Blood, Sweat and Pesticides: A closer look at toxic chemicals in period products

BLOOD, SWEAT AND PESTICIDES

ACRONYMS

AMPA - Aminomethylphosphonic acid

AMR - Antimicrobial resistance

ANSES - French Agency for Food, Environmental and Occupational Health and Safety

APAMI - Asia-Pacific Association for Medical Informatics

ASAP/PE - Associação Agroecológica do Pajeú

BCI - The Better Cotton Initiative

BPA - Bisphenol A

DBT - Department for Business and Trade

DDT - Dichlorodiphenyltrichloroethane

Defra - Department for Environment, Food and Rural Affairs

EDCs - Endocrine Disrupting Chemicals

EU - European Union

GHS - Globally Harmonized System of Classification and Labelling of Chemicals

GOTS - Global Organic Textile Standard

HHPs - Highly Hazardous Pesticides

HSE - The Health and Safety Executive

ICAC - International Cotton Advisory Committee

ISO - International Organization for Standardization

KEMI - Swedish Chemicals Agency

MRL - Maximum Residue Limit

NGO - Non-governmental Organisation

OBEPAB - The Benin Organisation for the Promotion of Organic Farming

OCA - The Organic Cotton Accelerator

OCDD - Form of dioxin (octachlorodibenzo-p-dioxin)

OPE - Organophosphate

OPSS - Office for Product Safety and Standards

PAN EUROPE - Pesticide Action Network Europe

PAN UK - Pesticide Action Network UK

PCOS - Polycystic Ovary Syndrome

PFAS - Perfluoroalkyl and Polyfluoroalkylated Substances

PPE - Personal Protective Equipment

SUDs - Single Use Disposables

TRV - Toxicological Reference Value

UK - United Kingdom

UK REACH - UK Registration, Evaluation, Authorisation and Restriction of Chemicals

UN - United Nations

US - United States

USDA - United States Department of Agriculture

VAT - Value Added Tax

VOCs - Volatile Organic Compounds

Wen - Women’s Environmental Network

WHO - World Health Organization

EXECUTIVE SUMMARY AND KEY RECOMMENDATIONS

Half of the world’s population will have periods during their lifetime, with women, girls and people who menstruate using an average of 11,000 disposable menstrual products throughout their life.1 Despite the prolific use of these products, the potential health impacts of the chemicals and pesticides that they can contain remains largely unexamined.

Broader societal and economic disparities linked to menstrual health persist across the world and here in the UK, with period equity remaining a significant issue, now compounded by the cost of living crisis. Furthermore, many women and other marginalised groups such as women of colour continue to be impacted by stigma around menstruation and systemic gaps in research into women’s health in particular.

It is within this context that this report aims to highlight concerns around the presence of harmful chemicals and pesticides in menstrual products, the lack of a regulatory framework in the UK to ensure that period products are safe to use, and how this impacts both consumers and cotton farmers around the globe, given that cotton is a main ingredient in both single use disposable menstrual products (SUDs), as well as in reusables.

In 2024, we conducted our own testing of boxes of tampons from UK shops and supermarkets, on a very small scale. We found glyphosate in tampons contained in one of the boxes at 40 times the level permitted in drinking water. Glyphosate is the world’s most commonly used herbicide, and in 2015 the World Health Organization (WHO) declared it to be a probable carcinogen, meaning that exposure to glyphosate is linked to cancer. In the US and other countries such as France, huge amounts of money has been paid in compensation to victims of glyphosate poisoning suffering from cancer, and there is increasing evidence that glyphosate is also linked to other conditions such as Parkinson’s.2 Given the global concern around the impact of glyphosate on human health, finding it in menstrual products is alarming.

Period products are used in and around a very sensitive part of the body. Chemicals absorbed via the vagina bypass the body’s metabolic system, entering straight into the bloodstream, a much more direct route in comparison to absorbing chemicals through the mouth or skin. Given that there are no safe levels of certain chemicals such as endocrine disrupting chemicals (EDCs), the safety margins for residues in period products should be below the level of detection with stricter regulations around additives and pesticide residues. However, this report reveals that the testing of period products does not take this into account. Products such as tampons can be treated as if they pose the same risk of chemical exposure as a t-shirt by some certifying bodies, despite the usages being very different in terms of absorption potential.

There is a regulatory vacuum in the UK when it comes to the chemical safety of our period products. There is no specific law beyond general consumer legislation requiring manufacturers to list the ingredients of period products, let alone any rule to prevent pesticide residues from ending up in the final product. Previous studies have shown that period products, namely tampons and pads and newer reusable products such as period underwear, can contain a variety of chemicals such as phthalates, perfluoroalkyl and polyfluoroalkylated substances (PFAS), dioxins, volatile organic compounds (VOCs) and heavy metals such as lead and arsenic. These chemicals have been linked to increased risks of reproductive and hormonal diseases such as endometriosis, infertility and cancer. While this news has been in the media, there remains very little research into the potential contamination of period products by pesticides.

This report also sheds light on the dangers faced by the cotton farmers themselves, at the beginning of the supply chain where the ingredients used in period products originate from. Cotton is often called the world’s “dirtiest crop”, as it uses more chemical pesticides than any other major crop in the world. Cotton farmers are being exposed to toxic pesticides at concerning levels and, particularly in the global south, are often working in environments with little to no protective equipment. Many cotton farmers are women, who face the health risks of working with pesticides both on the farm and in the home on a daily basis. However, this report also highlights the work of female organic cotton farmers, with case studies from Benin, Brazil and India demonstrating how the organic cotton movement improves the financial lives of women farmers, reduces health risks and acts as a source of empowerment to women.

In order to address these concerns, the UK Government must introduce specific and robust regulation to ensure the safety of period products, through mandatory testing regimes and requiring manufacturers to declare the ingredients used, with the ultimate aim of making period products residuefree. Furthermore, we urge the Government to provide only organic and additive free products through the hard-won national schemes providing free period products to schools. Issues around menstruation cannot be addressed in isolation: that is why we are calling for a Menstrual Health, Dignity and Sustainability Act to tackle the environmental, social and health related challenges around access to and the safety of menstrual products.3

By exploring the potential hidden dangers in period products and recommending some key policy changes, we aim to raise awareness and also encourage change at a national level. We urge the UK Government to prioritise the safety and sustainability of menstrual products for everyone who relies on them.

We are calling on the UK Government to take the following actions:

* Introduce robust government testing of period products.

* Introduce a legal requirement for manufacturers to disclose the ingredients and additives in all period products.

* Provide only certified organic single use disposables (SUDs) and additive free period products as part of the free period products programme in schools.

* Provide access to safe, healthy and affordable period products, as it is a human rights and public health issue. Wen (Women’s Environmental Network) is calling for a Menstrual Health, Dignity and Sustainability Act, which would give equal access to sustainable period products, improved menstrual education, independent testing, transparent product labelling and stronger regulations.

* Ensure a more joined-up approach between the Department for Health and Social Care and the Department for Environment, Food and Rural Affairs, to make sure that chemicals regulation is seen as an environmental and health issue.

* Ensure that research into the health impacts of pesticides and other chemicals includes gender disaggregated data, and specifically considers the gendered and intersectional impacts of exposure.4

For more detail on our recommendations, see page 27.

INTRODUCTION

Women, girls and people who menstruate will have nearly 500 periods in their lifetime.5 Menstruation is referred to as the ‘5th vital sign’ signifying if the body is functioning well or if there is a health problem that needs investigating, so menstruation can act as a crucial health indicator.6

In 2024, the ‘Feminine Hygiene’ market worldwide generated a revenue of US $49.75 billion.7 The UK market is forecast to reach £663 million by 2028, with the majority of market share comprising of largescale multinational companies producing single use disposable products. The period products industry therefore has huge economic influence and should be subject to robust regulation to ensure the health and safety of its products.8

Awareness of the environmental impact of waste arising from menstrual products has rightly grown in the public consciousness in the last decade, with many people choosing to move away from tampons and pads towards reusable alternatives such as menstrual cups, washable pads and period underwear.9 However, awareness of toxic chemicals, including pesticides, in menstrual products remains an area with a staggering lack of scientific research, as well as very little public awareness. This report seeks to change that.

Social and economic impact of periods

Periods are both a cause and a symptom of many wider problems in society that women, girls and people who menstruate have to face. Women, girls and people who menstruate are at an economic disadvantage when it comes to having periods. The so-called ‘tampon tax’ was only abolished in the UK as recently as January 2021, which finally removed VAT from tampons and pads, and in 2024 tax was removed from period pants. Furthermore, the cost of living crisis in the UK has reduced period equity, with many people having no money left for menstrual products, and therefore having to resort to using toilet paper, clothes, socks, or even newspaper, instead of pads. According to ActionAid, the number of UK women and people who menstruate who are struggling to afford period products rose to 21% in 2023, up from 12% in 2022. Those aged 18-24 were most affected, with 27% of this age group being impacted.10

There is still a huge amount of stigma attached to menstruation. 48% of girls aged 14-21 in the UK were embarrassed by their periods and 78% of girls do not feel comfortable discussing their period with their teacher.11 These statistics demonstrate that, despite half the population experiencing periods, there remains a huge amount of shame and stigma around them.

