LoginAnalysis: More Than Skin Deep
Cosmetic products like nasal tanning sprays and gel nail kits can pose a serious health risk. A CTSI campaign is helping educate consumers, but legislative gaps remain…
Helen Nugent, Freelance Contributor
Posted 26 May 2025 | JoTS Online
Content Tags: Analysis|Product Safety|National
In a world where social media is awash with versions of unattainable beauty, it’s not surprising that many people go to extraordinary lengths to meet an impossible ideal. From teeth whitening and skin lightening to artificial nails and lash tints, the beauty industry caters to every whim. Needless to say, the products servicing the more extreme procedures are not always safe or legal. In some instances, they are downright scary.
Consider nasal tanning sprays. Inhaled via the nose, they tan from within. As bizarre as that may sound, these unregulated products are very popular despite containing potentially risky substances. And, as unregulated substances in cosmetics go, this is the tip of the iceberg.
Last year CTSI launched its ‘Cost of Beauty’ campaign to warn consumers about the potential dangers of using various illegal and unsafe cosmetic products. Now the campaign is entering its second phase, focusing on key areas where the potential for consumer harm is high.
They’re completely untested and unregulated. We don’t know what they contain, and they are being sold in their thousands
Beauty comes at a cost
“From the engagement that I’ve had on The Cost of Beauty campaign, you’ve got members of the public who genuinely don’t know about the risks of some of these cosmetics products,” says Kerry Nicol, External Affairs Manager at CTSI. “But there’s also those who do know and they don’t mind – they’re happy to take that risk.
“All we can do is present those risks, provide the evidence that we have and the education, and hopefully steer them to safer products.”
Back in April 2024, when CTSI launched the first part of the campaign, it centred on three things: nails (UV gel and L&P (liquid and powder) nail kits), skin (skin-lightening creams), and teeth (illegal teeth-whitening kits). The second half of the campaign, launched in May 2025, will concentrate on three more areas: nasal tanning sprays, ‘at-home’ lash lift and tint kits, and nail adhesives/nail glue.
Nicol says: “These unregulated products are sold across online marketplaces, and lots of them are coming direct from overseas. They’re completely untested and unregulated. We don’t know what they contain, and they are being sold in their thousands. Trading Standards and other enforcement agencies are doing brilliant jobs to stop these products coming in at the ports and borders, but there’s only so much they can do; there are only so many containers they can check in a day. So, containers do get through and the products end up online or sold by unscrupulous traders.
“Our message is, go to a reputable retailer. Everything that’s in their stores has been tested and proven that they’re safe to use.”
As for the unregulated and illegal products, what harm do they cause? Let’s take a closer look.
Nails
UV Gel and L&P nail systems can cause allergic reactions and inflammation if not applied correctly. Problems are not confined to just the fingertips – they can occur anywhere the nail gel comes into contact with skin. Issues tend to arise when people use treatments at home, particularly those containing the chemicals HEMA and Di-HEMA. They are illegal for home use and, if someone develops an allergy, they can cause skin damage and lifelong side-effects.
Meanwhile, nail adhesives and nail glue are commonly used to apply artificial nails or nail art. They are readily available but some come with health and safety risks, especially if they are not used properly. Hazards include potential skin irritation, redness or even blistering if someone is sensitive to these substances. In addition, repeated use can weaken natural nails and aggressive removal methods can cause lasting damage to the nail plate.
Then there’s risk of fumes from the adhesive which can irritate the respiratory system, especially in poorly ventilated spaces, not to mention the risk of infection if applied on damaged nails.
In one truly terrifying case featured recently on the TV series Rip-Off Britain, 12-year-old Chloe Norris from Kent was left with horrible injuries after buying a false nail set from online marketplace Temu. During application, the nail glue was accidentally knocked over and got onto Chloe’s hands. The young girl said she had “never felt pain like that before” and that it was “very sharp and stinging”.
By the following day, the skin on Chloe’s hands had badly blistered. It transpired that the nail glue had burnt through to the nerve endings and Chloe was sent to a specialist burns unit for treatment. Skin from her thigh was used to replace the burnt skin on her hands. Thankfully, the surgery was a success but Chloe will always have scars and might never regain full feeling in her hands.
