The Danish Consumer Council THINK Chemicals’ test methods

This is how we test for unwanted chemicals

• 
  What types of chemical tests do we perform?

  The Danish Consumer Council THINK Chemicals conducts two different types of tests: Declaration tests and tests with chemical analysis.

• 
  Declaration tests

  In declaration tests, we check the ingredients listed on the label or online of cosmetics and personal care products, laundry and cleaning products, and some food items.

  These can include:

  • Deodorants
  • Universal cleaning products
  • Chewing gum

  We check the ingredient declaration up against a wide range of problematic chemicals.

  The assessments we make in the declaration tests of many products within a product category are similar to the assessments we make of individual products in our free  app Kemiluppen (only for Danish consumers).

• 
  Tests with chemical analysis

  In our tests with chemical analysis, we send consumer products that you or your children may come into close contact with to laboratories, which then examine for  substances the products contain or release.

  These are typically products where we assess that chemicals can be released from the products causing exposure to you or your surroundings.

  These can include:

  • Toys and baby products
  • Packaging for food
  • Impregnation sprays
• 
  What substances do we evaluate?

  In our evaluations of products in tests and in the Kemiluppen app, we focus on substances that are on one or more of these lists, for example:

   

  • Endocrine disruptors Lists  (2020) - Denmark, Sweden, Belgium, The Netherlands and France
  • The EU Commission priority list of potential endocrine disruptors in cosmetics (2019)
  • Endocrine Disrupter priority list (EU 2007)
  • SIN (“Substitute It Now!”) List (CHEMSEC)
  • Substances mentioned by the National Allergy Research Centre
  • List of undesirable substances – LOUS (Danish EPA)
  • List of harmonised classifications (EU)
  • Candidate List of Substances of Very High Concern for Authorisation (EU)
  • SCCS opinion on fragrance allergens in cosmetic products and other opinions by the EU scientific committees
    
    See 'Opinions open for comments'
  • List of 26 fragrance substances that should be labelled (page in Danish).
  • Listing of POPs (Persistent Organic Pollutants) in the Stockholm Convention
  • The Priority List of the Norwegian Environment Agency
  • Perfluorerinated substances -The Helsingør statement and The Madrid Statement

  Other substances can be included, for example, if they have been assessed as problematic by a scientific body in Denmark or abroad (such as DTU Food Institute, BfR, EFSA, or similar). The same applies to substances that Danish or foreign authorities are focusing on. They can also include substances included in the criteria of an official or private labeling scheme (such as Ecolabelling Denmark, Oeko-Tex "Confidence in Textiles", or similar).

  Examples of other substances include:

  Ethylhexyl salicylate

  Ethylhexyl salicylate breaks down into salicylic acid, which is classified as harmful to reproductive health and suspected to be an endocrine disrupter. Ethylhexyl salicylate was previously on the Common Authority's list of endocrine-disrupting substances (2020). The substance was removed from the list in 2022 when the EU removed the substance from their assessment list (Corap) because they now assess the endocrine-disrupting effects of salicylic acid, to which ethylhexyl salicylate breaks down.

  Homosalate

  DTU Food Institute assesses that homosalate can be endocrine-disrupting based on toxicological studies and because the substance breaks down into salicylic acid, which is classified as harmful to reproductive health and suspected to be an endocrine disrupter. Homosalate was previously on the Common Authority's list of endocrine-disrupting substances (2020). The substance was removed from the list in 2021 when SCCS issued their assessment that the substance was not safe in a wide range of cosmetics and personal care products due to effects on reproductive health.

  Octocrylene

  DTU Food Institute assesses that octocrylene may have endocrine-disrupting effects on the thyroid gland. Additionally, there are studies indicating that octocrylene transforms into benzophenone in products. Benzophenone is a suspected endocrine disrupter. Octocrylene was previously on the Common Authority's list of endocrine-disrupting substances (2020). The substance was removed from the list in 2021 when SCCS issued their assessment that the substance was safe to use in cosmetics and personal care products up to a certain level, even though octocrylene showed effects on reproductive health in toxicological studies.

  Dihydroxyacetone (DHA)

  DHA can release formaldehyde, which is classified as allergenic and also suspected to be carcinogenic when the substance is inhaled.

  Titanium dioxide

  Titanium dioxide is assessed as not safe as an additive in food by the EU's European Food Safety Authority, EFSA. It cannot be ruled out that the substance can affect our genes and thus may be carcinogenic.

  We only assess titanium dioxide in products that are ingested, such as chewing gum, lip products, and toothpaste.

  Previously, we also assessed titanium dioxide in loose powder or spray products, as titanium dioxide was also suspected to be carcinogenic when inhaled. However, in November 2022, the EU Court of Justice ruled that titanium dioxide should no longer be classified as suspected to be carcinogenic when inhaled.