Shame and stigma around menstruation has affected every aspect of the issue. It arises from deep-seated cultural, social and religious origins and its impact is profound, influencing everything from the products we use to how we dispose of them.12 The taboos and stigma surrounding menstruation are compounded by the lack of education around sexual and reproductive health, leading to deepening and internalisation of existing fear, and embarrassment.13 This fear can delay medical treatment and diagnosis of painful and damaging conditions like endometriosis and fibroids, while religious restrictions in connection with food preparation or physical contact can exclude menstruating women, girls and people from everyday life, viewing menstrual blood as ‘dirty’ or ‘unhygienic’.

To add to this, there remains a lack of medical research into menstrual health and women’s health in general. Less than 2.5% of publicly funded research is dedicated solely to reproductive health,14 despite the fact that one in three women in the UK will suffer from a reproductive or gynaecological health problem in their lifetime.15

Black women especially miss out when it comes to reproductive health care – which is especially problematic given that they are up to three times more likely to experience uterine fibroids, and non-cancerous tumours causing irregular, severe menstrual bleeding and a multitude of health issues such as pelvic pain, pelvic pressure and infertility.16 Black women are also less likely to be taken seriously by health professionals and diagnosed with conditions like endometriosis.17

Toxic chemicals in period products

Many of the issues we currently have with additives and toxic residues in period products stem from manufacturers trying to appease consumers’ concerns around hygiene and the need to distance themselves from menstrual blood. Globally there are no sterility requirements for period products. In Europe, tampons and other period products are considered consumer products, and there is no legal requirement for these products to be sterile, so their whiter than white appearance and individual packaging is unnecessary.18 There are somewhat stricter controls in Canada, Australia and the United States where SUDs are classified as medical devices, although these regulations only covers pads, tampons and cups and not period pants.19 Nor do these regulations prevent residual chemicals and pesticides from ending up in period products.

It is perhaps understandable then that the potential presence of pesticides in tampons and pads is not the first thing on people’s minds when they get their period, given the social stigma, financial burden and physical pain that periods can cause. The general expectation from consumers is if a product is on sale, it’s safe to use. However, given the potential serious health impacts of these chemicals, we argue that it is not this simple.

‘Pesticide’ is an umbrella term for any substance that is designed to control a pest or disease. Types of pesticides include herbicides (designed to kill plants), insecticides (insects), fungicides (fungi), rodenticides (rodents) and molluscicides (molluscs). The term also includes synthetic plant growth regulators (which modify plant development so they can grow out of season), defoliants (that accelerate leaf fall) and desiccants (which dry leaves out so they can be harvested). As noted, some of these substances have been observed to be toxic and severely detrimental to human health.20 21 Consequently, observing residue in menstrual products is a cause for concern. However, there is a notable lack of studies in this area.

This report will outline how pesticides in period products have the potential to impact girls, women and those who menstruate. It will explore issues associated with pesticide use in cotton, the key crop used in tampons and many other period products. Not only do pesticides in cotton products impact the product users, but also the farmers at the beginning of the supply chain. With this in mind, we will highlight how chemical exposure impacts female farmers’ health and lifestyle through stories from cotton farmers on the ground.

Many period products such as tampons and pads, begin their life as a cotton plant. Most of the world’s cotton is grown on conventional farms (with only around 1% of global cotton being grown organically) meaning that a multitude of pesticides are used on cotton crops.22 Many of these are ‘Highly Hazardous Pesticides’ (HHPs) – a UN concept used to identify pesticides with high potential to cause harm to human health or the environment – and some of the most commonly used pesticides on cotton are classed as HHPs. HHPs have damaging impacts on human health, whether that be as carcinogens, endocrine disruptors or reprotoxins, which can damage the reproductive process. When it comes to the environment, HHPs used on cotton are highly beetoxic or are water contaminants, causing environmental damage in the regions where cotton is grown.23

There are a total of approximately 300 pesticides used in cotton production globally, with roughly a third of these classified as HHPs. They include 2,4-D, which is a carcinogen and a human reproductive toxicant; glyphosate, which is a probable carcinogen according to WHO; and benomyl, which according to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a substance known to induce heritable mutations in the germ cells of humans, as well as a human reproductive toxicant which can impact fertility and reproductive function.

This ultimately means period products have the potential to be contaminated with these harmful chemicals, despite some limited regulation and testing being in place. There is an astounding lack of research into the presence and dangers of pesticides in period products, which must change so that we can fully understand the potential harm that these chemicals could cause. Regulation must be strengthened to protect women, girls and people who menstruate, their health and our environment.

ANALYSIS OF PESTICIDE RESIDUE TESTING IN COTTON-BASED MENSTRUAL PRODUCTS

Results from our tampon testing

In Aug 2024, we sent 15 boxes of tampons bought in UK shops to a lab to screen them for pesticide residues.24 They were a variety of brands and had a mix of ingredients. Tampons normally comprise of rayon, cotton, polypropylene, polyethylene and polyester, with coatings to make them look whiter i.e. titanium dioxide, and paraffin used to keep the string clean. However, there is no legal requirement for manufacturers to list the ingredients.

Fifteen boxes is a very small sample size, as lab testing is extremely expensive. Despite this small sample size, the lab found glyphosate in tampons contained in one of the boxes. They were from one of the most popular and recognised tampon brands.

Traces of AMPA (Aminomethylphosphonic acid) were found, which is a breakdown of glyphosate. This indicates that the cotton was treated with glyphosate somewhere in the supply chain. We have no way of knowing exactly where the cotton came from or how it was treated. We also don’t know whether it was only found in one tampon or in all the tampons contained in the box, as this was not possible for the lab to distinguish.

Glyphosate is the world’s most commonly used herbicide. In Mar 2015, the UN World Health Organization declared glyphosate to be a ‘probable carcinogen’ for humans, meaning that repeated or long-term exposure to the chemical is linked to cancer.

In the US, the link between glyphosate and cancer has played out publicly in the courts, with thousands of lawsuits being taken against pesticide company Monsanto (now Bayer). They are the manufacturers of Roundup, of which the active ingredient is glyphosate, and thousands of plaintiffs across the US have been awarded damages for their diagnosis of non-Hodgkin lymphoma (a type of cancer). In 2020, Monsanto agreed to pay almost $11 billion to settle most Roundup cancer claims. Additional trials are expected to resume in 2025.27

The amount of glyphosate found in the box of tampons was 0.004 mg/kg. This may sound like a minuscule amount, however, in both the UK 25 and the EU 26 the drinking water maximum residue level is 0.0001 mg/kg (0.1 micrograms/kg). The amount found in the box of tampons was 40x higher than permitted levels of glyphosate in drinking water.

Calculating exposure

Converting these levels of glyphosate found in this box of tampons, we wanted to calculate how much glyphosate per day someone could be exposed to when using tampons containing the residue levels we found. To calculate this, we used a methodology developed by the French Agency for Food, Environmental and Occupational Health & Safety (ANSES) which has been used previously to measure daily exposure to chemicals found in period products.28

By exposure per day, we mean how much glyphosate an average person of an average weight would be exposed to via the particular box of tampons in which we found glyphosate. In the highest exposure scenario for an adult, we are looking at 0.0000024 mg/kg/day and highest exposure for a child (aged 11-14) at 0.0000048 mg/kg/day. According to the ANSES methodology, this is below the ‘safe’ level exposure to glyphosate (which is 0.1 mg/kg/day) and glyphosate metabolites including AMPA (which is set at 0-1 mg/kg). The table in annex 1 demonstrates how this is calculated and goes into further explanatory detail.

This calculation estimates how much glyphosate would enter into your body in an average day, if all tampons used contained the same level of glyphosate that was found in the sample we tested.

However, questions must be raised about this methodology that calls them ‘safe’. In a report from ANSES, it says: “Considering the close contact of the feminine hygiene products with the external genitalia and vaginal mucosa, the use of dermal Toxicological Reference Value (TRVs) – determined levels of a chemical that consumers can be safely exposed to over a specific period of time – seemed appropriate.29 However, because no TRVs were available for this route of exposure, a search for TRVs by the oral route was carried out.”

We checked the sources they referenced for their exposure limits and checked on the report quoting 0-1 mg/kg.30

The report stated: “The Meeting reaffirmed the group [acceptable daily intake] for the sum of glyphosate and its metabolites of 0–1 mg/kg of body weight on the basis of effects on the salivary gland. The Meeting concluded that it was not necessary to establish an [acute reference dose] for glyphosate or its metabolites in view of its low acute toxicity.”

In other words, this method of testing for ‘safe’ toxicity levels of glyphosate only takes into consideration glyphosate that is absorbed through the mouth, otherwise known as ‘oral exposure’.

