, personal care and cleaning products, Breast Cancer Prevention Partners (Sept. 2018), https://www.bcpp.org/wp-content/uploads/2018/09/BCPP_Right-To-Know-Report_Secret-Toxic-Fragrance-Ingredients_9_26_2018.pdf; Alexandra J. White et al., Use of hair products in relation to ovarian cancer risk, 42 Carcinogenesis 1189–95 (Sept. 2021), https://pubmed.ncbi.nlm.nih.gov/34173819/.
See, e.g., Am. Cancer Soc’y, Hair Dyes and Cancer Risk, https://www.cancer.org/cancer/risk-prevention/chemicals/hair-dyes.html (last revised Nov. 22, 2022); Nat’l Cancer Inst., Hair Dyes, Other Hair Products, and Cancer Risk, https://www.cancer.gov/about-cancer/causes-prevention/risk/substances/hair-dyes-fact-sheet#why-is-there-concern-that-hair-dyes-may-cause-cancer (last reviewed Dec. 1, 2022); White et al., supra note 3.
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21 U.S.C.A. §§ 361–62; Rajiv Shah et al., Concealing Danger: How the Regulation of Cosmetics in the United States Puts Consumers at Risk, 23 Fordham Envt’l L. Rev. 203, 266-67 (2011).
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U.S. Food & Drug Admin., supra note 64.
EWG, Exposing the Cosmetics Cover-up (Oct. 10, 2013), www.ewg.org/research/exposing-cosmetics-cover/formaldehyde-releasers#.We61_RNSwXo.
21 C.F.R. §§ 701.3(a), 720.8 (2010).
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Shah et al., supra note 67, at 225–26.
Id.
Colleen Campbell, Intersectionality Matters in Food and Drug Law, 95 U. Colo. L. Rev. 1, 52–53 (2024).
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MoCRA, sec. 605.
MoCRA, sec. 608.
MoCRA, sec. 611.
MoCRA, sec. 607.
Id.
MoCRA, sec. 609.
MoCRA, sec. 3505.
Testing Methods for Detecting and Identifying Asbestos in Talc-Containing Cosmetic Products, 89 Fed. Reg. 105490 (proposed Dec. 27, 2024) (to be codified at 21 C.F.R. pt. 730).
MoCRA, sec. 609.
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MoCRA, sec. 606.
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MoCRA, sec. 3506.
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Arielle Humphries

Published March 2026

Introduction

Have you ever permed your hair? Yes How old were you when you had your first perm? About ten years old. How often did you perm your hair? About once a month. Did you ever have burns? Yes, every time.

Part I

Racial Health Disparities Affecting Black Women

Fig. 1

Part II

Drivers of Racial Disparities in Exposure to Harmful Chemicals in Personal Care Products

Black Women Consumers’ Hair Product Usage Patterns

Fig. 2

Personal Care Products Marketed and Available to Black Women Have More Harmful Chemicals

“The fact that products that are marketed to Black and brown women have more chemicals in them than products marketed to other women is an injustice that needs to be righted.”

—Victoria St. Martin31

Fig. 3

Fig. 4

Part III

Health Concerns from Hair Products Commonly Used by Black Women

Hair Relaxers

Hair Dyes

Natural Hair Styling Products

Synthetic Braiding Hair

Part IV

Government Regulation of Personal Care Products

The FDA’s Historically Limited Power to Regulate Cosmetics

Recent Statutory Changes Improving the FDA’s Ability to Regulate Cosmetics

MoCra Implementation Status

The Need for More Cosmetics Regulation to Protect Consumers and Improve Public Health

Part V

Recommendations and Conclusion

“As a mom of a five-year-old Black girl, I hope one day my daughter will walk into a store and she will be able to buy products that are safe. I want to make sure every little girl, every man, every woman has safe products they can use on their body.”

—Victoria St. Martin96

Policymakers

Photo via Getty Images

Safer Beauty Bill Package

Toxic-Free Beauty Act

Cosmetic Safety Protections for Communities of Color and Salon Workers Act

Cosmetic Hazardous Ingredient Right to Know Act

Cosmetic Supply Chain Transparency Act

Consumers

Have you ever permed your hair? Yes
How old were you when you had your first perm? About ten years old.
How often did you perm your hair? About once a month.
Did you ever have burns? Yes, every time.

—Victoria St. Martin³¹

—Victoria St. Martin⁹⁶