Pretty Scary: Could Halloween Face Paint Cause Lifelong Health Problems? A Report on Heavy Metals in Face Paints

Overview

This Campaign for Safe Cosmetics report (Sarantis, Malkan, Archer 2009, copyright October 2009 by Breast Cancer Fund and Commonwealth) commissioned the independent Analytical Sciences laboratory (Petaluma, California) to test 10 children’s face paint and theater makeup products purchased through Amazon.com for six metals: arsenic total arsenic (tAs), chromium (Cr), cobalt (Co), nickel (Ni), lead (Pb), and mercury total mercury (tHg). Mercury and arsenic were not detected in any of the 10 products. Lead was detected in all 10 products at concentrations ranging from 0.054 to 0.65 ppm, with 7 of 10 products exceeding the U.S. Food and Drug Administration’s 0.10 ppm limit on lead in candy and all 10 products exceeding the EPA’s Safe Drinking Water Act 0.015 ppm limit. Nickel was detected in 4 of 10 products (range 2.1 to 5.9 ppm), cobalt in 2 of 10 products (range 4.8 to 5.5 ppm), and chromium in 5 of 10 products (range 1.6 to 120 ppm). Six of the 10 products exceeded the industry-recommended 1 ppm target ceiling for nickel, cobalt, and chromium combined (European Chemical Industry Ecology and Toxicology Centre 1993; Unilever Safety and Environmental Assurance Centre 2003). No metals were listed on any product’s ingredient label; the report frames these as ingredient contaminants likely originating from poor-quality inorganic (mineral) base materials.

Note on evidence tier: This is a B-tier NGO-commissioned report rather than a peer-reviewed primary study. The laboratory is independent and EPA-method-compliant, but the public document contains no replicate, blank, or matrix-spike QC data; no measurement uncertainty; and the n=10 convenience sample cannot support population-level inference about the U.S. face-paint market. The report itself states: “Testing 10 products does not provide a complete window on the entire face paint market. There may be products on the market that contain no lead, even though we found lead in all the products we tested.” Use as occurrence evidence demonstrating the presence of heavy metals in commercially available U.S. children’s face paints in 2009; do not treat the proportions (10/10 lead, 6/10 above 1 ppm Ni/Co/Cr) as representative of the broader market.

Key numbers

Sample frame (Executive Summary p. 4; How the Tests Were Conducted p. 7)

• Products tested: 10 children’s face paint and theater makeup products.
• Purchase channel: Amazon.com (shipped by a variety of distribution companies).
• Product formats represented: water-based products, cream-based products, grease-based products, crayons, cakes, and gels.
• Countries of origin represented across the 10 products: USA (3 products), China (4 products), Spain (1 product), United Kingdom (1 product), and one product manufactured in the USA with components made and packaged in China.
• Laboratory: Analytical Sciences, Petaluma, California (independent EPA-method-compliant lab; cost approximately $270 per sample).
• Personal communication acknowledged: Mark Valentini at Analytical Sciences (Report reference 38, September 25, 2009).

Analytes tested (How the Tests Were Conducted p. 7)

All 10 products were tested for the following six metals: arsenic (tAs), chromium (Cr), cobalt (Co), nickel (Ni), lead (Pb), and mercury (tHg) — the panel the report explicitly names on p. 7 (“All products were tested for the same metals, which included arsenic, chromium, cobalt, nickel, lead and mercury.”). Mercury and arsenic were not detected in any of the 10 products and therefore no concentration results are reported for them. Lead, nickel, cobalt, and chromium are the four metals with concentration data in the Test Results table (p. 8).

Analytical methods (How the Tests Were Conducted p. 7)

A “more sensitive test” was used for lead than for the other analytes because of the well-documented health concerns associated with low-level lead exposure (Executive Summary p. 7). The report does not state a numerical method detection limit, reporting limit, or LOQ for any analyte. The report does not document replicate measurements, matrix spikes, or method blanks in the public document.

Lead — found in 10 of 10 products (Test Results Table p. 8)

Lead was detected in all 10 face paints. Concentrations across the 10 products ranged from 0.054 ppm to 0.65 ppm. The product-form distribution of detections (no brand attribution; descriptors used by the report itself):

(Brand names are deliberately suppressed strict reading 2026-05-17; the format/origin descriptors above carry the identifying information without naming the brand. See Verification notes.)