Diagram: Relative dermal pesticide absorption rates for various parts of the body.31

Routes of exposure

Chemicals can enter the body by inhalation, ingestion and absorption – known as ‘routes of exposure’. The most common route of exposure to pesticides is through the skin. Some pesticides (lipid-soluble toxins) can be readily absorbed through intact skin.

Different parts of the body absorb chemicals at different rates. The image above demonstrates the rates of absorption for different parts of the body, in comparison to the rate of absorption to skin on the forearm (=1). Genitalia is 11.8x the absorption rate of the forearm, and even then this refers to the external area of the genitalia rather than internal absorption rates, meaning that chemicals entering the body from these areas of higher absorption pose more potential health risks.

However, this diagram doesn’t identify whether the ‘genital area’ is male or female. Absorption rates from internal exposure in the vagina are thought to be 10-80 times higher than through the skin on the body. We know this from research done on pharmaceutical absorption rates.32 33

According to Upson et al, “the mean maximal plasma concentration using the vaginal route was twice that of the oral route” and, in fact, chemicals that enter the body via the vulva have an absorption rate of twice that of chemicals that are absorbed through the mouth.34 This is partially due to the fact that absorption via the vulva means that chemicals bypass the metabolism and enter directly into blood circulation.

The trace amounts of glyphosate found in the box of tampons were not ‘unsafe’ based on the methodology by ANSES. However, the above information leads us to question whether it is appropriate to judge it as ‘safe’ just because oral exposure at that level has been deemed to pose no risk. There is a difference in the route of exposure, not least the concerning aspect that “chemicals absorbed by the vagina bypass first-pass metabolism by the liver and directly enter systemic circulation”. As tampons sit in the vagina and are used consistently by users during their period, the fact that glyphosate was present is indeed concerning.

Unfortunately, there is no ‘better’ residue limit to check this against. A pesticide residue limit refers to the maximum amount of pesticide residue legally allowed to remain on or in food and other products. When it comes to period products, the only options are to use the residue limits for food and water, or for textiles that include clothing.

There are no residue limits for menstrual products: which is a major gap in residue testing, and one that needs filling to ensure that those using tampons (and other period products) can do so safely.

The testing that we undertook was on an incredibly small scale, and our sampling was random. Given that we found glyphosate under these testing conditions, it is extremely likely that more traces of pesticides are in tampons and other period products being used by women, girls and people menstruating across the globe. While big companies have testing in place, we want to see an independent government testing programme that regularly tests and publishes the levels of pesticide and chemical residues in period products.

We are calling for government regulation of period products akin to the regulation around cosmetics, with full product ingredients on the label, independent testing for all period products and publishing of tests on a relevant website.

Currently, there is no adequate regulation for period products so manufacturers do not have to disclose the contents or additives used in their products. Wen has repeatedly highlighted the need for regulation35 and transparency,36 so that consumers can make an informed choice when it comes to the period products many of us use on a monthly basis, and in one of the most absorbent parts of the human body. The Department for Environment, Food and Rural Affairs (Defra) has deemed there is no need for this regulation because there is no clear case (or interest) to justify looking at regulating period products. In short, they are not a priority. This needs to change.

Consumers are currently being kept in the dark: companies are not required to list the ingredients of tampons on the box. This urgently needs to change, to ensure greater levels of transparency when it comes to the potential chemical pollution of menstrual products.

LITERATURE REVIEWWHAT CHEMICALS ARE IN OUR MENSTRUAL PRODUCTS?

With thanks to Rebecca Barry

Chemicals in Menstrual Products

It is fair to say that, generally, most chemicals and substances used in everyday household products are perceived by the general public to be safe for human health, but independent research has highlighted how there are multiple chemicals of concern present in menstrual products. See Annex 2 for the timeline of testing of period products that has been done to date.

Menstrual products contain a number of chemicals which are either added intentionally for the desired properties they bring, or produced and integrated as a byproduct of processing and manufacturing the materials. These chemicals range from dioxins and furans to endocrine disrupting chemicals (EDCs) such as phthalates and per- and poly-fluoroalkylated substances (PFAS, harmful chemicals widely known as ‘forever chemicals’, are a man-made chemical that are usually used for their water resistant qualities), and heavy metals such as arsenic, cadmium and lead.

The cotton farming process can introduce harmful pesticides into the raw cotton material used for menstrual products. Further processing may involve adding plasticisers, adhesives, softeners and fragrances, often introducing more harmful and potentially toxic chemicals. Residues from the bleaching process may also be present. Exposure to a number of these chemicals through methods such as ingestion or surface skin absorption has demonstrated harmful health effects, and so identifying these chemicals in menstrual products is particularly problematic and worrying.37

Pesticide residues have also been found in items like panty liners. In 2016, 3,000 boxes of panty liners were pulled from the French and Canadian stores as a precautionary measure after the French consumer magazine 60 Millions de Consommateurs found traces of glyphosate (25ng/g) in half the samples tested. Unlike SUD period products, panty liners and similar items like continence products are designed to be worn daily.

38

What chemicals of concern have been identified?

Pesticides are just one type of the many chemicals that can appear in period products and add to the overall toxic exposure. The following literature review outlines findings from other various studies and research.

PESTICIDES

One of the first of the few studies to test tampons for pesticide residue was commissioned and published by the journal Naturally Savvy, focusing on menstrual products commercially available in North America. It revealed low but detectable levels of eight known pesticides.39 The levels detected were below the threshold for concern used for food products, but tampons have a different exposure route to ingested food, leaving us to question whether these levels are truly safe.

Glyphosate is a potent herbicide and is the world’s most popular weed killer that has been linked to reproductive, immunological and endocrine system health issues.40 Its metabolite, aminomethylphosphonic acid (AMPA), has been found in other tests of period products.41

A study in Argentina by the University of La Plata from 2015 found levels of AMPA in period products comparable to our findings, when they tested a range of cotton-containing products purchased from a pharmacy.42 In their study, they found between 0.0015 and 0.006 mg/kg of AMPA per kg of product, as well as identifying between 0.0015 and 0.007 mg/kg of glyphosate. This further suggests the results from our tests are not exceptional and are replicated across international studies. The researchers published a short paper on the test results at the time and they plan to continue the work once they secure funding.43

Subsequent investigations and studies from a number of European institutions were conducted in response. The Bavarian Health and Food Safety Authority sampled 25 products, the Swiss Food Safety Office sampled 16 products, and the Swedish Chemicals Agency KEMI sampled 35 products. They all reported no traces of glyphosate or AMPA (a product of glyphosate breakdown) in the tampons they sampled.44 The first two studies had a limit of detection of 10 μg/kg, and the KEMI study had a limit of 100 μg/kg. The limit of detection is the lowest concentration of a chemical that a lab can reliably distinguish from zero.

The general consensus of these European studies rejected the idea that there were harmful pesticides in tampons. Upon first observation, this raises some questions over the accuracy and reliability of the initial Argentinian study, but this requires more in-depth and ongoing investigations. Critically, it highlights how there is no universal standardisation in detection limits used for menstrual products, and so studies testing for a higher threshold could report no detections, when there could actually be substances present but at a lower level. It reinforces the need to develop a new and standardised detection threshold that is specific to vaginal exposure, not food ingestion or external skin contact.

Any traces of glyphosate or other pesticides in menstrual products should be cause for concern, and more concrete parameters should be in place for health protection moving forward.

PHTHALATES

Phthalates are a group of chemicals often used in personal care products to retain scents, or for softening and strengthening plastics and adhesions. They have been found to have endocrine disrupting properties and negatively impact fertility. While they have a short half life in human tissues, constant or persistent exposure could lead to a substantial buildup in the body over time.45

In 2023, a wide-reaching systemic review of existing studies on menstrual products was conducted, led by Joanna Marroquin. The review explored 71 studies on chemicals in menstrual products, conducted between 2001 and 2021, from a range of global locations including the USA, Japan, Australia and the UK.46

The review identified seven studies that tested for the presence of phthalates. All studies found some form of phthalates in some, or all, of their samples. Five studies demonstrated evidence of phthalates in period pads, and two studies found evidence of phthalates in tampons.

A US-focused study based in New York found phthalates present in 90% of the 120 menstrual materials they sampled, along with parabens and Bisphenol A (BPA).47 The researchers found this to be of high concern for female health and toxic exposure and suggested period products were a ‘neglected source’ of exposure to phthalates for women.

Similarly, an earlier 2019 study by Park et al. observed the presence of phthalates in the majority of 79 samples of ‘feminine hygiene’ products, including sanitary (menstrual) pads, tampons, washes and wipes.48 Phthalates were found to be most prevalent in sanitary (menstrual) pads. The ‘feminine hygiene’ products were sourced from a range of locations, including Korea, Japan, Finland, France, Greece and the United States. While the concentrations differed slightly between the different geographical samples, we can see that this is evidently a global issue.

