Don’t take our word for it. Here’s every fact on this site, with its evidence grade, its caveats, and a link to the source, so you can check us.
We start you on the strong ones: findings that have been replicated or come from one large, well-controlled study. Moderate and weak facts are here too, labeled for what they are. Use “Link to this fact” to share a single card.
The industry / Animal study
The two molecules that give lavender oil its scent, linalool and linalyl acetate, were put through the full regulatory endocrine test battery (OECD guideline cell assays plus rat uterotrophic, Hershberger, and one-generation reproductive studies) and came back negative on estrogen and androgen endpoints, in a study written, run, and entirely funded by BASF, the company that manufactures both chemicals, with all five authors BASF employees.
Strong evidence.
Caveats
Guideline designs with working positive controls, so the negative is real; the conflict of interest is disclosed in the paper and should be stated whenever the result is cited. Scope: two constituents, not lavender or tea tree oil.
Source: Hareng 2024, Archives of Toxicology Industry-funded Link to this fact
The industry / Animal study
The industry-run endocrine tests on lavender's scent molecules (BASF 2024) did not cover tea tree oil: its main constituent, terpinen-4-ol, was not tested.
Strong evidence: A statement about the study's scope, not about tea tree oil's safety either way.
Source: Hareng 2024, Archives of Toxicology Industry-funded Link to this fact
The industry / Review of other studies
The fragrance industry's safety system is self-run: by its own 2003 description, companies fund the Research Institute for Fragrance Materials through dues, its expert panel reviews ingredient safety, and conclusions go to the industry's trade body IFRA, which sets voluntary standards for those same companies. No regulator appears in the loop.
Strong evidence: Industry's own description (2003); panel members are required to be independent of the industry; later governance changes not covered.
Source: Bickers 2003 (RIFM Expert Panel), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
By the industry's own figures, about 60% of fragrance goes into soaps, fabric softeners, cleaners, and detergents, yet its 2003 method for estimating people's exposure counted only 10 personal-care products applied to skin, and breathing fragrance in was not part of the calculation.
Strong evidence: Describes the 2003 process; later RIFM aggregate-exposure work may differ. Shows the route was not assessed, not that it causes harm.
Source: Bickers 2003 (RIFM Expert Panel), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Other evidence
By 1994 the fragrance industry itself had banned or restricted 82 fragrance materials, most because they cause skin allergy and a dozen because they cause skin reactions in sunlight.
Strong evidence: Counts restrictions, not harm rates; limits not printed.
Source: Ford 1994 (RIFM) Industry-funded Link to this fact
The industry / Government agency
In 2000 the EU's scientific advisers recommended banning 36 fragrance materials from cosmetics, and the list they endorsed was the fragrance industry's own list of materials it had already prohibited (IFRA); the committee added no testing of its own and deferred all industry restrictions to later.
Strong evidence: Describes the 2000 procedure; later EU opinions (SCCS 2012) did independent hazard classification.
Source: SCCNFP 2000 Link to this fact
The industry / Review of other studies
A trade consortium of 11 French essential-oil companies funded and employed the authors of the journal letter disputing the lavender breast-growth case reports; together with the tea tree oil trade association's letter, the published rebuttals to those case reports came from industry.
Strong evidence: Documents who argued what (disclosed in the letter); says nothing about whether the oils cause breast growth.
Source: Giroux & Orjubin 2020 (JCEM letter; Consortium Huiles Essentielles), The Journal of Clinical Endocrinology & Metabolism Industry-funded Link to this fact
The industry / Review of other studies
In 1997 the cosmetics industry's own safety panel (CIR) formally asked for inhalation-toxicity data on benzyl alcohol, benzoic acid, and sodium benzoate, received none, and still published a 2001 "safe" conclusion that explicitly excludes any product where inhalation is a route of exposure (colognes, hairsprays, deodorants, aerosol fixatives).