Caroline Rainsford is Director of Science at the Cosmetic, Toiletry and Perfumery Association (CTPA), the UK trade association representing companies involved in making, supplying and selling cosmetics and personal care products. It has been involved with, and supports, CTSI’s Cost of Beauty campaign.
“We welcome anything that helps to educate consumers about what to look out for and what to avoid,” she says. “We represent the cosmetics industry and we represent companies who are responsible and doing the right thing, so we and our members want to make sure that people aren’t buying products which are unsafe or which are from companies who are not doing the right thing. We work really closely with Trading Standards and we’d like to continue working with them in the future.”
Where it gets sad is when people have really damaged their skin due to the cosmetics and then they’re going back for more
Teeth
With years of scientific research and testing going into every item in our bathroom cabinets and make-up bags, a lot of work happens to ensure cosmetics produced by responsible brands are safe before they come onto the market. That is not the case with illegal teeth-whitening kits.
Dazzling white smiles beam out from magazines, movies and TV so it’s tempting to cut corners and attempt to replicate those pearly whites at home. But fraudulent merchandise can cause burns and damage to gums. While teeth-whitening products administered by dentists have a legal limit of 6% hydrogen peroxide, some teeth whiteners found for sale online contain up to 300 times the safe and legal maximum.
Skin
Then there’s the plethora of skin-lightening lotions, some sold legally while others are banned because of their harmful ingredients. The desire to have lighter skin is socially and ethically complex but, in the modern world, it is often perceived as being fashionable – and this is regularly reinforced on the social media pages of global celebrities.
The banned substances hydroquinone and mercury have been found by Trading Standards when checking and analysing skin-lightening and anti-blemish creams at the borders and at retailers inland.
While some skin-lightening creams can cause conditions like acne and eczema, the most dangerous can result in permanent disfigurement and serious long-term health problems.
In addition, skin-lightening creams being sold illegally in the UK have been found to contain twice the amount of active steroid ingredients that are allowed in prescription products. Brent Trading Standards ordered the removal of 625 listings for skin-lightening products purporting to be cosmetics from online marketplaces after it was discovered they contained high levels of various corticosteroids – unlicensed medicines available on prescription only.
Cenred Elworthy is Trading Standards Manager at the Royal Borough of Greenwich. He explains that hydroquinone in skin products has been banned in Europe and the UK but is still legal in the US and African retail markets.
“Hydroquinone is an industrial product and it’s cheap, whereas the stuff that’s legal in Europe that will lighten your skin is considerably more expensive. It’s actually quite good to have natural tanning processes in your skin. If you’re stripping your skin, you then get all the effects of the sun rays. And you can also end up with pigmentation problems, so you get lots of blotches. You can end up with a sort of hyper-pigmentation, which you wouldn’t think you’d get from skin lightening, and it could become cancerous at a later stage.”
He adds that illegal skin-lightening lotions are one of the biggest areas of cosmetics concern in London.
“It’s always there and that’s depressing, but there’s always a demand. I can understand the demand because the treatments are quite effective, but where it gets sad is when people have really damaged their skin due to the cosmetics and then they’re going back for more.”
As devastating as that sounds, at the opposite end of the scale are nasal tanning sprays – nasal tanners – which promise an all-over tan without sun exposure. Essentially, they tan you from the inside out. Not surprisingly, they are unregulated, possibly unsafe, and contain potentially risky substances like Melanotan 2 which can cause negative side effects such as nausea, vomiting, and high blood pressure. While long-term health impacts are not well-studied, serious concerns exist, including a potential link to melanoma.
Since they are not classified as medicines or medical devices, nasal tanning sprays are not subject to any kind of pre-approval, official oversight, production control, or post-marketing surveillance. And as inhaling sprays can irritate the respiratory tract, symptoms could include coughing, sneezing and nasal congestion. Repeated exposure could lead to chronic respiratory issues.
Nicol says: “We have become aware of sellers on social media sites posting pictures of nasal tanning sprays that are available in flavours, such as Red Bull, grape, strawberry and lime. These unscrupulous sellers are also marketing tanning drops and gummies designed to be ingested. There is a real concern that these products are being marketed at children given the child-appealing flavours and packaging, which causes a growing concern that this could lead to an epidemic, such as we have previously seen with youth vaping.”