  Mineral oils

  Mineral oils are a diverse group of substances, some of which (MOAH) are suspected to be carcinogenic, while others (MOSH) are suspected to accumulate in organs.

  We only assess ingredients based on mineral oils in products that are ingested, such as lip products and toothpaste, or in chemical tests of food and food contact materials.

  Phenoxyethanol

  The French health authorities assess that phenoxyethanol should not be used in baby products for the diaper area. There may be a higher uptake of the substance due to vulnerable skin. We only assess phenoxyethanol in baby products intended for the diaper area.

  Extracts of daisy flowers

  Allergy to daisy flowers is well known. Whether extracts of daisy flowers are allergenic when found in skincare products is uncertain. Based on a precautionary principle, it is a good idea to avoid them in skincare products for the youngest children.

  We only assess extracts from daisy flowers, such as Chamomile recutita, Arnica montana, Anthemis nobilis, and calendula officinalis extracts, when they are found in baby products.

• 
  What effects do the substances we look for have?

  The chemicals that we look for in products are or are suspected to be:

  • Endocrine disrupting
  • Allergenic
  • Carcinogenic
  • Harmful to reproduction
  • Environmentally harmful (for example, substances that are difficult to break down in nature or substances that accumulate in nature or in animals)

  The chemicals typically do not pose an acute health or environmental risk but can be problematic with long-term exposure.

  The chemicals - and the products with problematic chemicals - do not generally represent a health or environmental risk on their own. However, they can contribute to an overall exposure to problematic chemicals that may pose a risk to our health or the environment.

• 
  What criteria do we choose products based on?

  In chemical tests, we select products based on:

  • Professional assumptions about which products may contain problematic chemicals
  • The ambition to develop knowledge in new areas
  • The ambition to focus on selected problematic chemicals or product categories
  • The ambition to meet consumers' interest in knowledge about specific product areas

  The focus is on products that consumers - including children and young people - typically come into close contact with.

  We particularly focus on products made of materials that may contain problematic chemicals.

  We select and purchase products for testing as a regular consumer would. That is, they are purchased in regular stores or webshops.

• 
  Declaration tests: How do we do it?

  Declaration tests involve us purchasing a range of products, typically cosmetics and personal care products, or laundry and cleaning products. We then review the declared ingredients on the label of the products.

  Food items can also be included in a declaration test. For example, we have tested chewing gum.

  We choose the products based on:

  • What consumers typically use or are exposed to
  • Professional assessments
  • The ambition to put focus on specific chemicals
  • The products are purchased in regular stores or webshops, which consumers have access to.
• 
  Declaration tests: How do we assess the substances?

  In our assessments of ingredients in cosmetics, personal care products, as well as detergents and cleaning agents, we follow some overarching principles.

  The content of:

  • Perfume and allergenic plant extracts (SCCS) generally results in a B rating for the majority of products. Exceptions are children's products, where the presence of perfume and allergenic plant extracts results in a C rating, while we do not evaluate perfume when it is present in toothpaste.
  • Extracts of chamomile trigger a B rating in children's products.
  • Preservatives that function by releasing formaldehyde result in a C rating. Other substances, such as DHA, which can also release formaldehyde, are assessed separately, and DHA triggers a B rating.
  • Substances classified in the EU as suspected carcinogenic, harmful to our genetic material, or detrimental to reproduction – known as CMR substances – result in a C rating in all products. This applies even if the use of these substances in cosmetics and personal care products has been deemed safe by the EU's Scientific Committee on Consumer Safety (SCCS).
  • Substances classified in the EU as persistently harmful to aquatic environments (Aquatic Chronic 1 and 2) trigger a B rating.
  • Substances assessed as persistent or difficult to degrade in the environment result in a C rating. This includes all PFAS substances, for example.
  • Substances classified in the EU as allergenic when in contact with the skin (Skin sens. 1) result in a C rating, with the exception of certain classified perfume ingredients, which are evaluated as perfume and receive a B rating.
  • Suspected endocrine disrupting substances result in a C rating in all products.
  • Substances assessed as problematic for ingestion by the EU's Scientific Committee on Food Safety (EFSA) are typically considered problematic only in products that are likely to be ingested to a significant extent. This typically results in a B rating.

  Some substances can fall into multiple of the above categories. For these substances, with few exceptions, it will be the lowest rating of the substance that applies to the entire product.

• 
  Tests with chemical analysis: How do we do it?

  Chemical analysis tests are conducted by sending a range of products – such as carpets, school bags, or children's tableware – to a laboratory for examination.

  Chemical tests can be expensive, so we typically do not analyze the entire chemical composition of a product or send a large selection of products for testing. Instead, we select a limited number of products to be examined for a restricted range of problematic chemicals.

  We determine which chemicals to investigate based on the materials used in the product and input from other studies in the field, as well as from authorities, researchers, and testing laboratories.