Strong evidence: The gap is documented in the report's own text (Notice of Insufficient Data, no comments received); no later CIR report closing it was found in this pass.
Source: Nair 2001 (CIR Expert Panel), International Journal of Toxicology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
The lab tests that replaced animal testing for fragrance and cosmetic allergy limits have been stuck at explaining about 62% of allergy potency (as measured by the mouse test) since 2015 — the 2015 model and the 2022 model perform the same.
Strong evidence: Regression R2(adj) against mouse LLNA potency, not human outcomes; industry-funded (Givaudan).
Source: Natsch 2015, Toxicological Sciences Industry-funded Link to this fact
The industry / Measured in people or real products
The independent dermatologists who ran this study concluded deodorants should contain cinnamal at less than 0.01% to protect people already sensitized, a stricter limit than the fragrance industry's later 0.05% IFRA standard.
Strong evidence: Authors' own recommendation, not a regulatory outcome; the 0.05% IFRA cap was set afterward using the induction NOEL, not this elicitation data.
Source: Bruze et al. 2003, Journal of the American Academy of Dermatology Link to this fact
The industry / Review of other studies
The fragrance industry's own risk-assessment methodology (QRA1, then QRA2) has set enforceable safety limits for fragrance materials since 2008, but by its own authors' admission has never been tested against real-world clinical outcomes.
Strong evidence: Industry-authored methodology paper; the paper itself calls for the longitudinal clinical studies that would settle this, and states they have not been done.
Source: Api 2020 (RIFM/IFRA), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The industry's fragrance safety-limit system (QRA/IFRA Standards) is explicitly designed to prevent new fragrance allergies from developing, not to protect people who are already allergic from reacting to a compliant product.
Strong evidence.
Caveats
Confirmed as the framework's own stated design intent (Section 2.2), not inferred from a single ingredient's numbers; does not itself test whether existing limits provoke reactions in sensitized people.
Source: Api 2020 (RIFM/IFRA), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The 2020 update to the industry's fragrance safety-assessment methodology exists because an independent EU regulatory body (the SCCS), not the industry itself, found the original 2008 version's exposure assumptions and safety factors inadequately justified.
Strong evidence.
Caveats
Confirmed directly from the SCCS's own primary text, now ingested: SCCS Notes of Guidance, 11th revision (SCCS/1628/21, 2021), §3-4.7.1, p.56 — "The SCCS considers that it is not yet possible to use the QRA2 to establish a concentration at which induction of sensitization of a fragrance is unlikely to occur. Several aspects of the methodology are not clear…".
Source: Api 2020 (RIFM/IFRA), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Government agency
A population study widely treated in dermatology literature as independent, EU-style evidence that confirmed dermatologists' fragrance-allergy estimates over the industry's own claims was itself funded by the fragrance industry's own research body, the Research Institute for Fragrance Materials (RIFM) — a funding fact omitted by every earlier secondhand citation of this study.
Strong evidence.
Caveats
The industry-funded study still confirmed the higher, consumer-relevant estimate (1.9% clinically relevant, up from a disputed 'up to 2%') over industry's own 2000 'far lower' claim — the funding did not appear to weaken the result in this case.
Source: Diepgen 2015 (EDEN), British Journal of Dermatology Industry-funded Link to this fact
The industry / Government agency
The EU guidance that defines what 'free from' and 'hypoallergenic' cosmetic claims are allowed to mean was jointly agreed by the European Commission, all EU/EFTA member states, the main EU cosmetics trade body (Cosmetics Europe) and the fragrance industry's own trade association (IFRA).
Strong evidence: Stated on the document's own cover page (footnote 1); this describes who wrote the guidance, not an independent audit of its content.
Source: EC Technical Document on Cosmetic Claims 2017 Industry-funded Link to this fact
The industry / Government agency
This all-allergen EDEN study, like its fragrance-specific companion paper, was funded by the Research Institute for Fragrance Materials (RIFM), the fragrance industry's own scientific body, with a co-author (M. Bruze) sitting on RIFM's own expert panel.
