New Study Exposes Massive Lead Risk in Cosmetics

Ryan Cheng, Chief Revenue Officer at Nature Coatings

Recent independent testing has renewed attention on an old but unresolved issue in cosmetics: the presence of lead in certain eyeliners. While the most extreme findings were associated with traditional formulations, the implications extend far beyond a single product type or cultural practice. For modern cosmetic companies, this moment highlights a deeper structural challenge—how materials are sourced, specified, and validated in a regulatory environment that is becoming steadily more demanding.

For R&D teams and procurement officers, the lesson is not simply about avoiding one ingredient or category. It is about recognizing that material safety, traceability, and regulatory readiness are now inseparable from product performance.

Lead rarely appears in contemporary cosmetics because it is not intentionally added. More often, it enters formulations through mineral pigments, legacy raw materials, or poorly characterized carbon blacks. In color cosmetics, where pigments are used at relatively high loadings, even trace contamination at the ingredient level can translate into finished products that exceed regulatory thresholds. This creates a technical challenge for formulators: achieving deep blacks, smooth application, and long-wear performance without relying on materials that carry hidden toxicological risk.

At the same time, the regulatory landscape is shifting rapidly. While cosmetic rules have historically varied by region, global alignment is accelerating. In the United States, the FDA recommends limiting lead in cosmetics to 10 parts per million. The European Union effectively enforces even stricter standards through its precautionary regulatory framework. Across Asia-Pacific and Latin America, regulators are increasingly harmonizing with EU-style approaches, and major retailers are layering on their own compliance requirements. In practice, this means products are now judged by the strictest standard they encounter, not the most permissive.

For R&D teams, this convergence changes how formulations are designed. It is no longer sufficient to optimize for performance and address regulatory issues later. Leading teams are designing for global compliance from the outset, selecting materials that are inherently lower risk and easier to defend under scrutiny. This often means moving away from traditional fossil-based or mineral-derived blacks that can contain polycyclic aromatic hydrocarbons or trace toxic heavy metals, like lead and arsenic, depending on feedstock and processing. Even when these materials meet specifications on paper, their variability and documentation gaps can create ongoing risk.

This shift also places new demands on ingredient transparency. Certificates of analysis alone are no longer enough. R&D teams increasingly need clear documentation of feedstock origin, manufacturing processes, and batch-to-batch consistency. When questions arise—whether from regulators, retailers, or consumers—teams must be able to trace materials back to their source with confidence.

Procurement officers also sit at the center of this transition. The eyeliner findings underscore that sourcing decisions are no longer purely commercial or logistical; they are brand-risk decisions. Procurement strategies must now account for supplier testing practices, contaminant controls, and long-term scalability, not just price and availability. Materials that appear cost-effective upfront can become liabilities if they trigger reformulations, recalls, or delayed market access down the line.

In this context, bio-based alternatives (though not all are equal) are gaining traction across the cosmetics industry. Bio-based carbon materials like BioBlack Beauty, produced from renewable biomass rather than fossil fuels, offer a fundamentally different risk profile. Because their feedstocks and production pathways are tightly controlled, they tend to carry a lower inherent risk of heavy-metal contamination. Some, like BioBlack Beauty, also avoid the PAHs associated with many petroleum-derived carbon blacks and offer improved consistency and traceability—attributes that matter as much to compliance teams as they do to formulators.

Bio-based carbon materials like BioBlack Beauty, produced from certified wood waste rather than fossil fuels, have no trace toxic elements, including no detectable  PFAS, lead, or Nanomaterials (and reduce emissions). Because our feedstock and production pathways are tightly controlled and sustainable from beginning to end, BioBlack has a lower inherent risk of heavy-metal contamination. That includes PAHs otherwise associated with petroleum-derived carbon blacks. 

BioBlack Beauty for cosmetics offers improved consistency and traceability—attributes that matter as much to compliance teams as they do to formulators.

For eyeliner developers, bio-based alternatives like BioBlack Beauty open a meaningful path forward. Safer materials make it possible to deliver the depth of color and performance consumers expect while aligning with clean beauty standards and future regulatory requirements. Importantly, they also reduce the need for downstream mitigation strategies, such as additional testing or reformulation under regulatory pressure.

The broader takeaway from the recent findings is not alarmism, but opportunity. Brands that treat material selection as a strategic lever—rather than a back-end constraint—are better positioned to move quickly, enter new markets, and earn trust in an environment of growing scrutiny. As regulations evolve and expectations rise, the safest and most resilient products will be those designed from the start with safer materials at their core.

For R&D leaders and procurement teams alike, the message is clear: the future of cosmetics will be built not just on performance, but on materials that can stand up to science, regulation, and public trust at the same time.