Gifting Lip Products This Holiday? U.S. Safety Rules Do Not Fully Account for Incidental Ingestion or Absorption of Ingredients Through the Lips

The Lip Service Alliance's two peer-reviewed publications find that none of the six regulatory frameworks examined fully accounts for lip products' combined incidental ingestion and absorption through lip tissue at modern usage rates, even for formulas containing intentionally added microplastics.

Key facts

• A regulatory blind spot: Much of what goes on our lips doesn't stay there; it is ingested with wear or may be absorbed through lip tissue. In the U.S., only color additives need pre-market approval, and other cosmetic ingredients are not required to be assessed for incidental ingestion or long-term oral exposure (Lynch et al., 2026; DiGirolamo et al., 2026).
• Rules built on outdated usage data: Where regulatory frameworks make ingestion assumptions, they rely largely on data collected more than 20 years ago. A 2017 study reported lip-balm application of 1,270 mg a day at the 95th percentile, equivalent to around 93 five-gram tubes a year (DiGirolamo et al., 2026).
• Exposure can start in childhood: 45% of U.S. girls ages 6 to 8 already use lipstick or lip gloss (Mintel, 2017, cited in DiGirolamo et al., 2026).

LOS ANGELES, Nov. 11, 2026 — Many lip products are flavored and marketed like food and are popular as holiday gifts, yet two peer-reviewed publications find that regulatory frameworks do not fully account for repeated ingestion and absorption through lip tissue. In the U.S., FDA guidance on lead uses a 2005 lipstick-use figure of 87 mg a day, but there is no general requirement to assess other lip-product ingredients for incidental ingestion (DiGirolamo et al., 2026).

Laura DiGirolamo, a California attorney, identified the gap three years ago and founded the nonprofit Lip Service Alliance (LSA) to examine it, bringing together scientific and legal experts, including researchers at the University of Birmingham in the U.K. Their findings appear in two peer-reviewed papers in Oxford University Press's journal Integrated Environmental Assessment and Management.

"Marketing terms like 'clean' don't tell shoppers whether ingredients have been assessed for ingestion or absorption, yet lips have two doorways into the body. Popular products are often flavored and even sweetened like food, so we feel a real urgency to close this gap," said DiGirolamo. "An absence of proven harm is not the same as safety. I founded the LSA to raise consumer awareness, build the evidence with experts around the globe, and invite the industry to help us modernize how we make, market and regulate these products, which millions of people, including children, use repeatedly every single day."

The Global Framework for Lip Product Safety paper (DiGirolamo et al., 2026) reviewed six regulatory frameworks: the U.S., EU, U.K., Canada, China and South Korea. The EU acknowledges that lipstick is partly ingested and uses an assumption of 57 mg a day at the 90th percentile. By comparison, the heaviest lip-balm users in that 2017 study applied about 22 times the EU lipstick figure, although the figures relate to different products and population percentiles. The underlying regulatory usage data were collected more than 20 years ago, before lip oils, long-wear stains and product layering became routine. Today, 40% of U.S. women ages 18 to 34 use four or more types of lip product (Mintel, 2025, cited in DiGirolamo et al., 2026).

The authors do not conclude that lip products are unsafe but do conclude that the risks from lip cosmetics and their ingredients are not being accurately assessed at modern usage rates.

Examples of ingredients allowed in lip products

• Microplastics: U.S. law does not restrict them in lip products, and the EU's restriction on intentionally added microplastics doesn't take effect until October 2035, with "contains microplastics" labels required from October 2031.
• Titanium dioxide: The EU banned it from food in 2022 because DNA damage (genotoxicity) could not be ruled out and no safe daily intake could be set. Yet it is still allowed as a colorant in EU lip products, which are partly ingested.

It's not just ingestion, it's absorption too

The second paper, The Permeable Lip (Lynch et al., 2026), notes that the lip's protective outer layer is only 3 to 5 cell layers deep, compared with 10 to 20 on facial skin. Lips also lack oil glands and have blood vessels just beneath the surface, features associated with greater permeability than ordinary facial skin. Yet no regulatory framework reviewed requires testing on lip tissue. "Lips aren't ordinary skin," said Iseult Lynch, professor of environmental nanosciences at the University of Birmingham and an LSA board member. "They behave more like the lining of the mouth, which drugmakers use to deliver medicine straight into the bloodstream. Yet safety testing still relies on ordinary external skin and assumes ingestion is limited."

The researchers call for updated usage studies based on current usage patterns and demographics, testing on existing validated mucosal tissue models, and reassessing ingredients against ingestion safety standards. The LSA is developing a patent-pending lip tissue model that requires no animal testing.

Separately from the papers, the LSA advises shoppers to read ingredient labels, ask brands how ingestion exposure has been considered, and seek further information about the safety evidence for ingredients used in lip products. Learn more at lipservicealliance.org.

SOURCE The Lip Service Alliance