While the FDA’s proposed maximum limit for lead of 10 ppm in cosmetic lip products and externally applied cosmetics is a step in the right direction, it does not go far enough. Clearly, a maximum limit of lead in cosmetic lip products of 5 ppm would be easily achievable since over 99.5% of the 479 cosmetic lip products surveyed by FDA met this standard. We urge FDA to decrease the recommended maximum lead level in cosmetic lip products and externally applied cosmetics to at most 5 ppm, or significantly lower as may be necessary to protect the public from the recognized harmful impact of exposure to even very low levels of lead.

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