DIOXINS

Dioxins were also present in tampons and pads sampled in the studies in Marroquin’s review. These chemicals are environmental pollutants, usually byproducts of manufacturing activities mostly from the bleaching process of raw materials, and not added to products intentionally as they are extremely harmful to human health. They have been observed to affect the immune, nervous and reproductive functions with chronic exposure.49 Levels of observed OCDD (a form of dioxin) were seen to be increased with the advertised absorbency of the tampon, with super absorbent tampons displaying the most OCDD. The study also notes that, “Although dioxin levels were below safety thresholds for systemic exposure, no such threshold exists for menstrual products.” This again indicates that we lack adequately informed and researched exposure parameters for chemicals in menstrual products and are therefore unable to evaluate risk and potential degrees of harm that may be caused.

VOLATILE ORGANIC TOXIC METALS

COMPOUNDS (VOCS)

Volatile Organic Compounds were also noted in Marroquin’s review, as with other studies. These substances are often used as binders and absorbents in products or in their packaging. Exposure to high levels of VOCs can cause irritation, inflammation, detrimental reproductive effects and potential carcinogenicity.

A study by Gao et al. in 2019 focused directly on the presence of VOCs in what was categorised as ‘Feminine Hygiene Products’ from China. They noted that, while VOCs were found mainly in wipes and washes intended for menstrual hygiene, they were also present in tampons and pads in slightly lower concentrations. A similar study checking products from the US, noted that menstrual products labelled ‘sensitive’, ‘organic’, or ‘all natural’ did not have largely differing levels of VOCs compared to the other samples. In other words, levels of VOCs were similar amongst the samples despite different labelling which may have led consumers to believe otherwise.51 They found VOCs in all 79 commercially available menstrual products sampled.52 The observed VOCs may be “inadvertent or residual components in the product ingredients, used in manufacturing or packaging these products, or added for specific purposes, e.g. as fragrances, binders, and adhesives”. Researchers drew attention to the fact this was not evident on any packaging or ingredients lists. Despite the observed concentrations being measured as ‘low’, researchers felt that the presence of these chemicals should still be acknowledged on packaging, as we are still uncertain of potential risks associated to

One of the most recent and concerning discoveries around harmful substances in menstrual products was a 2024 study from Shearston et al. that identified measurable amounts of metals, (including toxic metals) in all of the 60 tampon samples that were investigated, from a range of brands.53

Metals can become incorporated into tampons in multiple ways. One potential route is through soil or water contamination of the cotton crops during the growing process. Pesticide sprays may also contain metals, which enter the growing cotton bud. Metals then leach into the cotton crop, which is harvested as a raw material to make the subsequent menstrual products. During the manufacturing process, some metals are purposely added for their desirable properties. This can be for antibacterial, anti-odour, whitening or lubrication purposes.

The study found that all of the 16 metals that were assessed were found in all of the tampons sampled, albeit in varying degrees. This included the presence of several toxic metals, such as lead, cadmium and arsenic. Worryingly, lead was found in all tampon samples, and is associated with numerous adverse neurological, renal, cardiovascular, haematological, immunological, reproductive and developmental effects. Even though the concentrations may have been low, there is no safe exposure level for lead – it is damaging in all doses.54

The study did not specify the manufacture location of each sample, but did state that these products were available for purchase in a range of global locations, including the UK. This therefore is not an isolated problem, but a global concern. The study also notes how, amongst all three governing bodies where the tampons were purchased (the UK, the US and the EU), regular product testing for menstrual products is not required, and product legislation is far from extensive. This study demonstrates the urgent need for action in the health regulation of menstrual products in a universally agreed and enforced mandate.

This was the first study to ever examine the presence of metals in tampons, and after the publication of some very alarming results, should definitely not be the last. Following its publication, there has been significant media and public attention directed at the safety of menstrual products, which can hopefully be harnessed and used as momentum to propel further research, advocacy and intervention.55

FRAGRANCES

Fragrances are substances used to provide scents to products, most notably personal care products. Not all fragrances used in personal care products are harmful to health. Unfortunately, however, many fragrances are actually known to have damaging effects, but companies are not mandated to display extensive ingredient lists on packaging for consumer products, as highlighted by CHEM Trust.56 It is somewhat unsurprising that this is the case in menstrual products too, which exhibit fragrances often unrecorded in packaging, sometimes at levels prohibited in cosmetics due to skin sensitising. Both the EU regulations on cosmetics and toys ban or restrict fragrance ingredients often found in fragranced period products.

Fragrances from SUDs and reusable period products can also cause skin irritation and inflammation,

In fact, if the same level of fragrance that was found in period products was found in personal care products or children’s toys, it would require mandatory labelling.57 But no such regulation exists for period products.

and have been associated with increased rates of bacterial vaginosis and yeast infections.58 Use of products like douches, wet wipes and certain lubricants make the vulva more susceptible to sexually transmitted infections and inflammation, which in turn can allow any chemical or pesticide residues present to be more readily absorbed. 59 60

However, more worryingly, fragrances can be constituted from a number of different toxic chemicals as noted by the ‘Chem Fatale’ report from Women’s Voices for the Earth. These can include carcinogens, reproductive toxicants, endocrine disruptors, problematic disinfectants and numerous allergens.61

It is also worthwhile considering exposure to harmful chemicals, especially fragrances, through a demographic framework, to identify groups that may be at increased risk. A recent US study examined the uses of fragranced vs non-fragranced menstrual products amongst 661 individuals who menstruate. Through a demographic lens, they found that those with a higher level of formal education opted most often for unscented products, and those with a lower level of formal education appear to have opted predominantly for fragranced products.62

Additionally, they found that fragranced menstrual products were chosen far more frequently by black women than white women. The researchers draw attention to the potential contributing factor of negative socio-historical attitudes towards black women being a motivator for their current behaviour to pursue odour control and hygiene. They illustrate how this has been observed in other self-care behaviours in black women, such as hair scenting and styling.63 There are likely, of course, to be compounding factors underlying this pattern of fragranced product use, including social and cultural norms.

As the study has not been replicated in the UK, we cannot assume that the patterns it shows would be directly translated to this geographical region. However, it does bring to light important considerations around health equity, and which population demographic groups face greater health due to higher exposure to chemicals in menstrual products including fragrances.

The lack of research and awareness around chemicals and menstrual products

As this report has already discussed, there is arguably a lack of existing research that investigates the health impacts of these chemicals on the female body through the exposure route of direct/invasive contact, and for the duration and persistent monthly use that is most common for the “average” woman or person who menstruates. There is a gap in long-term, in-depth studies, which would have the potential to reveal the reality of exposure impacts.

This is coupled with a lack of consumer awareness around which chemicals are harmful to health, and which chemicals are actually present in menstrual products. While research is slowly being carried out, women and those who menstruate are still using potentially harmful products without being properly informed. Companies themselves have even been found to be unaware of chemicals including PFAS being present in their products.64 If producers and marketing agents are not fully informed about the constituents of their products, how is the consumer expected to make an informed decision?

Some women, girls and people who menstruate turn to brands and products marketed as sustainable or eco-friendly, in the pursuit of both their own and environmental health. Scientific studies in the chemical toxicity of these products are scant. However, an investigation into a manufacturer of reusable period underwear, found PFAS present in some of their products.65 The manufacturer in question denied the use of these chemicals in their products, but settled in a class-action lawsuit.66 These situations put consumers in a very difficult position, as even brands advertised as being sustainable, healthier and more environmentally friendly could pose further or unknown chemical exposures.

As for the lack of independent studies around pesticide products specifically, it may be the case that pesticides break down during the manufacturing process into other observable and known harmful chemicals, and so current studies focus on identifying these substances over the pesticide itself. For example, some pesticides also fall into certain chemical groupings, such as being Volatile Organic Compounds (VOCs, which are carbonbased substances that evaporate at normal room temperatures and pressures), and so studies may test for the collective chemical group as opposed to the named pesticide. Alternatively, it could be a general lack of awareness of this issue until relatively recently, or the absence of funding. Again, the lack of knowledge available indicates a need for further research.

Menstrual products are often socially taboo or stigmatised subjects, which can limit the fluency of discussion surrounding them. However, the research suggesting the potential dangers of chemical exposure through menstrual products should act to catalyse discussion, awareness and further intervention in this area to cultivate optimal health and well-being for all those who use period products.

HOW PESTICIDES IN PERIOD PRODUCTS IMPACT WOMEN’S HEALTH

Women can be particularly exposed to and affected by pesticides, not just because of their biology but also the various intersectional issues that affect everything from the work they do to where they live and the various racial and cultural factors that define their lives.

Biological factors such as higher levels of adipose (fat tissue) leading to a build-up of higher concentrations and so prolonged detoxing in females, thinner skin 67 and smaller bodies (resulting in illfitting personal protective equipment (PPE)), different immune systems, and a lifetime of hormonal changes in puberty, menstruation, pregnancy and menopause means women, girls and those born female are far more susceptible to the impacts of exposure to pesticides and toxic chemicals than men or those born male.68 In fact, there are differences right across the body systems between males and females and this is important when it comes to research on the effects on health from exposure to pesticides and chemicals.

