Labeling Laws for Personal Care Products: Potential Pitfalls for the Consumer

Evelyne Tantry; Ariadna Perez-Sanchez, MD; Shelly Fu; Shravya Potula; Rajani Katta, MD


Skin Therapy Letter. 2021;26(5):1-6. 

In This Article

Hair Dyes

P-paraphenylenediamine (PPDA) is a common allergen, with the latest data placing it as the 10th most frequent allergen in North America.[2] Exposure is primarily via permanent hair dyes.

Although hair dyes in retail stores must list this ingredient, consumers face some challenges. First, unlike other products such as sunscreen, active hair dye ingredients are not required to be highlighted on the label. In fact, active ingredients are typically found as just one ingredient in a long list of chemical names. Second, products that are not intended for retail sale are exempt from ingredient declaration. Products used at a hair salon, therefore, may be exempt from providing ingredients.

In terms of product safety, consumers should realize that FDA approval is not required for hair dyes with PPDA. Regulations divide hair dyes into two categories: coal-tar hair dye (CTHD) and plant or mineral sourced hair dye. Although PPDA is not a coal-tar by-product, it falls into this category. Under FDA regulations there is no need for approval for any of the CTHD.[29] Even more worrisome, the FDA cannot take action against a CTHD even if "it is or contains a poisonous or deleterious ingredient that may make it harmful to consumers," as long as the manufacturer includes a caution statement.[29] The only exception is for dyes used in eyelash and eyebrow coloring.