The Insurance Implications Of The Recent Personal Care Products Chemical Contamination Study

A new peer reviewed study published in August 2026 in the journal Environment & Health has found that nearly all personal care and cleaning products tested contained chemicals not disclosed on their labels. 

What the study found 

The testing of 113 products including shampoo, hair styling products, sunscreen, moisturizer, baby care products, intimate products, fragrance, hand/body wash, deodorant, lip balm, oral care, oils and house cleaning products found evidence of unlabelled toxic chemicals. Nearly all products, 98%, contained at least one unlabelled chemical and 85% contained at least one with known or suspected health hazards. The products averaged more than three times as many chemicals than what was listed on their labels. 

The study also compared the label and web site claims of individual products for example 'phthalate free' or '100% natural'. Several products contained chemicals that went against their label claims, for example, 'phthalate-free' products containing phthalates. Synthetic chemicals were present in a significant percentage of products that claimed they were '100% Natural.' Products also made claims for being 'non toxic', 'free from harsh chemicals', 'harmful chemical free', 'Pure' or '100% Pure' but contained contamination or harmful chemicals contrary to those claims. A few products were labelled as 'hypoallergenic' but contained allergens and sensitizers.

Previous research has linked some of these chemicals to infertility, miscarriage, breast cancer, obesity, diabetes, allergies, and other health problems.

Among the chemicals detected were hormone disruptors and carcinogens such as phthalates, parabens, PFAS and formaldehyde – many of which are sometimes intentionally added to personal care products, and are linked to cancer, neurological disease, reproductive harm and damage to developing children.

Failure rates for large brands, regional brands, and small direct to consumer brands all landed between 50% and 60%, meaning neither a higher price nor a smaller company predicted a cleaner result.

There is growing recognition of the importance of regulating toxic substances in consumer goods and promoting the use of safer ingredients. The study concludes that its findings underscore the need for comprehensive testing as part of these policies to ensure product safety beyond what is listed on the label.

What do the findings mean for the insurance market?

The findings send a significant signal across multiple lines of insurance; for underwriters, claims managers, product liability specialists, and risk modellers. 

Failings in this space have already translated into mass recall events and large scale product liability exposure, such as in 2022, when Valisure found benzene, a highly carcinogenic chemical, in 27% of 663 products it tested, including some at life threatening levels. This triggered major voluntary recalls by Procter & Gamble, Bayer, CVS and others for brands such as Old Spice and Pantene. Research has found that there are no safe levels of benzene as it is so toxic at low levels and causes cancer.

The US banned benzene as an ingredient almost 50 years ago. Johnson & Johnson has also faced massive global litigation after allegations that its talc based baby powder was contaminated with asbestos and caused ovarian cancer or mesothelioma.

What are the insurance implications?

1. Product liability insurance

This is the most significant area of exposure. The study reveals a systemic, industry wide phenomenon. Labelling has failed to disclose harmful substances. This could result in consumer bodily injury claims and false marketing and misrepresentation claims. Some businesses may unwittingly be buying contaminated raw materials, this means that liability could sit with a manufacturer in the chain, a raw material supplier or a packager. In such cases whether indemnity and contribution obligations are adequately reflected in both commercial contracts across the supply chain will be critical. Insurers involved at multiple tiers of a supply chain may face exposures that are not immediately apparent.

2. Product recall insurance

Where unlabelled hazardous substances are identified in products, recalls becomes likely. Large scale, multi brand recalls requiring rapid market withdrawal, consumer notification, and disposal are costly and often insured events.

Recall insurers should note that the report authors have said that they have shared product specific findings with manufacturers, along with offers to assist in identifying potential contamination sources and exposure pathways. They say that most companies did not respond to these outreach efforts. The authors plan to identify potentially harmful products by name and highlight the manufacturers that engage in efforts to identify and reduce contamination in an upcoming report. There is a real prospect of voluntary or compelled recalls. Underwriters should review their books for concentration risk within this sector.

3. Directors’ and Officers’ (D&O) liability

Corporate officers and directors of personal care product companies face potential exposure on multiple fronts arising from this study:

• Securities liability: Publicly listed companies in this sector may face shareholder claims if they have made representations about product safety, compliance culture, or ESG credentials that are undermined by evidence of systemic undisclosed chemical contamination. 
• Regulatory investigations: Regulators may use studies of this nature to open enforcement investigations. Officers implicated in decisions about testing protocols, quality control, or labelling face personal liability exposure.
• Greenwashing: products labelled 'natural' or 'organic' also contained dangerous compounds. D&O underwriters should be alert to the growing regulatory and litigation risk around greenwashing, particularly where marketing claims cannot be substantiated.

4. Employers’ liability and occupational disease

Workers in manufacturing facilities who are exposed to undisclosed hazardous chemicals, potentially without appropriate controls in place because the hazard was not recognised may have grounds for occupational disease claims. Where safety is based on declared ingredients rather than the actual chemical profile of the products, employers may face liability. 

5. Environmental liability

Manufacturing processes and product disposal create pathways for contamination of land and water. Environmental liability policies covering manufacturers of personal care products may face increased exposure if regulators and others focus on this sector as a result of the study.

Key risk factors for underwriting assessment

Insurance professionals reviewing risks in the personal care products sector should consider the following in light of this study:

• Testing protocols: Does the insured conduct non targeted chemical analysis of finished, packaged products, or does its quality control rely solely on declared ingredients? The researchers recommend making non targeted analyses of finished, packaged products a standard part of product safety and quality control, alongside existing checks such as stability testing and microbial testing.
• Supply chain due diligence: How does the insured vet raw material suppliers? Are contractual protections and warranties in place?
• Marketing claims: What 'free-from' or 'natural' claims does the insured make, and what is the evidential basis for those claims?
• Regulatory jurisdiction: What markets does the insured sell into? Different markets have stricter regulatory oversight.
• Portfolio review: Assess concentration of exposure to personal care product manufacturers, retailers and supply chain participants.
• Policy wording review: Examine whether existing exclusions and conditions reflect underwriting intention.
• Pricing and reserving: Consider whether premiums adequately reflect potential long tail exposure.
• Monitoring of brand disclosure: The specific brands and products tested have not been released and the authors have said they will appear in an upcoming report. Do current insurance arrangements require insureds to disclose contact by the study authors?