Strong evidence.
Caveats
The study's own funding statement names RIFM directly; this paper's own headline result (nickel and thiomersal, not fragrance, are the top allergens) has no obvious pro-fragrance-industry stake either way.
Source: Diepgen 2016 (EDEN), British Journal of Dermatology Industry-funded Link to this fact
The industry / Other evidence
This research was supported entirely by the Research Institute for Fragrance Materials, Inc. (RIFM), a fragrance-industry trade body funded by fragrance and consumer-product manufacturers; co-authors are staff of RIFM, Creme Global (RIFM's contract exposure-modeling partner), Unilever, Givaudan, Procter & Gamble and Firmenich.
Strong evidence.
Caveats
Fact about funding and authorship, not an independent finding; the paper states "the authors report no conflicts of interest" in the narrow disclosure sense despite full industry funding and staffing.
Source: Safford 2017, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The candle recipes tested in this study, the criteria for making them, and the study's funding all came from an advisory committee of candle and fragrance industry groups: the European Candle Association, National Candle Association, Latin American Candle Manufacturers Association, and the fragrance houses Arylessence, Belmay, Firmenich, Givaudan, International Flavors & Fragrances, Symrise, and Takasago.
Strong evidence.
Caveats
The authors' Declaration of Competing Interest states no known competing financial interests, alongside this acknowledged industry funding, study design input, and co-author industry affiliations (Arylessence, European Candle Association).
Source: Salthammer 2021, Environment International Industry-funded Link to this fact
The industry / Review of other studies
The main published review arguing eye drops should shift toward preservative-free and sustained-release drug-delivery devices to avoid BAK toxicity was written entirely by employees of Ocular Therapeutix, Inc. — a company that sells sustained-release ocular drug-delivery products, including one (DEXTENZA) of the same type the review names as the field's future direction — and the company funded the paper's editorial assistance and open-access fee.
Strong evidence.
Caveats
This doesn't make BAK's documented cytotoxicity untrue, but the review's framing of sustained-delivery platforms as the best long-term fix should be read as the stated position of a company that sells that exact product category.
Source: Goldstein 2022, Eye Industry-funded Link to this fact
The industry / Review of other studies
All but one author of this fragrance-industry potency review were full-time, fully paid employees of the Research Institute for Fragrance Materials (RIFM) at the time of the work, and the remaining author was paid by RIFM for the time spent preparing the paper — a fully industry-funded and industry-staffed study that sets the potency categories RIFM and IFRA use to justify their own safety limits.
Strong evidence: Disclosed by the authors themselves in the paper's own conflict-of-interest statement.
Source: Na et al. 2022, Dermatitis Industry-funded Link to this fact
The industry / Measured in people or real products
The independent dermatologists who ran this study concluded deodorants should contain isoeugenol at less than 0.0063% to protect people already sensitized, about 3x stricter than IFRA's current 0.02% ceiling for consumer products.
Strong evidence.
Caveats
Authors' own recommendation, not a regulatory outcome; the 0.02% IFRA cap (set in 1998) was not derived from this elicitation data, and 0.0063% is only the lowest concentration this study tested, not a demonstrated safe floor.
Source: Bruze et al. 2005, Contact Dermatitis Link to this fact
The industry / Other evidence
A 2014 peer-reviewed critique disputing the WHO-UNEP 2012 endocrine-disruptor report's evidence standards was funded by six chemical- and pesticide-industry trade associations (American Chemistry Council, CropLife America, CropLife Canada, CropLife International, Cefic, and the European Crop Protection Association), which were given the opportunity to review and comment on the draft before publication; most of the authors are employees of industry-consulting firms (Exponent, Gradient) or paid consultants/testifying experts for the chemical industry in litigation over pesticides, PCBs, and dioxins.
Strong evidence.