69

The fact that children as young as eight years old are starting their periods means a longer lifetime use of period products and longer exposure to residues found in these products. In both the UK70 and US71 this early onset of menarche has been linked to lower socioeconomic status and a heavier body mass index, with racial disparities among Black, Asian Pakistani and Bangladeshi girls starting puberty earlier than their White counterparts. Black girls are more than twice as likely to start their periods earlier than white girls.72 The rate of early puberty onset73 has been linked to exposure to certain chemicals, metals and pesticides.74 Ironically, these are some of the same chemicals and metals that have been found in period products, i.e. phthalates, cadmium and lead.75

Why is exposure to these chemicals in menstrual products particularly concerning?

ENDOCRINE DISTRUPTION

Many chemicals mentioned in this literature review fall under the domain of being ‘endocrine disrupting chemicals’ (EDCs), and in particular numerous pesticides fall into the chemical category of endocrine disruptors.76 The endocrine system works to regulate the body’s growth and development through the production and regulation of hormones. In women and those born female, this hormonedisrupting ability bears particular relevance.

Greater levels of hormones like oestrogen are linked with hormonally related diseases such as breast and ovarian cancer. As these chemicals can be found in many everyday products used predominantly but not exclusively by women, e.g. cosmetics, personal care products, period products and cleaning products, they are particularly at risk. EDCs have been linked with increased rates of breast77 and ovarian78 cancer, reproductive and neurological disorders, infertility79 and autoimmune diseases in women.80

Endocrine disrupting chemicals, including dioxins, phthalates and VOCs, interfere with this carefully tuned biological system.81 They may mimic certain hormones or block hormone receptors, causing the body to respond in a way that can incite detrimental effects on the health of the individual.82 Research has linked exposure to endocrine disruptors more generally to the development of cancer, metabolic diseases and infertility.83

REPRODUCTIVE HEALTH

Endocrine disruptors have been shown to affect reproductive health, which is concerning given the proximity and the invasive nature of menstrual products to the female reproductive system. Endocrine disruptors therefore have a much closer interaction with some of the glands and organs responsible for producing and regulating reproductive hormones, which is likely to maximise their detrimental impact on fertility and on fertilityaffecting illnesses.84

Research indicates that there may be a relationship between endocrine disruptor exposure and the development of endometriosis and adenomyosis, two very painful fertility-affecting illnesses, both affecting one in ten women in the UK.85 There is also a connection between glyphosate and endocrine disrupting chemicals and Polycystic Ovary Syndrome (PCOS).86 Environmental exposure to EDCs like dioxins, phthalates and BPA (all found in period products) is also strongly associated with the onset of endometriosis,87 and the presence of endocrine disruptors in menstrual products is suspected to exacerbate symptoms and severity of existing diseases like endometriosis and adenomyosis.88

LACK OF RESEARCH

Although it is estimated that 385 million people or half the world’s farmers and farmworkers are unintentionally poisoned by pesticides each year, due to the lack of gender disaggregated data there is no specific data on how many female workers are harmed or killed.89 If damage to health is not recorded then there is no requirement for health and safety measures to be introduced.

COCKTAIL OF RESIDUES

There is a growing body of evidence that pesticides can become more harmful when combined, a phenomenon known as the ‘cocktail effect’.90 Despite this, the regulatory system in the UK and globally looks at individual chemicals and safety assessments are only carried out for one pesticide at a time.

Daily cumulative and combined exposure to a cocktail of chemicals and pesticide residues is linked with a range of illnesses and diseases. Exposure occurs in the home, workplace, external environment and from products such as period and other products used on a regular basis. More recently, bisphenols (endocrine disruptors) have been found in 50% of women’s everyday underwear tested in the EU, with 17% containing high levels of bisphenols of concern.91

Certain pesticides like glyphosate and its metabolite aminomethylphosphonic acid (AMPA), lindane, organochlorine, organophosphate (OPEs) and the fungicide hexachlorobenzene have all been found in a range of period and menstrual care items such as pads, tampons and panty liners.92 93 Despite these studies going back to 2016, pesticides, chemicals and substances of concern still continually turn up in residue testing of period products.94 95

Exposure to pesticides like glyphosate can damage the health of the human microbiome, which is essential to health and well-being.96 The vaginal microbiome, just like the gut, is extremely sensitive to exposure to harmful substances.

It’s not just the chemicals in period products that can affect health but also the materials they are made from. Rayon, used widely in period products such as SUD pads and tampons, can expose workers to carbon disulphide97 during processing and has been associated with an increased risk of miscarriage and menstrual disorders among women workers.98

IMPROVING THE REGULATION OF PERIOD PRODUCTS

In the UK, there are no specific regulations for period products: they are currently regulated under the General Products Safety Regulations 2005.99 The responsible department is the Office for Product Safety and Standards (OPSS), which is part of the Department for Business and Trade (DBT). There is no independent or transparent testing regime required for period products, which are not even mentioned in the regulations. Responsibility lies with the period product producer or manufacturer to ensure safety and the regulations state that “under normal or reasonably foreseeable conditions of use (the product) does not present any risk or only the minimum risk compatible with the product’s use, considered to be acceptable and consistent with a high level of protection of health and safety”.100 As testing for pesticides requires significant costs and potential changes in production methods if pesticide residues are found, menstrual product companies may be reluctant to carry these tests out voluntarily.

To fill this regulatory vacuum, the best we have are private certification bodies that companies use to demonstrate to consumers that their products have been tested and are ‘safe’ to use. We wanted to delve into the process that one particular certification body uses when it comes to testing for pesticide residues in period products, given the health risks that this report has discussed.

OEKO-TEX® is the biggest and most well-known certification body for textiles, and since 1992 its aim has been “to ensure textile products are harmless to human health”. It has multiple standards that companies are able to choose from, from OEKOTEX® ORGANIC COTTON to OEKO-TEX® LEATHER STANDARD. Many UK tampon brands use the OEKO-TEX® STANDARD 100 on their packaging, to demonstrate to consumers that their products have been tested for harmful chemicals.

OEKO-TEX® themselves describe the STANDARD 100 certification as “a label for textiles tested for harmful substances. It sets the benchmark for textile safety, from yarn to finished product. Every item bearing the STANDARD 100 label is certified as having passed safety tests for the presence of harmful substances.” Over 35,000 companies worldwide use OEKO-TEX® as certification. We wanted to investigate this standard, to see which pesticides they test for and at what levels. In other words, what OEKO-TEX® defines as ‘safe’ in terms of pesticide residues in textile products. It is important to note that our enquiries into the OEKO-TEX® standard only focussed on period products and our comments below are, therefore, restricted to this topic and not their certification of other textiles.

While the OEKO-TEX® standard can certainly provide some reassurance to users of period products concerned about chemical contamination, we also found a number of potential weaknesses within the standard. We met with OEKO-TEX® online on the 7th January 2025 to discuss our analysis of these potential weaknesses. In February 2025, we then sent OEKO-TEX® our analysis in writing and received a detailed response from them dated 7th Mar 2025. The key points of our analysis and their responses are both outlined in the text in the remainder of this section.

One of the key issues we discovered with the OEKOTEX® standard is the fact that period products are not treated as their own category of product when it comes to how they are tested for ‘safe’ levels of chemicals. Their STANDARD 100 categorises products under four categories or ‘classes’, which are described as follows:

“Textile articles can be OEKO-TEX® STANDARD 100 certified following 4 different Product Classes:

1. Product Class I: Babies and small children up to 3 years

2. Product Class II: Skin contact materials

3. Product Class III: Material without skin contact

4. Product Class IV: Home textiles” 101

From these Product Classes, there is no obvious one for period products to fall under, given that babies and children do not use them, and that products such as tampons are internal products so are not strictly covered by “skin contact” only. OEKO-TEX® confirmed that Product Class II is the minimum requirement for period products. However, many companies do choose to certify their period products under Class I, which offers more stringent checks.

This means that tampons are routinely being tested as if they pose the same risk as a t-shirt under Product Class II. Furthermore, testing to Product Class I may sound more rigorous, but period products are not used by babies and small children up to 3 years, so the comparison is not strictly relevant. While babies and small children have more sensitive and absorbent skin, and products such as nappies do involve skin contact, such products are not inserted into the body like tampons.

OEKO-TEX® responded to this critique to highlight that baby products often have significant mucous membrane contact, as babies tend to put objects in their mouths. They explained that this is why Product Class I considers more than just skin contact. While OEKO-TEX® acknowledged that absorption rates between vulvar and oral mucosa cannot be directly compared, they argued that the comparison is still relevant. They stated that, given Product Class I already accounts for such exposure, it is a “valid reference” and affirmed their belief that testing period products under Product Class I is sufficient. In fact, they said that the lack of a Product Class specifically for period products to them demonstrated that “…our Product Classes are safe enough for tampons, which shows that they are extra safe for normal apparel.”

As outlined above, companies are therefore able to choose whether to test period products under Product Class I or II. However, it is not immediately obvious to consumers which class has been selected unless they use the online ‘label check’ tool. OEKOTEX® explained that many period product producers do in fact choose to be certified under Product Class I due to the fact that the products are touching parts of the body with mucous membranes which, as this report has discussed, leads to a higher absorption of chemicals.