Lead — regulatory benchmarks the report uses (Test Results p. 8; Lead p. 9–13)

• FDA limit on lead in candy (2006): 0.10 ppm. 7 of 10 face paints tested exceeded this limit (the report explicitly applies the candy limit as a comparator because face paints can be licked off the lips or transferred from hands to mouth).
• EPA Safe Drinking Water Act (1974) limit: 15 ppb (0.015 ppm). All 10 face paints exceeded this drinking-water limit; the highest face-paint result (0.65 ppm) is approximately 43 times the drinking-water limit.
• CPSC 2009 lead-in-children’s-products limit (Consumer Product Improvement Act § 101): 300 ppm in children’s products and 90 ppm in paint marketed to children under age 12. All 10 face paints were below both ceilings.
• Canada Hot List (Health Canada): lead is on the prohibited list for cosmetics.
• European Union Cosmetics Directive Annex II: lead is on the list of substances that must not form part of the composition of cosmetic products.

Nickel — found in 4 of 10 products (Test Results Table p. 8; Nickel, Cobalt and Chromium p. 14–15)

Nickel was detected in 4 of 10 face paints. Concentrations across the 4 detections ranged from 2.1 ppm to 5.9 ppm. The product-form distribution of detections:

Nickel was below the laboratory’s detection limit in the remaining 6 products. All 4 detections exceed the industry-recommended ≤ 1 ppm target ceiling cited by the report (European Chemical Industry Ecology and Toxicology Centre 1993 and Unilever Safety and Environmental Assurance Centre 2003).

Cobalt — found in 2 of 10 products (Test Results Table p. 8)

Cobalt was detected in 2 of 10 face paints. Concentrations across the 2 detections ranged from 4.8 ppm to 5.5 ppm. The product-form distribution of detections:

Both detections exceed the industry-recommended ≤ 1 ppm target ceiling. Cobalt was below the laboratory’s detection limit in the remaining 8 products.

Chromium — found in 5 of 10 products (Test Results Table p. 8)

Chromium (total Cr; speciation between Cr-III and hexavalent chromium (Cr-VI) was not performed in this study) was detected in 5 of 10 face paints. Concentrations across the 5 detections ranged from 1.6 ppm to 120 ppm. The product-form distribution of detections:

All 5 detections exceed the industry-recommended ≤ 1 ppm target ceiling. The report notes (p. 18) that the chromium detected in two of these five products may originate at least in part from chromium oxide green (an FDA-approved color additive that several sources identify as an allergen, particularly in tattoo pigments), though the analytical method used (total Cr by ICP-OES) cannot distinguish chromium-oxide-pigment contribution from chromium contamination of mineral base materials.

Aggregate summary across the 10 products (Executive Summary p. 5; report body p. 14–16)

• 10 of 10 products contained lead (range 0.054 – 0.65 ppm).
• 4 of 10 products contained nickel (range 2.1 – 5.9 ppm).
• 2 of 10 products contained cobalt (range 4.8 – 5.5 ppm).
• 5 of 10 products contained chromium (range 1.6 – 120 ppm).
• 6 of 10 products exceeded the 1 ppm industry target ceiling for nickel, cobalt, or chromium individually.
• 7 of 10 products exceeded the FDA’s 0.10 ppm limit on lead in candy.
• 10 of 10 products exceeded the EPA’s 15 ppb (0.015 ppm) Safe Drinking Water Act limit for lead.
• 0 of 10 products had detectable mercury or arsenic.
• Many products contained two, three, or all four of the four detected metals (Pb, Ni, Co, Cr); 4 products contained at least three of the four; 1 product (the USA-makeup / China-components greasepaint crayons, 6-pack) contained all four — Pb 0.074 ppm, Ni 4.1 ppm, Co 4.8 ppm, Cr 16 ppm.
• 3 of 10 products had no detectable nickel, cobalt, or chromium, demonstrating (per the report) that it is technically feasible to manufacture face paint without these contaminants.

Industry-recommended limits the report compares to (Nickel, Cobalt and Chromium p. 16)

• European Chemical Industry Ecology and Toxicology Centre 1993: “trace nickel, cobalt and chromium concentrations in consumer products are less than 5 ppm of each metal. It is recommended that this be accepted as a standard for maximum concentrations and that the target should be to achieve concentrations as low as 1 ppm.” (5 ppm hard ceiling; 1 ppm target.)
• Unilever Safety and Environmental Assurance Centre 2003: “household (and other consumer) products should not contain more than 5 ppm of each of Ni, Cr or Co and that, for an even greater degree of protection, the ultimate target level should be 1 ppm.” (5 ppm hard ceiling; 1 ppm target.) The report describes this as a reaffirmation a decade after the 1993 ECETOC guidance.
• 2001 follow-up study (same Unilever group) for chromium specifically in household products: same 1 ppm target.

