Ingredients added to consumer products: Disclosure requirements, trade secrets, and the public's health

Background: Consumer product corporations influence population health. Consumer goods including foods, beverages, tobacco, cosmetics, and household cleaners contain multiple chemical ingredients. As these products are in wide use, population exposure is great and the potential for harm increased. In light of growing concerns over population exposures to hazardous chemicals, we investigate the existing legal requirements for disclosures of product ingredients to U.S. regulatory agencies and consumers. Methods: This qualitative study relied on publicly accessible data sources including federal, corporate, and advocacy Web sites, news media articles, and the scientific literature. Results: Consumer products are sold without full ingredient disclosures to either government or consumers, and regulations vary by product. Product labels that refer to “flavor” or “fragrance” do not represent single ingredients but may in fact refer to flavor or fragrance “formulas” that are made up of multiple, undisclosed chemicals. Under existing food additive regulation, new flavors may be designated “generally recognized as safe” for their intended use in foods and added to foods and beverages without notifying FDA. A new law requires tobacco product ingredient disclosures to FDA. When pressed for disclosure, consumer product companies invoke the protection of their trade secrets to prevent ingredient disclosures. Implications: Consumer product corporations place the burden of being “informed” on consumers. Weighing a product's potential harms and benefits is impossible when both consumers and regulators do not know exactly what is in the product. To protect the public's health, regulatory agencies need to pursue increased disclosure and labeling requirements for consumer products.