Lack of Transparency: Product Testing In Certifications Is Crucial

Want the real fine print no label includes? What’s on the bottle may not be everything in the bottle. For years, doing your homework meant reading ingredient lists, using scoring apps, and looking for trusted certification seals. That’s why we were so frustrated to learn that over 90% of the 113 products we tested contained at least one unlabeled chemical [1]. Our companion review found another major blind spot. None of the 18 programs reviewed used nontargeted testing to verify what was actually in the finished product [2]. Let’s unpack what our two latest papers reveal, and what consumers, brands, certifiers, and regulators can do to demand transparency backed by testing.

Key Findings:

>90% of products contained at least one unlabeled chemical.
85% contained at least one unlabeled chemical with a known or suspected health hazard.
Products listed an average of 16 ingredients, but testing found an average of 51 chemicals per product.
26% of products contained chemicals that contradicted their own label or marketing claims.
0 out of 18 chemical-safety programs required routine finished-product testing or used broad chemical screening to identify contaminants.

How to Choose Safer Products: Why Finished-Product Testing Matters

Consumers are doing the work. The problem is that nearly every tool they are given starts with the same incomplete information.

Reading labels, avoiding certain chemicals, choosing “free-from” products, and consulting apps or certification seals are thoughtful, responsible steps. Yet, these tools generally assess only the ingredients manufacturers intend to use and disclose.

They do not reflect the full chemical composition of the finished product. A scoring app cannot flag an unlisted contaminant, and a certification cannot assess a chemical it does not test for. That leaves consumers (and conscientious brands, retailers, and certifiers) making important decisions without the full picture.

Chemicals can enter through:

Raw materials
Manufacturing equipment
Storage
Chemical reactions
Packaging

All of these points of contamination can happen without ever appearing on the label. The answer is not to abandon labels, apps, or certifications, but to strengthen them with independent finished-product testing that verifies what is actually there. This data is the only way to give everyone better information to act on!

The Role of Testing in Product Transparency

Long before we began testing products, Million Marker was first founded by testing people. We developed The Exposure Test, a mail-in urine test that measures metabolites of phthalates, parabens, bisphenols, and oxybenzone to provide a snapshot of recent exposure.

In one Million Marker study, 174 participants documented the products they had used during the previous 24 hours. These participants underwent a product ingredient audit to receive personalized recommendations. Then, the participants completed follow-up testing.

Many participants acted on those recommendations, and some exposures declined. Others, including parabens, oxybenzone, and several phthalate metabolites, persisted [3]. Notably, our recommendations relied on the ingredients disclosed on product labels.

But the results raised a question we could not ignore. What if people were making thoughtful product swaps, but the products still contained chemicals the labels did not reveal?

The findings didn’t prove that contamination caused those persistent exposures, but they gave us an important lead. To better understand what people were encountering, we had to move beyond the label and test the products themselves. That’s why we started our nonprofit arm, Million Marker Research Institute (MMRI).

MMRI analyzes products and certifications to find the safest products and promote greater transparency for customers.

To achieve this goal, we performed two ambitious studies:

We used nontargeted analysis to examine 113 personal care and cleaning products, including products marketed as “natural,” “non-toxic,” and “fragrance-free.
Separately, we reviewed 18 widely used certification and ingredient-evaluation programs—from MADE SAFE, EWG VERIFIED, Cradle to Cradle, COSMOS, EU Ecolabel, and EPA Safer Choice to Clean + Planet Aware at Sephora, Target Clean, Yuka, and Think Dirty.

We’ve learned that independent testing is where claims become proof. Even when certification programs incorporate testing, it is typically targeted testing. These limitations are why products that appear to be safe choices on the label are still exposing health-conscious consumers to harmful chemicals.

Undisclosed Chemicals in Household Cleaning and Personal Care Products

To see how much a label might miss, we tested 113 personal care and cleaning products across 12 categories. These were products reported by Million Marker users and included items rated Go, Slow, or Stop based on their listed ingredients. The goal was not to represent every product on the market, but to examine a wide range of products people use.