Regulatory benchmarks cited by the report (Executive Summary p. 5; Nickel, Cobalt and Chromium p. 14–17)

• European Union Cosmetics Directive Annex II: nickel is banned in cosmetics in the European Union.
• EU Nickel Directive 94/27/EC (1994): restricts the rate of nickel release from objects that come into prolonged contact with the skin (e.g., earrings, piercings). The report describes this directive as a triggered driver of measurable decline in nickel sensitisation rates among Germans under age 30 (from 36.7 % to 25.8 % over an 8-year period) and Danish young female patients (from 27.6 % to 16.8 % between 1985 and 2007).
• Canada Hot List: chromium is banned in cosmetics in Canada.
• ASEAN Cosmetic Directive (Brunei Darussalam, Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, Philippines, Singapore, Thailand, Vietnam): chromium is restricted in cosmetics.
• EU Cosmetics Directive Annex II: chromium is restricted in cosmetics in the European Union.
• Italy, July 2009: Italian authorities pulled children’s makeup from store shelves because it was contaminated with chromium and nickel; the cited concern was allergy and dermatitis (Green Planet, “Italy, toxic substances found in cosmetics for children,” July 16, 2009; EU Consumer Affairs Rapid Alert System for Non-Food Products, Week 5, 2008, alert ref. 169).

Halloween-store ingredient-label scan (What Else Is in the Halloween Store? p. 19–21)

The report also documents an ingredient-label review of three additional Halloween-store products purchased at the Spirit Halloween store in Berkeley, California, on September 30, 2009. These three products are documented for label-disclosed ingredients only (no laboratory metals analysis). For each, the report names ingredients of concern flagged by FDA, the EPA, the National Toxicology Program, the Environment Canada Domestic Substance List, and / or the Cosmetic Ingredient Review panel: a neon hair-color spray (butane, basic violet 11:1, pigment green 7 not approved by FDA for cosmetics, diethylaminomethylcoumarin, pigment blue 15 not approved by FDA for cosmetics); a black-light hair spray (butane, propylene glycol, alumina); and a “fake skin” liquid latex (thiram banned or restricted in cosmetics in Canada and Japan, centrifuged natural rubber latex). These three products are not part of the laboratory-tested 10-face-paint dataset and contain no metals measurements; they are documented as label-disclosed contents observations.

Additional chemicals named on labels of the 10 tested products (Multiple Chemicals in Cosmetics p. 21)

Ingredients of safety concern named on the labels of products in the 10-product test set: butylated hydroxyanisole (BHA), methylparaben, diazolidinyl urea (formaldehyde releaser), propylene glycol, and parfum/fragrance (label-disclosed; no laboratory measurement of these compounds was performed in this study).

Methods (brief)

Convenience sample of 10 children’s face paint and theater makeup products purchased through Amazon.com in 2009. Products were delivered unopened to Analytical Sciences, Petaluma, California, for digestion and instrumental analysis.

For nickel, cobalt, chromium, and arsenic: approximately 1 g of face paint was weighed to the nearest mg, placed in a metals acid digestion cup, and digested with 5 mL of 1:1 nitric acid heated to 95 °C for 15 minutes; an additional 2 mL of nitric acid was added and the heated digestion continued for a further 30 minutes; after cooling, 2 mL of 30 % hydrogen peroxide was added; 2 mL of concentrated hydrochloric acid was then added and the sample was reheated to 95 °C for an additional 15 minutes; after cooling, 50 µL of yttrium internal standard was added and the sample brought to a final volume of 50 mL with 2.5 % nitric acid. The metals digestate was analysed by inductively coupled plasma spectrometry (the report names only “ICP”; EPA Method 6010 corresponds to the ICP-OES / ICP-AES family), calibrated with multiple certified standards and corrected for sample aspiration efficiency via the yttrium internal-standard signal. Results were reported on a milligram-of-metal per kilogram-of-sample (ppm) basis.

For lead: 1–2 g of face paint was placed in an acid-rinsed ceramic crucible, weighed to the nearest mg, and ashed in a high-temperature furnace at 550 °C (1,022 °F) in an oxygen-rich atmosphere for approximately 30 minutes; after cooling, the ashed sample was quantitatively transferred to a plastic digestion cup and brought to a final volume of 5.0 mL using nitric acid. The acid digestate was quantitatively introduced by autosampler into a graphite-furnace atomic absorption spectrometer operating with Zeeman background correction (EPA Method 200.9). The instrument was optimised and calibrated using certified lead standards prior to analysis of samples. Results were reported on a milligram-of-lead per kilogram-of-sample (ppm) basis. Lead was analysed by Zeeman graphite-furnace AAS — a “more sensitive test” than the ICP-OES used for the other analytes — because of the well-documented health concerns associated with low-level lead exposure.

Speciation discipline: arsenic and mercury are reported as total (tAs, tHg); chromium is reported as total Cr (the analytical method cannot distinguish hexavalent chromium from trivalent chromium); nickel and cobalt are reported as total. No method detection limit (MDL), reporting limit (RL), limit of quantification (LOQ), replicate-measurement RPD, matrix-spike recovery, or method-blank concentration is documented in the public report. The laboratory reported per sample (not per replicate); no per-product replicate count is documented.