  Here's how it works in the laboratory:

  We send the products to the laboratory, and together with the laboratory, we determine whether it is the entire product or specific parts of the product that need to be examined.

  If multiple parts of the product need to be included in the test, we typically examine the various parts in a combined sample. This means that it is not always possible for us to pinpoint exactly which part of the product any unwanted substances originate from.

  The parts of a product that we consider relevant for examination are the parts that you can come into contact with when using the product.

  For a stroller, for example, this would include:

  • Upholstery and outer covering
  • Mattress
  • Canopy and handle

  However, this does not apply to the wheels and frame of the stroller.

• 
  Chemical Analysis: How do we assess the substances?

  We assess the content of chemicals in products with the premise that the safest option for consumers is products without problematic ingredients, and that the risk of individual products can contribute to an overall risk of undesired effects. This is known as the combination or cocktail effect.

  We rarely know the specific risk of the particular product.

  We evaluate the chemical content using external references to concentrations whenever possible.

  Our references can be limits used in legislation, in private labeling schemes, or official guidelines, even if they may not necessarily apply to the exact type of product we have tested or perhaps not to all substances within a chemical group. For instance, we can use toy regulations to assess content in strollers, even though strollers are not subject to the legislation. Or we can use legal requirements for certain phthalates to also assess the content of other phthalates.

  For some substances, we do not have direct references to concentration limits, and instead, we must establish the limit in other ways, such as by comparing the concentration in all tested products and with expert assistance from the laboratory, among other methods.

• 
  Chemical Analysis: These are examples of the substances we look for

  In materials in contact with food, we often look for:

  • PFAS
  • Phthalates
  • Bisphenols
  • Mineral oils
  • Primary aromatic amines

  In children's products, we typically look for:

  • Phthalates
  • Flame retardants
  • PAHs
  • Organic fluorine compounds
  • Chlorinated paraffins

  In other consumer plastic products, we typically look for phthalates.

• 
  What do the ratings A, B, C mean?

  In tests, we assign the ratings A, B, and C.

  There can be slight differences in what they mean in declaration tests and tests with chemical analysis.

  Rating in declaration tests and in Kemiluppen

  A-rating: The product is a good choice. It is without a range of problematic substances.

  B-rating: Be cautious. The product is free of several problematic substances, but it contains substances that you should be aware of. This could be perfume or substances that may harm the environment. You can avoid these products if you want to minimize the risk of perfume allergies or be more environmentally conscious.

  C-rating: The product contains problematic substances, such as those suspected of being endocrine disrupters. As a baseline, these substances are legally allowed for use, and the individual product is not inherently dangerous. However, it contributes to your overall exposure to problematic substances.

  Ratings in tests with chemical analysis

  A-rating: The product is a good choice. It is entirely free of or only contains small traces of the substance(s) we have investigated.

  B-rating: The product contains limited amounts of one or more of the problematic substances we have investigated. You may consider if there are better alternatives.

  C-rating: The product contains larger quantities of one or more of the problematic substances we have investigated. In some cases, it may contain illegal content, but most often, it consists of legal substances where the individual product is not inherently dangerous. However, it contributes to your overall exposure to problematic substances.

• 
  How do we inform companies?

  Both when conducting declaration tests and tests with chemical analysis, we send information about the test to manufacturers or Danish distributors/importers of the product. This happens before we publish the test.

  For declaration tests, we send information about the product and our comments on the product's content.

  For tests with chemical analysis, we send information about the product and the results of the chemical analyses. We do not disclose which laboratories test for us or provide test reports. We believe that by not disclosing this information, we can ensure that the laboratories can operate independently of other interests.

  The primary purpose is to inform the manufacturer about the upcoming test and the specific substances we are looking for, as well as to ensure that there are no factual errors in the results. Additionally, it gives manufacturers an opportunity to comment on the results before publication. Relevant comments can be made public in the test under the "What Companies Say" section.

  Companies are given a minimum of one week (5 business days) to send any comments to us, and if they request more time, we are flexible.

  Information about tests and the test results is also sent to authorities such as the Danish Environmental Protection Agency or the Danish Veterinary and Food Administration, and possibly other stakeholders.

• 
  How do we publish test results?

  Results for all tests are published on kemi.tænk.dk, where products are rated with an A, B, or C for their chemical content, along with information about the basis for the rating.

  If products have also been functionally tested, they are also published on tænk.dk. In such cases, the rating of the products' chemical content is included in the overall assessment by the Forbrugerrådet Tænk.

  Both declaration tests and tests with chemical analysis may also be published in the Tænk magazine.

  If it turns out that our test shows that a product contain chemicals that are illegal, the product is reported to the Danish Environmental Protection Agency or other relevant authority. These reports can also concern misleading claims, considering the chemical content. In both cases, the company is informed about the report.