Caveats
This describes the funding and authorship of the critique itself, not the truth or falsity of any individual claim it makes — several of its specific factual points are independently checkable against the primary sources it cites.
Source: Lamb et al. 2014, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Government agency
The European Commission describes its 2018 endocrine disruptor strategy as aiming to protect health and the environment 'at the same time' as preserving 'an internal market which delivers for consumers and where all EU business can thrive' — explicitly balancing precaution against industry competitiveness rather than only minimizing exposure.
Strong evidence: This is the Commission's own stated framing of its goals, not an independent assessment of whether the balance struck is adequate.
Source: EU Commission 2018 Link to this fact
The industry / Other evidence
A 2017 review concluding that mineral oils and waxes in cosmetics do not penetrate skin or pose a health risk was written entirely by employees of cosmetics manufacturers (L'Oreal, Johnson & Johnson, Kao, Procter & Gamble, Henkel, Beiersdorf) and the German cosmetics trade association IKW, and funded by that same trade association, despite the paper's own statement that its authors 'report no conflicts of interest.'
Strong evidence: This is a direct quotation from the paper's own Conflict of Interest and Acknowledgment sections, not an inference.
Source: Petry et al. 2017, Toxicology Letters Industry-funded Link to this fact
The industry / Government agency
The EU's cosmetics safety regulator (SCCS) assumes 50% of a cosmetic ingredient is absorbed through skin when no measured dermal absorption data exist, and requires at least a 100-fold safety margin between an animal no-effect dose and estimated human exposure before an ingredient is judged safe.
Strong evidence.
Caveats
General default methodology, not a finding about any specific chemical; the 50% is used only in the absence of adequate measured data, and a 12th revision (2023) may have updated it.
The industry / Government agency
As of 2021, the EU's cosmetics regulator states directly that it is not yet possible to use the fragrance industry's QRA2 methodology to set a concentration below which a fragrance chemical is unlikely to cause allergy in new users.
Strong evidence: A regulatory verdict on methodology validity, not a finding that current fragrance concentration limits are unsafe; QRA2 remains in industry use for setting IFRA limits regardless.
The industry / Government agency
The EU's cosmetics regulator treats chemicals suspected of disrupting hormones the same way it treats other health-concern chemicals: through a risk assessment weighing exposure level, not an automatic hazard-based ban.
Strong evidence.
Caveats
This is the SCCS's stated position for cosmetics specifically; other EU sectors (pesticides, biocides) use a stricter hazard-based approach for the same class of chemicals, a policy split the regulator itself has acknowledged elsewhere.
The industry / Measured in people or real products
This 24-formulation detergent skin-irritation comparison was sponsored and funded by the Soap and Detergent Association trade group, with test formulations supplied by a consortium including Procter & Gamble, Colgate-Palmolive, Shell Chemical, Unilever, Reckitt Benckiser, S.C. Johnson, Clorox, and Access Business Group (Amway); the study's statistical analysis was performed by a named Procter & Gamble scientist.
Strong evidence.
Caveats
Funding and authorship are directly stated in the paper's acknowledgments and affiliations; this is a description of the study's sponsorship, not an independent replication of its findings.
Source: Robinson et al. 2005, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Other evidence
All nine authors of this 2025 industry review of cosmetic spray inhalation exposure are current staff of cosmetics/fragrance manufacturers (L'Oreal, Chanel, Reckitt, Henkel, Beiersdorf x2, Unilever) or the EU cosmetics trade association Cosmetics Europe, plus one independent consultant who is a former Beiersdorf scientist — yet the paper's Declaration of Competing Interest states the authors have no known competing financial interests.
Strong evidence: Read from the paper's author affiliations and its competing-interest statement; whether the declaration breaches the journal's policy is not established here.