There is a real concern that these products are being marketed at children given the child-appealing flavours and packaging
Eyes
Other products currently rising in popularity are ‘at-home’ lash lift and tint kits. Like other home-use merchandise, they contain strong chemicals. In these cases, perming solutions and dyes could cause irritation and even allergic reactions if they come into contact with the skin or eyes. Furthermore, chemicals touching the eye can result in corneal burns or infections that could leave the user with permanent damage.
For safety reasons, ingredients in some eyelash tints and lifts are only legally allowed in professional-use products. Professional hygiene standards are also crucial, as are professional application techniques.
The legal picture
When it comes to the legislative landscape, Rainsford says that the UK’s legal framework is extremely robust. In the UK, the manufacture and supply of cosmetics is governed by the UK Cosmetics Regulation (UKCR), EU Regulation 1223/2009 assimilated through the EU exit process and REUL Act. This is part of UK consumer product safety legislation and compliance is mandatory.
The UKCR controls what may or may not be put in a cosmetic and contains extensive annexes of banned substances and ingredients which may only be used when they comply with specific restrictions. These restrictions have been set following a detailed scientific review by a panel of independent scientists, who confirm that the ingredient is safe under these particular conditions of use.
Before it is made available for sale, each cosmetic product must undergo a safety assessment by a duly qualified and experienced safety assessor, who must have qualifications which are stated in the UKCR. The UKCR also provides guidance on how this safety assessment must be carried out. The safety assessment takes account of all the ingredients used in the cosmetic product, how the product will be used, by whom, where and how often. The product cannot be sold unless the professional safety assessor personally signs the report to say it is safe.
However, Rainsford points out, a number of products fall outside of cosmetics regulation. In some of those instances, including nasal tanning sprays, they default to the General Product Safety Regulation (GPSR). Richard Knight, CTSI Lead Officer for Cosmetics and Beauty, says that’s “a sort of catch-all backstop piece of legislation that we have for products that don’t have their own sector-specific rules”.
He continues: “Under General Product Safety Regulation, unlike with cosmetics where we can say to a producer or importer, ‘prove to me it’s safe’, with these products we have to prove they’re not safe ourselves. This is difficult because we might not even know what’s in them.”
night says there is “a huge borderline grey territory” regarding what falls under the main legislation and what doesn’t. “Many of the inquiries that I get from TSOs up and down the country are about borderline products. Are they or aren’t they cosmetics?”
GPSR is powerful but difficult to enforce. It only applies to products designed for private use by consumers. If a product is made for use in a salon, it falls into what Knight calls a “black hole”.
“People assume there must be rules that cover something somewhere. But our law is not that joined-up at times. So, you do get situations where business-use products, salon products, if they’re not caught by cosmetics [regulations], they might be caught by nothing. And the only people who can do anything about it are Environmental Health Officers going into the salon and trying to apply the Health and Safety at Work Act, Section 3, which is not easy.”
If they can’t even get the labelling right, that’s usually a good clue. If it doesn’t have the fundamentals, then we start digging more deeply
Trust the professionals
The bottom line for the consumer is this: buy from a reputable source. Also, Rainsford says that consumers can do simple checks to ensure that their product is legal and safe. “If there is a picture of the packaging online, you might be able to check if it has a UK company name and address on the packaging. Does it have writing and instructions in British English? Does it tell you how to use the product? Does it actually have information that you’d expect to see? And if you have any doubts or something doesn’t look right, then it’s best to trust the professional to apply it.”
Knight agrees. “We find all kinds of problems but we start with the labelling. Because if they can’t even get the labelling right, that’s usually a good clue. If it doesn’t have the fundamentals, then we start digging more deeply.”
Knight believes that better control of online selling platforms is crucial, not least because companies based overseas with no UK address can easily avoid enforcement action. It is also difficult to require online platforms to be more diligent in their approach to who sells products on their sites.
Meanwhile, Nicol concludes that Trading Standards Officers “don’t have the time and resources to do as much proactively as they would like to in this space. I think the opportunity for CTSI to do a public campaign that raises awareness, provides them with resources that they can use locally, and things that they can share with networks, has been beneficial.”
PLEASE NOTE: This content originally appeared on our standalone Journal of Trading Standards website (www.journaloftradingstandards.co.uk), which we are gradually migrating over to the Journal's new home on the CTSI website. Please bear with us while we complete this process. This will not affect the production of our Print Edition.
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Content Tags: Analysis|Product Safety|National