Instead of searching for only a short list of known chemicals, we used non-targeted analysis, or NTA. In contrast, targeted testing is useful when you know exactly what you want to find. For example, a test can confirm whether methylparaben is present.

However, targeting a few specific chemicals may miss something unexpected. For instance, a test looking for parabens might overlook bis(2-ethylhexyl) phthalate (DEHP), which our study identified as a likely contaminant from plastic packaging.

NTA looks much more broadly. Think of targeted testing as shining a flashlight on a few known chemicals. NTA turns on the lights across the room. It can uncover chemicals that were never expected, listed, or included on a targeted testing panel. That broader view helps make “free-from” and other product claims more credible and verifiable.

Our results showed why that matters. Product labels listed an average of 16 ingredients, while testing detected an average of 51 chemicals per product. Over 90% contained at least one unlabeled chemical, and 85% contained at least one unlabeled chemical with a known or suspected health hazard. In 113 products, more than half failed our hazard-based contamination criteria.

Even products that looked reassuring on paper were affected. Of the 27 products initially rated Go, 59% failed contamination testing. Testing also found chemicals that contradicted claims on 26% of products, including phthalates or parabens in products marketed as free of them and allergens in products labeled “hypoallergenic.”

These findings raised an obvious next question. If labels and ingredient-based ratings can miss unexpected chemicals, what are product certifications actually checking? We wanted to know whether certification programs were independently testing finished products, or relying on the same ingredient lists and documentation. That question led directly to our next study.

Why Certifications Fall Short on Product Safety

A certification seal can feel like an extra layer of protection…and in many ways, it is. Certifications can help screen out known hazardous ingredients, improve formulation standards, and give consumers an easier way to compare products.

However, our review revealed a crucial limitation in the current system. Most programs are still evaluating what a product is supposed to contain, not directly measuring everything that is actually in the finished product.

We reviewed 18 certification and ingredient-evaluation programs used in U.S. and European personal care markets. 16 of those specifically evaluated chemical safety or ingredient hazards. Among those 16, none required routine analytical testing of finished products, and none incorporated non-targeted analysis.

Only six explicitly considered contaminants or impurities as a category. Yet, even then, evaluation was generally based on ingredient disclosures, manufacturer or supplier documentation, restricted-substance lists, and hazard databases.

A certification can do a strong job reviewing the ingredients a company reports and applying meaningful safety standards. The challenge is that if a chemical is not disclosed for testing, the certification may never have the opportunity to evaluate it.

Regulation works in a similar way. U.S. and EU systems differ in scope, but both still rely largely on ingredient rules and documentation, with much less emphasis on routinely testing the finished product itself.

The solution is not to throw out certifications. We want to make them more complete. Ingredient review and hazard screening remain valuable, but pairing them with NTA finished-product testing adds another layer by confirming what is actually present. Together, they give consumers and brands a more complete picture to act on.

Why Are Personal Care Products Contaminated?

A product can begin with a carefully chosen formula and still pick up unexpected chemicals before it reaches your bathroom shelf. Even brands operating with the best intentions may not have full visibility into every supplier, facility, material, and production step involved.

The finished product may differ from the intended recipe for several reasons:

Raw materials may already contain impurities.
Suppliers may substitute or alter ingredients.
Shared machinery, sanitation agents, or cross-contamination may introduce chemicals.
Ingredients may react with one another or form new compounds as they degrade.
Storage containers or packaging may leach chemicals into the product.
Fragrance mixtures may contain many chemicals covered by a single umbrella term.
Botanical ingredients may naturally contain numerous chemicals that are not listed separately.
In some cases, substances may be intentionally added but left off the label.

Our study found some of the same contaminants across different product categories. This suggests that shared raw materials, manufacturing processes, or packaging may contribute to the problem.

NTA can reveal an unexpected chemical, but it generally cannot show exactly where it entered the supply chain or whether it was added intentionally. Answering those questions requires follow-up investigation, stronger supplier oversight, clear communication when materials or processes change, and testing of both raw materials and the final packaged product.

We shouldn’t assume every unlisted chemical was deliberately concealed. Contamination can happen at many points along the supply chain. Therefore, consumers, brands, suppliers, certifiers, and regulators all have a stake in improving how products are made and verified.