Source: Steiling et al. 2025, Toxicology Letters Industry-funded Link to this fact
The industry / Government agency
The EU gave cosmetics manufacturers a 3-year transition period to reformulate products and a 5-year period to sell through existing non-compliant stock after this fragrance-allergen expansion — explicitly citing 'the large number of new fragrance allergens to be individually labeled and the significant number of cosmetic products concerned' as the reason for the longer-than-usual timeline.
Strong evidence: Quoted from recital 11 of the regulation; this is the EU's own stated rationale for industry accommodation, not an independent assessment of whether the timeline is appropriate.
Source: Regulation (EU) 2023/1545 Link to this fact
The industry / Other evidence
All eight authors of this scented-candle health-risk-assessment paper are employees of the fragrance industry's research institute (RIFM), fragrance houses, a regulatory consultancy, or consumer-goods manufacturers with major candle and home-fragrance product lines, and the paper's own funding statement names a RIFM-organized consortium of companies.
Strong evidence: Direct quotation from the paper's own Conflict of Interest statement and title-page affiliations.
Source: Petry 2014, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Government agency
This hair-dye systemic-exposure study was conducted and written almost entirely by the hair dye's own manufacturer: 4 of its 5 authors, including the senior and corresponding author, were L'Oreal Research employees, with the human clinical phase subcontracted to TNO (Netherlands); no independent funding source or conflict-of-interest statement is printed in the paper.
Strong evidence: Named funder/sponsor: L'Oreal (Global Safety and Cutaneous Bioavailability and Metabolism groups); the specific hair dye brand/manufacturer tested is not named in the text.
Source: Hueber-Becker et al. 2004, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Government agency
This hairdresser hair-dye exposure study was sponsored by major international hair dye producers, and three of its seven authors, including the corresponding author, are L'Oreal employees in L'Oreal's own Worldwide Safety Department.
Strong evidence: Named funder: L'Oreal (Worldwide Safety Department), plus unnamed co-sponsoring hair dye producers.
Source: Hueber-Becker et al. 2007, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Review of other studies
This review's literature search and analysis were funded directly by Firmenich, SA, one of the world's largest fragrance and flavor manufacturers, and the review's organizing term "aromachology" was itself coined by the fragrance industry's own Sense of Smell Institute in 1982.
Strong evidence.
Caveats
Funding disclosure is stated verbatim in the paper itself. Industry funding of the review does not by itself invalidate the 18 underlying primary studies, most from independent academic labs; it is flagged so readers can weigh the review's framing and conclusions accordingly.
Source: Herz 2009, International Journal of Neuroscience Industry-funded Link to this fact
The industry / Other evidence
US flavor ingredients can be declared 'generally recognized as safe' (GRAS) by an expert panel appointed by the flavor industry's own trade association (FEMA), whose six to eight members must decide unanimously; the association's lawyer and science advisor wrote in 1995 that this private route is legal and need not be submitted to FDA.
Strong evidence: Authors are FEMA's counsel and science advisor, so this is the industry's own description and legal argument; it does not show FDA agreed in each case.
Source: Hallagan 1995, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Other evidence
Whether a flavor ingredient is 'generally recognized as safe' (GRAS) in the US is decided by a panel appointed by the flavor industry's own trade association (FEMA), and the panel's decision must be unanimous; by 1996 it had evaluated more than 1,700 flavor ingredients and judged the vast majority GRAS.
Strong evidence.
Caveats
Descriptive of the program as the industry itself describes it; the paper is written by FEMA staff and panel members, with a fragrance-industry (RIFM) liaison, and states no funder.
Source: Adams 1996, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Other evidence
The 1999 trial finding no rebound swelling from a benzalkonium-chloride-preserved oxymetazoline spray was funded by the spray's manufacturer, Draco Läkemedel AB.
Strong evidence: Funding does not show the result is wrong; it is a reason to want independent replication.