We asked OEKO-TEX® to clarify whether Product Class I looks at both oral and dermal absorption. Instead of taking absorption into account at all, they test for total chemical content within a product. This means that they extract all the contents for testing in the lab to measure the total chemical content within a product. They then compare the results to a set limit to ensure the chemical levels do not exceed the allowed threshold. They do not test on humans or animals, so it is not possible to test the absorption rate. They use the same testing methods for all the different Product Classes, but as the Product Class becomes more stringent the limits permitted are lowered. Product Class I takes into account the concept of oral absorption because babies are likely to put items in their mouths, but the safety limits are not tested against an oral absorption level. Therefore, given the higher rates of absorption of the genitalia, and especially the vulva, the way that OEKO-TEX® tests for ‘safe’ chemical levels does not seem entirely satisfactory. We maintain that the testing and safety assessment regimes for baby products and period products should be different. A baby doesn’t have a textile in its mouth for up to four hours at a time several times a day, and perhaps eight hours over night, as a tampon user does.

Furthermore, we looked at which pesticides OEKOTEX® test for. Page 52 of OEKO-TEX’s® brochure contains the full list of pesticides that the STANDARD 100 tests for by default, for all fibres.102 They test for 82 pesticides; however, there are around 300 pesticides used in cotton production globally.

We asked OEKO-TEX® why they did not test for more pesticide active substances, and how they selected the 82 that are tested for. They responded to say that they work with internal and external experts monitoring EU and US regulations and also consult with NGOs. They also said that they sometimes remove pesticides that they never find from the list and that they only test for 82 pesticides because they find that most “wash out”, usually after the initial treatment. However, when we asked how they know if the roughly 200 additional pesticides used in global cotton production “wash out” if they aren’t testing for them, a satisfactory answer wasn’t given.

When it comes to glyphosate, the OEKO-TEX® STANDARD 100 sets a limit of 5 milligrams per kilogram (mg/kg) across all Product Classes.103 This means that the traces we found in the box of tampons is far below the standard set so, according to OEKO-TEX®, is deemed ‘safe’. However, as discussed earlier in this report, from our own testing of tampons and analysis, we don’t believe that this level can be described as ‘safe’ given the higher absorption levels of chemicals through the vagina.

OEKO-TEX® responded to our analysis with their own calculations. They used the WHO’s safety level for glyphosate in drinking water (0.3 mg/kg) to compare the yearly uptake of glyphosate via drinking water to the one via tampons that contain 5mg/ kg of glyphosate. Assuming a worst-case scenario in which all of the glyphosate in the tampons was absorbed, they concluded that a user of period products would absorb 5.04 mg of glyphosate in a year, compared to 219 mg via drinking water (so 40 times less). However, our own calculations based on the previously mentioned ANSES study reveal quite different figures, with high users of period products (6 a day, 7 days of bleeding and 13 bleeds a year) exposed to a total of up to 163.8 mg per year.104 Based on these results, we believe that the issues raised in the report around exposure through vaginal mucosa, and the uptake directly into blood stream bypassing traditional pathways for detoxifying, still very much hold firm.

While there may be some disagreement on the exact method for calculating the health risk posed by the presence of glyphosate in tampons, there is certainly sufficient evidence to argue for the Precautionary Principle to be invoked. Preventing glyphosate from ending up in tampons is arguably a far easier job than stopping it from contaminating drinking water, and therefore a logical way to reduce our overall chemical exposure.

It is also worth noting that the level allowed for glyphosate is the same across all Product Classes. However, evidence points to the fact that the presence of glyphosate poses a greater potential risk to babies, children and young people. There is growing evidence that glyphosate exposure can lead to neurodevelopmental, kidney and liver problems and behavioural issues in children105, as well as birth defects.106

In summary, our key suggestions for OEKO-TEX® are the following:

* Create a separate Product Class specifically for period products. Ensure that the testing methods under this new Product Class take into account the fact that the absorption rate through the genitalia can pose more of a risk than dermal and oral absorption.

* Set residue limits for all chemicals in period products at the Limit of Detection (LoD).

* Expand the list of pesticides that are tested for to include all pesticides used in cotton and other textiles in the global supply chain, to ensure that the testing is not missing traces of harmful chemicals.

OEKO-TEX® has been open to hearing these suggestions and has said that some of these issues are already topics of internal conversations.

It is important to note that OEKO-TEX® is only one private company, and they are working within the technical parameters of laboratories (e.g. being restricted to test only to the limits of detection for each chemical). While it is important that private sector actors are applying the most rigorous chemical safety testing possible, it is ultimately the responsibility of the Government to ensure the safety of period products. Uk consumers are being let down with no way of ascertaining which chemicals may be contaminating menstrual products.

In fact, national regulation can be extremely helpful to private certification bodies such as OEKOTEX®, because it sets minimum safety, quality and performance standards for products which are developed and enforced by experts. This can provide a baseline that private certifiers can build on, adding credibility to the certification process and thus increasing consumer confidence that products are tested to the highest possible safety standards. A clear and robust regulatory framework for period products in the UK would also provide more support for enforcement of non-compliance of companies misusing or abusing certification systems, and could increase the possibility for innovation and competition for the most robust testing of chemical safety levels.

We must learn from experience that voluntary or non-legally binding initiatives are not enough. New standards to be proposed by the ISO (International Organization for Standardization) for menstrual products may provide the foundations for new regulations if, and only if, they address the health, environmental, and suitability aspects of period products.107 It is important to see national regulation and private certification bodies work in a way that complements each other for the benefit of consumer safety.

The UK Government must ensure that pesticide residues in tampons or any other type of menstrual product are eliminated as far as is possible to do so, and period products should be free from any pesticide residue above the minimum limit of detection (the lowest concentration of a substance that can be reliably detected in a sample). Taking the precautionary approach is vital to ensure that women, girls and those who menstruate are at the least risk possible when it comes to exposure to chemicals through period products.

National regulation is crucial to protect consumers. The Government should therefore introduce a widespread and randomised testing regime, taking into account the routes of exposure discussed in this report. A maximum residue limit for pesticides on period products must also be introduced, so that consumers do not need to solely rely on private sector bodies to provide this.

THE BEGINNING OF THE COTTON SUPPLY CHAIN

Cotton is a key ingredient of many period products, from tampons and pads to period underwear.

Cotton can be difficult to grow: yields can be decimated by severe weather such as droughts and flooding, and cotton is also particularly vulnerable to pest attacks. It is also one of the world’s most pesticide-intensive crops: cotton covers just 2.4% of the world’s cultivated land, but uses 4.7% of the world’s pesticides, and a staggering 10% of the world’s insecticides.108 According to the International Cotton Advisory Committee, cotton is second only to bananas in terms of the proportion of HHPs used.109

Most of the world’s cotton is produced through intensive farming methods; only around 1% of global cotton is grown organically, meaning that a multitude of pesticides are used on the majority of the world’s cotton crop.110

The global cotton export market is dominated by countries that include Brazil, the United States, China, Australia and India, all of which use HHPs that are banned in the UK and the EU. For example, paraquat has been banned in the UK and EU since 2007 because of its acute toxicity, but is still widely used as a weedkiller in the US. This is concerning, as due to the lack of transparency of the cotton supply chain in the context of period products, this means that some of these extremely toxic pesticides have the potential to appear in the final products.

Tampax, one of the world’s biggest period product companies, says: “The cotton used in Tampax products is supplied by a privately owned family company founded 116 years ago in the United States. The cotton produced is purified without chlorine and is natural, soft and absorbent” and the cotton is certified by OEKO-TEX®” 111 From 2019–2023, cotton produced in the United States used 42 million pounds (19,086 tonnes) of pesticides on 10.3 million acres (4,174,504 hectares) of cotton. This ranks conventional cotton as the crop with the most intensive pesticide use per land unit (4.1 pounds per acre/4.6 kilogram per hectare or kg/ha) of the nine field crops surveyed by the United States Department of Agriculture (USDA) during this time, including corn, soybeans, and wheat.112 This further demonstrates that industrialised cotton farming systems such as the US are intensely reliant

on pesticides that may remain in the period products that this cotton is used in.

When it comes to smallholder farmers, cotton farming is of marginal profitability. Some can earn less than two dollars a day from their cotton. What’s more, smallholder cotton farmers spend up to 60% of their annual income on pesticides.113

In addition, more toxic pesticides may be registered for use in cotton compared to food crops because of fewer concerns about pesticide residues in the harvested crop. Like food, however, period products containing pesticide residues arguably pose an equal risk in terms of human exposure. Cotton is grown in hotter regions where Personal Protective Equipment (PPE) can be, uncomfortable and impractical. In lower income countries, PPE is often too costly or simply unavailable to the majority of smallholder producers, so millions of cotton farmers worldwide are growing cotton using highly toxic pesticides with no protection. It is therefore not a surprise that so many suffer from occupational poisoning.114 This problem affects farmers and farm workers as well as their families. Families can be exposed when in fields or handling the sprayed crop. These toxic chemicals are frequently stored in the home and there are many incidents where children are harmed or killed due to accidental spills or ingestion of pesticides.