Brands need better tools to find problems, correct them, and prevent them from happening again. At the same time, consumers can help push that progress forward by asking whether finished products are independently tested, how often they are retested, and what happens when unexpected chemicals are found.

How Finished-Product Testing Can Boost a Product’s Safety Profile

Finished-product testing does more than uncover unexpected chemicals. It can also confirm when concerns raised by an ingredient review are not supported by testing.

Before testing, we scored products using the ingredient lists on their labels because that is the same information consumers have when they are trying to make a choice. Using our scientific review of those ingredients, we also applied precautionary penalties when certain ingredients were known to carry a risk of contamination during manufacturing.

For example, an ethoxylated ingredient may raise concern about possible impurities even if those contaminants are not actually present. Finished-product NTA testing gives us the chance to check that assumption, remove the penalty when the contaminant is not detected, and give the product a more accurate score.

In our study, two products moved from Slow to Go, while 10 moved from Stop to Slow after suspected contaminants were not detected.

That is an important part of the story. Testing should not be about looking for problems or catching brands doing something wrong. It gives everyone—consumers, brands, certifiers, and regulators—better evidence to work with.

It can identify contamination that needs attention, rule out concerns that are not present, and help companies improve sourcing and manufacturing. NTA is the bridge for all transparency gaps in products, from supplier to brand to consumer.

How to Know If Your Product Is Safe

You should not have to become a chemist to shop for everyday products. While labels and certifications do not always tell the whole story, there are still practical ways to reduce potential exposure and push the market toward greater transparency.

Choose products with fewer ingredients of concern, and when possible, simpler ingredient lists overall.
Skip products listing “fragrance” or “parfum.”
Be cautious with “unscented,” which can still contain fragrance ingredients used to mask odor. Look for “fragrance-free” instead!
Choose glass, metal, unbleached paper, or cardboard packaging over plastic when practical.
Pay attention to expiration dates. As packaging ages or degrades, chemicals may have more opportunity to migrate into the product.
Support companies that are transparent about their ingredients, suppliers, and finished-product testing.
Ask brands a simple question: “Do you independently test your finished products for contaminants, and what type of testing do you use?”
Support stronger policies that require testing of finished products, not just review of ingredient lists and paperwork.

None of these steps can eliminate every possible exposure, and the responsibility should not fall entirely on shoppers. Just remember, your choices still matter. Supporting companies that embrace transparency can help make them more accessible to us all.

What Million Marker’s Findings Mean for Everybody?

Our two studies point to a practical way forward. Consumers deserve clearer information, brands need better visibility across their supply chains, certifiers and retailers need stronger ways to verify claims, and regulators need standards that keep pace with what testing can reveal.

Routine finished-product testing can help connect all of those pieces. It can catch changes that may occur as suppliers, ingredients, packaging, or manufacturing conditions shift. This useful resource can prevent health outbreaks from contaminated products and recalls for companies.

Our findings are meant to create clarity and action, rather than fear. Consumers can keep making informed choices, reach out to brands, and support companies that prioritize transparency. They can also stay engaged with chemical-safety policies at the local, state, and federal level and speak up when stronger protections are being considered.

Suppliers and brands can strengthen sourcing and manufacturing practices and incorporate testing into their processes. Certifiers can add more verification to their standards, while regulators can use testing data to inform policy. Together, these steps can lead to safer products, clearer standards, and greater confidence across the marketplace.

Test Yourself, Support Product Testing

Your exposome is the sum of the environmental exposures you encounter throughout your life, from the products you use to the air you breathe, the food you eat, and more. Understanding part of that exposome can help you take more informed action. The Million Marker Exposure Test measures your recent levels of certain harmful chemicals and turns those results into practical recommendations you can use in everyday life.

In addition to improving your exposome, those individual results also help inform the bigger picture. Patterns in what we see can shape the questions we ask next, the products we investigate, and the research priorities we pursue through Million Marker Research Institute.

Supporting MMRI helps keep that work moving. Your donations fund independent product testing, exposure research, and the evidence needed to strengthen transparency and product safety. The more we learn from both people and products, the more confidently we can decide what to study next and where change is most needed.