Source: [[src-1999-ten-days-oxymetazoline-nasal-spray-benzalkonium-chloride|Graf 1999 (Arch Otolaryngol)]], Archives of Otolaryngology–Head & Neck Surgery Industry-funded Link to this fact
The industry / Other evidence
The flavor industry's safety panel wrote its own 2005 rules for judging whether 'natural flavor' oils such as essential oils remain GRAS: the authors are the FEMA Expert Panel, FEMA staff, or consultants, and one employee of a flavor and fragrance company (Givaudan).
Strong evidence: A procedure paper, not an outcome study; funder is inferred from authorship (no funding statement printed). Industry-authored (FEMA).
Source: Smith 2005, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Other evidence
FDA has no conflict-of-interest standards for the scientists who make GRAS safety determinations for food manufacturers, even when they are employees or consultants of the company selling the product; the Government Accountability Office said in 2010 that FDA's oversight 'does not help ensure the safety of all new GRAS determinations'.
Strong evidence: As of 2013; FDA asked for comment on guidance in 2010 and the paper does not report the later outcome. Pew-funded authors.
Source: Maffini 2013, Comprehensive Reviews in Food Science and Food Safety Link to this fact
The industry / Other evidence
The 2018 procedure for judging 'natural flavor' safety in US food was written, and paid for, by the flavor industry's own trade group: all ten authors are FEMA Expert Panel members or FEMA's contractor staff.
Strong evidence: A procedure paper, not an outcome study; it says nothing about whether any flavor is unsafe. Industry-authored, named FEMA.
Source: Cohen 2018, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Other evidence
The flavor industry's expert panel (FEMA) declared 18 natural flavor extracts 'generally recognized as safe' (GRAS) in 2026, including oak moss, jasmine, tuberose, cassie, vanilla, bitter almond, and wintergreen; the work was paid for by three flavor-industry trade groups (IOFI, FEMA, and IFEAT), eight authors sit on the FEMA panel, and three work for FEMA's management contractor.
Strong evidence.
Caveats
Describes who funded and wrote the review, not whether the safety conclusion is wrong; the panel states it alone makes the determinations and publishes conflict-of-interest procedures.
Source: Guengerich 2026 (FEMA Expert Panel), Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Other evidence
The flavor industry's own expert panel (convened by the trade association FEMA, with 4 of 13 authors FEMA staff) declared 61 new flavor substances 'generally recognized as safe' in 2011, FEMA numbers 4667-4727, and printed the decision in a food-technology trade magazine.
Strong evidence: This is the panel's and trade association's own report; no FDA review of these decisions appears in the paper, and the paper says nothing on how members are chosen or paid.
Source: FEMA GRAS 25 (2011), Food Technology Industry-funded Link to this fact
The industry / Government agency
FDA reported 614 voluntary GRAS notices for human food from 1998 through the end of 2015 (about 34 a year; 69 in 2014 and 51 in 2015), compared with only 6 GRAS affirmation regulations finalized in the same period.
Strong evidence.
Caveats
Sections I.A and Responses 24 and 26. A count of notices filed, not of GRAS conclusions; the rule does not estimate the number never notified. Covers all food ingredients, not only flavors.
Source: FDA 2016, 81 FR 54960 Link to this fact
The industry / Government agency
In the 2016 GRAS rule FDA did not set any conflict-of-interest requirement for expert panels used to support GRAS conclusions; it said it would issue guidance, stated that the rule 'neither requires that a notifier convene a GRAS panel nor establishes any other requirements applicable to a GRAS panel,' and did not require notices to report panelists' independence.
Strong evidence: Responses 125-127 (p. 55026-27). FDA's later guidance was not checked. GAO had said in 2010 that FDA had issued no conflict-of-interest guidance.
Source: FDA 2016, 81 FR 54960 Link to this fact
The industry / Other evidence
In its 2018 GRAS 28 list the flavor industry's own Expert Panel said methyl eugenol (FEMA 2475) 'has been removed from the FEMA GRAS list' because 'additional data are required' on 'the relevance to humans of DNA adducts formed by methyl eugenol', 'until such data are available'.