“In India, pesticides rank only next to road traffic accidents as the most common cause of death,” said Dr Ashish Bhalla, Professor of Internal Medicine and President of the AsiaPacific Association for Medical Informatics (APAMI).

There are countless horrifying stories from all over the world that involve pesticide poisoning. In Yavatmal, India, in 2017, approximately 800 agricultural workers were severely poisoned when spraying pesticides on cotton fields within a 12-week period. Tragically, over 20 of them died. A Public Eye investigation showed that the insecticide Polo was largely responsible.115 Polo contains the active agent “Diafenthiuron”, which has been banned in the EU and the UK for decades.116

Gender and occupational exposure

Women are particularly impacted by pesticide poisoning on smallholder farms across the global south. The following extract is from Environmental Sciences Europe 34(1), from Sep 2022:

“Pesticides that are suspected or possible endocrine disruptors or carcinogens, neurotoxicants, cholinesterase inhibitors, or other conditions are intensively used in smallholder as well as commercial farming in sub-Saharan Africa, where women have little protection. For example, endosulfan, which is proposed for cotton, has been widely used in smallholder farms in Ethiopia and Uganda, however this organochlorine insecticide is listed as a suspected endocrine disruptor. Williamson found serious ill health among 36 people as well as 37 fatalities in Benin, under poor spraying conditions of endosulfan. A report from Women in Europe for a Common Future shows that many women exposed to endosulfan reported illnesses, miscarriages and birth defects. Likewise, use of DDT has been associated with endocrine disruption, probable carcinogens, and the ability to cause defects in a developing fetus as this insecticide persists in the environment, accumulates in the food chain and persists in human fatty tissues.”-117

Pesticides such as DDT (dichlorodiphenyltrichloroethane), which was used on cotton before it was banned, can impact not only a woman’s adult daughters, but their grandchildren too. Researchers discovered that granddaughters of women who were exposed to DDT during pregnancy also suffer from significant health threats: breast cancer, higher rates of obesity and menstrual

There are many reasons why women may be at heightened exposure risk to pesticides on smallholder farms across the world. The following extract is from a 2007 report by the Environmental Justice Foundation:

“Pesticides are valuable, and are stored in the house. Farming communities live in basic housing, and few have lockable or isolated storage facilities. After use, the empty containers are generally reused. Typically, water is not readily accessible near the fields of the drier zones where cotton is grown, and few houses have running water or a nearby standpipe. Farmers and workers cannot immediately wash their hands or bodies splashed with pesticides. The task of washing out spray equipment and work clothing is generally assigned to women, who may need to use the same bowls as for washing, clothes, cooking or eating utensils, or possibly for food preparation.”-119

Globally, women make up 43% of the agricultural workforce. Meanwhile, in Sub-Saharan Africa - where most HHPs remain in use - women make up 60% of the agricultural workforce, this figure rising to almost 70% in South Asia. This figure is likely to be an underestimation, as subsistence farming, seasonal and unpaid work on family farms often goes unaccounted for and frequently involves women and girls. In Malaysia alone, it is estimated there are around 300,000 female plantation workers who mix and spray pesticides.120

Due to the different gendered roles in farming, women and girls are more likely to be involved in what is often perceived as less harmful agricultural work, such as weeding and harvesting.121 This type of work is viewed as ‘safe’ and not requiring Personal Protective Equipment (PPE), despite bringing female workers into close contact with flower farms, where women experience a higher frequency of poisoning symptoms than men that do the Studies also found more girls than boys reported exposure to pesticides washing spraying tanks in Vietnam.123 For this type of work, there is often little training or education given to women and girls on how to protect

Pesticide exposure also happens indirectly through household chores such as washing contaminated clothing and equipment or storing pesticides in the home. This can be compounded by the reuse of old pesticide containers, domestic pesticide usage or from spray drift from nearby fields, which also particularly affects women, with ingestion, inhalation and skin absorption all being routes of exposure.124

These horror stories of pesticide use in cotton bring home the fact that the beginning of the supply chain for many cotton-based period products is toxic. As we have seen, pesticides can be toxic to the many women and girls that grow, spray and harvest the cotton, or experience indirect exposure, as well as potentially harmful to the women, girls and those who menstruate that end up using them. The potential risk of harm at each stage of the supply chain due to pesticide use is unacceptable. But things can change, and are changing, although all too slowly.

There are large international initiatives such as the Better Cotton Initiative (BCI), which promotes sustainable cotton production that is better for the environment as well as for farmers’ livelihoods, and the Organic Cotton Accelerator (OCA), who work to expand the organic cotton supply chain. Pesticide Action Network UK (PAN UK) and PAN Ethiopia, with support from TRAID, have trained over 8,000 cotton farmers in southern Ethiopia, to grow cotton without the use of pesticides. Yields are roughly 30-50% higher now that these cotton farms are organic.

Alongside The Benin Organisation for the Promotion of Organic Farming (OBEPAB), PAN UK supports over 6,000 farmers in growing organic cotton and has helped these farmers to establish cotton cooperatives and to engage in local and national cotton forums. All organic cotton is sold to the Beninese government with a guaranteed premium (currently 20%). Of the participating farmers, 30% are women, which is three times the number in

conventional cotton farming in the region.

As PAN UK recently noted, ‘Most small farmers are motivated to move to organic cotton to avoid corruption in the conventional sector, health risks, debt, and by the prospect of receiving organic premiums as well as prompt cash payments. For women, the prime motivations for organic farming are improved family health, and their children are not at daily risk of fatal poisonings. Their food supply is also safer, and more plentiful.’ Women seem to benefit in particular from organic cotton production, particularly from the freedom to control their own incomes.125 126

The following three case studies from Benin, Brazil and India demonstrate that organic cotton farming can be seen as a microcosm for social change, and one that supports wider female empowerment alongside the reduction of chemicals in cotton farming that improves health outcomes, as well as profit.

These case studies come from Cotton At The Source, a project led by Cotton Diaries and A Growing Culture, in collaboration with journalists, storytellers and cotton farmer communities. We are very grateful to them and the growers featured for allowing us to amplify their story.127

CASE STUDY 1

Organic cotton farming in Benin128

With special thanks to:

Project Lead (OBEPAB): Simplice Davo Vodouhe

Journalist/Writer: Gamaï Léonce Davodoun

Agroecology Specialist: Oluwafèmi Kochoni

Photographer: Gbèmèho Elisé Fanou

“Organic cotton should also be a women’s affair,” says Alougba, an organic cotton farmer in Benin. Nearly half of the members of her cooperative, based in Lagbo village, are women. Some women cotton producers assist their husbands, while others cultivate their own cotton fields, along with organic food crops.

“Cotton farming is even more difficult for women. We cannot plough, and it takes a long time to find labourers,” Alphonsine insists. Despite these difficulties, in addition to small-scale trade and food crops, women’s cotton production reinforces their empowerment. With the income from cotton sale, they meet their own needs and contribute financially to the household. “I use the cotton money to finance my children’s education and support my husband in household expenses,” Philomène says proudly. She is the organiser of the Kpodji Kiki cooperative.

Still, limitations regarding women’s involvement in decision-making bodies are a challenge in Benin. It is a stubborn national reality. To get things moving, in 2019, amendments were made to the constitution and electoral code to increase women’s representation in parliament. Henceforth, of the total 109 seats in the National Assembly, a quota of 24 seats is dedicated exclusively to women, at the rate of one seat per electoral district. These new provisions were applied to the January 2023 legislative elections. These changes to improve representation at the political level have impacted wider gender equality in Benin, and this impact can be seen in the organic cotton farming sector.

In Aklampa, even before this national political reform, through awareness actions, OBEPAB – The Benin Organisation for the Promotion of Organic Farming – changed the dynamics in organic farmers’ associations. Women are now elected to cooperative leadership positions. Every cooperative with women among its members must elect at least one woman to its leadership board. In some cases, women are represented in both the board of directors and the oversight committee, while in other cases, they are represented in one of these bodies.

« Al Alougba, the president of a cooperative of organic cotton producers in Benin.

CASE STUDY 2

A model of agroecology in Brazil129

With special thanks to:

Project Lead (Diaconia): Fábio Santiago

Writer: Luiz Felipe Silva

Photojournalist: Fellipe Abreu

Instagram: @fellipeabreu_fotografia

The introduction of agroecology in the Brazilian semi-arid region reverses a trend that had prevailed for centuries. In the early 1990s, farmers tested the first agroecological models in the Ceará municipality of Tauá, under the guidance of the non-governmental organisation Esplar, which collaborated to sell the first harvest of agroecological cotton to Greenpeace.

Thirty years later, this programme would be reproduced in cities in all nine states within the Northeast region.

Most farmers turned their noses up at the novelty. The few who paid attention were viewed with mistrust. “We were called crazy,” Joana laughs. The “crazy ones” were a group of about 20 cotton farmers. Together, they founded the Associação Agroecológica do Pajeú (ASAP/PE) to facilitate participatory organic certification.