Limitations the report itself names:

• Sample size: “Testing 10 products does not provide a complete window on the entire face paint market.” Findings cannot be generalised to the U.S. face-paint market.
• Non-detection inference: “the fact that we did not find mercury or arsenic does not mean that all face paints sold in the United States are free of mercury or arsenic.” Mercury and arsenic were both detected in Canadian testing of similar products (the report cites Schmidt 2009 Canwest News Service).
• Skin absorption: the report acknowledges that “There is limited evidence that lead can be absorbed through the skin, though this is less understood than other routes of exposure.” Ingestion (face-paint licked off lips, transferred from face to hands to mouth) and inhalation (dust) are the report’s framed exposure routes for children. The report does not produce its own dermal-absorption or hand-to-mouth-ingestion exposure model; benchmark comparisons are made to FDA candy and EPA drinking-water limits rather than to dermal or ingested-cosmetic doses specifically.
• Speciation: the report does not measure chromium speciation (Cr-VI vs Cr-III). The discussion notes that chromium oxide green is an FDA-approved cosmetic color additive and that the chromium detected in two of the five chromium-positive products may originate from intentional chromium-oxide pigmentation rather than ingredient contamination.

Implications

Contributes occurrence data for product category face-paint (10 of 10 lead-positive at 0.054 – 0.65 ppm; 4 of 10 nickel-positive at 2.1 – 5.9 ppm; 2 of 10 cobalt-positive at 4.8 – 5.5 ppm; 5 of 10 chromium-positive at 1.6 – 120 ppm). This is the earliest U.S.-market occurrence dataset for heavy metals in children’s face paint identifiable in this corpus. Because the sample is small and purposive, the occurrence-frequency proportions should not be propagated as market-representative; the per-detection concentration ranges are usable as documented presence-evidence for the four metals in U.S.-marketed face paints in 2009.

Contributes occurrence data for product category children’s-makeup (overlapping subset; theater face paints and children’s “play” face paints span both face-paint and children’s-makeup category usage). The report’s products labelled “play and music face painting kit,” “children’s face painting kit,” and “make-up” are children-marketed; the theater-targeted “color wheel,” “creme wheel,” “metallic fard,” and “fantasy F-X” products are not children-marketed but were purchased through general retail channels where consumer face-painting buyers may purchase them.

Contributes regulatory context for the U.S.-vs-Canada-vs-EU lead-in-cosmetics gap. The report documents that lead is on the EU Cosmetics Directive Annex II prohibited list and on Health Canada’s Hot List for cosmetics, while remaining legal in U.S. cosmetics in unlimited amounts; that the EU Nickel Directive 94/27/EC produced measurable reductions in nickel-sensitisation rates after passage in 1994; and that chromium is restricted in EU, Canada, and 10 ASEAN cosmetics jurisdictions while remaining legal in U.S. cosmetics. The 2009 Consumer Product Safety Improvement Act § 101 children’s-products lead limit (300 ppm in children’s products, 90 ppm in children’s paint) is the only U.S. federal lead ceiling that even nominally applies to children’s face paint, and all 10 tested products were well below it.

Contributes precedent for the 1 ppm Ni / Co / Cr industry target ceiling. The 1993 ECETOC and 2003 Unilever SEAC industry guidance documents are the report’s anchor for “what good manufacturing practice can achieve” on transition-metal contaminants in consumer products. Six of ten face paints exceeded this 1 ppm target ceiling for at least one of Ni, Co, or Cr.

Methodological precedent: EPA Method 6010 ICP-OES for transition-metal analysis and EPA Method 200.9 Zeeman graphite-furnace AAS for lead in cosmetic-product digestates; aqua-regia + hydrogen-peroxide digestion at 95 °C for ICP-OES analytes; dry-ashing in oxygen-rich atmosphere at 550 °C with nitric-acid re-dissolution for AAS lead. The lack of documented LOD/LOQ/QC data in the public report limits its replicability and is the principal driver of its B-tier rating.

Related evidence

• Lead
• Nickel
• Cobalt
• Chromium
• Face Paint
• Children's Makeup (ages 0-5)
• Children Personal Care (HMT&C Category 2 master)
• Makeup — body/leg paints, bases, fixatives (including airbrush)
• What's in My Baby's Food? A National Investigation Finds 95 Percent of Baby Foods Tested Contain Toxic Chemicals That Lower Babies' IQ, Including Arsenic and Lead
• Pretty Scary 2: Unmasking Toxic Chemicals in Kids' Makeup
• Potentially Toxic Elements in Costume Cosmetics Used by Children and Adults Are Associated with Cancer Risk
• Quality Assurance Project Plan: Parabens and Metals in Children's Cosmetic and Personal Care Products
• Children's Seasonal Products Report 2014-2015

Update history

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