Strong evidence: This is the industry panel's own statement in its own document; the statement is undated, so the year of the decision cannot be read from it (FEMA's 2020 review dates it 2015).
Source: FEMA Expert Panel 2018 (GRAS 28), Food Technology Industry-funded Link to this fact
The industry / Other evidence
The same GRAS 28 statement says herbs, spices, and essential oils that naturally contain methyl eugenol, 'including basil, pimento, allspice, etc. and their extractives', 'continue to meet the criteria for FEMA GRAS'; the document gives no intake figure or margin of exposure for these.
Strong evidence: Industry panel's conclusion; the supporting reasoning is not in this document (see the 2020 clove/bay-leaf paper for the intake calculation).
Source: FEMA Expert Panel 2018 (GRAS 28), Food Technology Industry-funded Link to this fact
The industry / Other evidence
GRAS 28 lists 60 new flavor substances, FEMA numbers 4817 to 4878 (4874 and 4875 absent), of which 21 (4846 to 4866) are citrus natural flavor complexes whose evaluation is deferred to a pending separate publication.
Strong evidence: Counts are from the document's own table; the FEMA numbers say nothing about FDA review.
Source: FEMA Expert Panel 2018 (GRAS 28), Food Technology Industry-funded Link to this fact
The industry / Other evidence
EWG Verified is a licensing program in which EWG writes the criteria, scores the products, pre-approves the mark's use in marketing, and can bar claims that 'would harm or discredit EWG'.
Strong evidence: EWG is an advocacy nonprofit, not an industry body, but it is an interested party acting as standard-setter, certifier and publisher.
Source: EWG Verified criteria for cleaning products (10.24), Environmental Working Group, 2024 Link to this fact
The industry / Government agency
FDA may review the qualitative formula behind a flavor supplier's "no artificial flavor" certification, but the regulation bars review of the quantitative formula and bars public disclosure of the notes outside a judicial proceeding; certifications are kept at least three years after supply ends (21 CFR 101.22(i)(4)(iv)-(v)).
Strong evidence: FDA verifies only "a reasonable number" of certifications, a representative sample, and does not request all. No data on how often this is done.
Source: 21 CFR 101 (4-1-24 ed.), Code of Federal Regulations, Title 21, Part 101 Link to this fact
The industry / Industry source
GAO found in 2010 that FDA had issued no conflict-of-interest guidance for the expert panels that companies use to support GRAS decisions, and that GRAS notices were not required to say whether the panelists were independent, so FDA 'does not know whether the determinations of companies' expert panels are arrived at independently'.
Strong evidence: The existence of actual bias was not measured by GAO; the concern comes from structure and interviews. FDA's 2016 rule answered with promised guidance, not a requirement.
Source: GAO 2010, GAO-10-246 Link to this fact
The industry / Other evidence
The UK Health Minister told the committee the Government had no credible evidence that homeopathy works beyond placebo ('the straight answer is no'), yet NHS bodies were free to fund it and the Department of Health 'does not maintain a position' on complementary treatments.
Strong evidence: Records the Government's stated position in late 2009; its formal reply is a separate document (Cm 7914) and may differ.
Source: UK House of Commons Science and Technology Committee, Evidence Check 2: Homeopathy (HC 45), Feb 2010 Link to this fact
The industry / Other evidence
The UK Government said the 'overriding reason' for NHS homeopathy provision is patient choice, not efficacy, while its Chief Scientific Adviser said the evidence for homeopathy is 'highly questionable' and worried the public would assume NHS provision means it works.
Strong evidence: Government's own characterization; the CSA's concern was about communication, and the policy stayed unchanged.
Source: UK Department of Health, Government Response to the Science and Technology Committee report 'Evidence Check 2: Homeopathy', Cm 7914 (July 2010), Command Paper Cm 7914 (July 2010) Link to this fact
The industry / Other evidence
In 2010 the industry-funded CIR panel reopened its trimonium review because behentrimonium chloride, a common hair-conditioner ingredient, was due on the priority list for its number of uses (641 reported), not because of a toxicity alert.
Strong evidence: Transcript statement by a panel member; use counts come from FDA's voluntary registration (self-reported by firms). CIR is funded by the Personal Care Products Council.
Source: CIR 2010 trimoniums (draft) Industry-funded Link to this fact
The industry / Other evidence
FDA's 2021 proposed order states that its scientific discussion of oxybenzone is generally the same as the 2019 proposed rule, which put oxybenzone in the category of insufficient data for GRASE.
Strong evidence: This is FDA's own statement of continuity; the industry's 2021 CIR report reached a different "safe as used" conclusion for a narrower use.
Source: FDA proposed order OTC000008 (2021) Link to this fact
The industry / Other evidence
Under FDA's drug rule a manufacturer must register each facility within 5 days of starting production (before import for foreign plants), list each drug within 3 days of registering, update registration every October-December, and review listings every June and December.
Strong evidence: Deadlines as of the 2022 edition. The text has no penalties section, so nothing here shows how often the rules are enforced.
Source: 21 CFR 207 (2022 ed.) Link to this fact
The industry / Other evidence
The paper declares 'no conflicts of interest' even though eight of its ten authors work for Kao USA, the company that makes and sells every lotion tested.
Strong evidence: Employment is not misconduct, and company-run testing is normal for product safety; the point is that the declaration does not name the employer's financial interest.
Source: Cameron 2013, Toxicology in Vitro Industry-funded Link to this fact
The industry / Other evidence
The cosmetics industry's own safety panel (CIR, funded by the Personal Care Products Council) concluded in 2012 that 52 trimonium conditioner and surfactant ingredients, including cetrimonium, steartrimonium and behentrimonium chlorides, are safe as used only 'when formulated to be nonirritating', and set no numeric concentration limit.
Strong evidence.
Caveats
Literature review by an industry-funded panel, so this is the industry's own position; about half the 52 ingredients are cleared on read-across with no ingredient-specific data. CIR is financed by the Personal Care Products Council, the cosmetics industry trade association.
Source: Becker et al. 2012 (CIR), Int J Toxicol, International Journal of Toxicology Industry-funded Link to this fact
The industry / Other evidence
A flavor sold to a food manufacturer must be labeled either with each ingredient by name or with the statement that all flavor ingredients are approved in an FDA regulation, and non-flavor or unapproved ingredients must be listed separately (21 CFR 101.22(g)(2)); the shopper's label need not show this detail.
Strong evidence: Supplier-to-manufacturer rule; our evidence base has no data on how often brand owners use the supplier label.
Source: 21 CFR 101.22 (eCFR 2026), Code of Federal Regulations, Title 21, Section 101.22 (eCFR) Link to this fact
The industry / Other evidence
FDA may review a flavor supplier's records to verify a 'no artificial flavor' certification, but only the qualitative formula, not the quantitative one, and the records may not be disclosed publicly except in a judicial proceeding (21 CFR 101.22(i)(4)(v)).
Strong evidence: FDA verifies a representative sample, not all certifications ((i)(4)(ii)); how often it does so is not in the text.
Source: 21 CFR 101.22 (eCFR 2026), Code of Federal Regulations, Title 21, Section 101.22 (eCFR) Link to this fact
Laws and loopholes / Review of other studies
As of 2008, no US federal law required companies to list all the chemicals in a consumer product or in its fragrance; air fresheners and laundry products did not even have to say they contained fragrance.
Strong evidence.
Caveats
US law as of 2008; MoCRA (2022) later required FDA-designated fragrance-allergen labeling for cosmetics only (rule pending at enactment); household products still uncovered for cosmetics.
Source: Steinemann 2009, Environmental Impact Assessment Review Link to this fact
Information, not medical advice. See also: myths we won’t tell you.