Cotton farmer Lucineide Cordeiro Marinho has slowly adopted agroecological practices. She recalls that she was introduced to the model of cotton in consortia back in 2013, when she decided to return for good from the city to live in the rural area where she was born. She faced resistance. “My father didn’t believe it would work. We always planted conventional, normal crops,” she says. Six years later, she made the decision to shift 100 per cent of her production to an agroecological model, and today has a field full of beans, sunflowers, and sesame, besides, of course, cotton. “And now he [her father] has given in,” Lucineide laughs. “And he sees that we can plant without burning and without using poison.”

Lucineide’s account is far from an isolated case. In most farms where agroecology is practised, the entry point is women’s courage to try something new. Today, more than 50 per cent of the association’s members are women. They’ve had to confront the resistance of men – not only to the novelty of agroecology, but also to the proposal of equal gender division in work, decision-making and compensation. “In the beginning, I didn’t see myself as a farmer, just as a helper for my husband”, Joana recalls. “After we started working in the consortium, we increased our household income, and I understood that I also had a right to that money”, she adds.

Attracting women to agroecology, empowering them and making them aware of their rights are some of the goals of the gender working groups that exist within the seven associations that make up the Cotton in Agroecological Consortia Project – Diaconia. And the numbers prove it: women occupy almost half (47 per cent) of the total number of decision-making positions, and are part of the fiscal council, coordination, ethics and evaluation commissions, and presidency. Six out of the seven groups are headed by women.

“Every purchase of a product with agroecological cotton is a vote on the change of our life,” Joana concludes.

« Lucineide Cordeiro Marinho, cotton farmer using agroecological growing methods in Brazil.

CASE STUDY 3

A move to bio-pesticides in India130

With special thanks to:

Project Lead (Srijan): Rajneesh Vishwakarma

Journalist/Writer: Prachi Pinglay-Plumber

Writer/Consultant: Jaideep Hardikar

Photographer: Apoorva Salkade

Instagram: @apoorva_salkade

In Marram village lives Sangeeta Kumre, 50, a diligent farmer belonging to the Gond tribe who owns just two acres with her husband Kannulal and is upbeat about a gradual transformation being scripted in her own village.

Oozing with confidence, mainly stemming from a great deal of training she’s undergone, Sangeeta’s fully-converted organic cotton farm has a kitchen or “nutrition garden”, a recent feature, which gives her family fresh food all year round, such as okra, chilli, greens, beans, fruit and maize. “I want to improve our health by eating good food,” she says. “I want to meet our household needs, so we are diversifying our crops – cotton and pulses and millets and vegetables. We use our own seeds,” she says buoyantly, “and we don’t use any chemicals.”

A mile away, off the road from their small but clean home is a shed, with a sign reading ‘Bio-Input Resource Centre (BRC)’. Here, Sangeeta and ten other neighbourhood women have come together as part of the Nav-Durga Women’s Self-Help Group to prepare the pach-patti-kadha – a bio-pesticide made with cow urine collected from their own cattle sheds, mixed with the foliage of five medicinal plants and some jaggery, to be sprayed on the farms to control insect-pests. The group stores the bio-pesticide and other organic products they prepare at the BRC. “We use it on our farms and sell it in one-litre bottles for 30 Rupees apiece,” Sangeeta says. A litre of this liquid emulsion dissolved in about ten litres of water is enough for an acre of land; it repels pests and improves soil health. Her group, she says, makes a decent income from selling this bio-pesticide, the demand for which is steadily growing among even the non-organic farmers.

Sangeeta is part of a growing number of cotton farmers joining a nascent but significant initiative in India’s Chhindwara district (within the state of Madhya Pradesh) – an initiative that creates a pathway for communities to gradually transition from market-dependent chemical agriculture to natural and organic practices. Hundreds of smallholder farmers here are bound by a common thread: cotton. Breaking away from the rampant use of chemicals on cotton monocultures, they are trying to switch to a combination of organic and modern methods to heal their farms and landscapes. In the process, they are finding the added benefits of cutting production costs, diversifying income sources, and steadily improving returns.

« Al Sangeeta Kumare practising organic cotton farming methods in Madhya Pradesh, India.

FULL RECOMMENDATIONS FOR THE UK GOVERNMENT

* Introduce robust Government testing of period products.

• In order to significantly reduce pesticide residues in period products, with the ultimate aim of making them residue-free, the UK must introduce a UK-wide testing regime for period products that is robust and transparent.

• Good examples of regulation and policy include New York State,131 Catalonia,132 Wales133 and Scotland.134 The Global Organic Textiles Standard is a good model to follow, which includes limit values for heavy metals, pesticides, PFAS and some endocrine disrupting chemicals.135 The European Eco label prohibits the use of many harmful chemicals found in period products but is a voluntary code of excellence.136

* Introduce a legal requirement for manufacturers to disclose the ingredients and additives in all period products. Currently, there is no

* Provide only certified organic single use disposables (SUDs) and additive-free period products as part of the free period products programme in schools.

• The UK Government’s scheme to provide free period products in schools must be commended. However, physiological factors can increase the vulnerability of women and children to harm from pesticide exposure. Therefore, given that more research is needed on the potential health impacts on girls and young people undergoing puberty from pesticide and chemical residues in period products, a precautionary approach should be taken. Only certified organic SUDs and additive-free products should be provided, until a testing programme is in place.

• Education around menstruation in schools is sadly inadequate. Young people of colour from faith groups feel the most excluded and underserved by formal education on menstruation. Compounded fear and stigma around menstruation means delays in seeking health care. We want to see a more intersectional 137 and inclusive138 approach to menstrual education that includes accurate and faith-informed menstrual education within schools and also community settings and other safe spaces.

* Provide access to safe, healthy and affordable period products, as this is a human rights and public health issue. Wen is calling for a Menstrual Health, Dignity and Sustainability Act – which calls for equal access to sustainable period products, improved menstrual education, independent testing, transparent product labelling and stronger regulations.139

• The Act should start from the premise that menstruation is a human rights and public health issue. It needs to address the health and waste impacts, period equity and dignity, education and regulation, and challenge existing stigma and taboos.

• The Women’s Health Commissioner’s remit should include chemicals and pesticides, to ensure that their impact on the health of women, girls and those who menstruate are considered in women’s health policy. This should be reflected in an updated Women’s Health Strategy. While the 2022 strategy mentioned menstruation, it does not mention period products and the chemicals that they may contain.

* Ensure a more joined-up approach between the Department for Health and Social Care and the Department for Environment, Food and Rural Affairs, to make sure that chemicals regulation is seen as both an environmental and health issue.

• Chemicals management including pesticide regulation must be seen as a human health concern, as well as an environmental one. We suggest that a special minister to represent the link between health and environment would be helpful in enacting a more joined-up approach. This idea has already been proposed by Breast Cancer UK.140

• The long-awaited UK chemicals strategy, committed to in the 25 year environment plan, should include a plan to address the gendered impacts of chemicals on women’s health, as well as a specific strategy to tackle the chemical pollution found in period products. While the government has recognised that there may be hazardous substances in period products, they have declined to make this a priority area in the UK REACH regulations.141

* Ensure that research into the health impacts of pesticides and other chemicals include genderdisaggregated data, and specifically consider the gendered and intersectional impacts of exposure.142

• To ensure that women do not continue to be at a disadvantage when it comes to being protected from chemicals, there must be more gender disaggregated data collected in order to understand the specific risks and inequalities facing women, girls and people who menstruate. This will strengthen the case for clearer public health policies when it comes to exposure to pesticides through period products.

Period Products: Calculating Daily Exposure Dose for AMPA (Glyphosate metabolite)

Low Exposure Child (11-14)

Low Exposure Adult

Notes on calculation:

C: concentration found in sample

W: weight of one tampon

F: frequency of use

T: transfer to skin

Abs: Fraction absorbed by skin/mucosa

BW: body weight

DED: daily exposure dose

From:

CONSO2016SA0108EN.pdf (anses.fr)

High Exposure Adult

DED = C x W x F x T x Abs

To go into more detail, the ANSES methodology follows a quantitative health risk assessment, to understand the health risks associated with a measured quantity of a toxic substance. This was carried out by calculating a daily exposure dose, following a dermal route of exposure via the vaginal mucosa. This calculation takes into account the quantity of chemical found in the product, the weight of the product, the frequency of use over one day, the transfer of the substance to the skin, the skin absorption level and an estimated average body weight. This daily exposure dose was then compared to toxicity reference values set by national governments and international institutions that define an agreed level of exposure over a given time without any appreciable health risk. Due to the limitations of toxicity reference values for exposure via vaginal mucosa or dermal routes, ANSES used oral

values.

2002

A TIMELINE OF TESTS ON PERIOD PRODUCTS FOR TOXIC CHEMICALS AND PESTICIDES, UPDATED

TO THE PRESENT DAY

2013 Nov Chem Fatale - potential health effects of toxic chemicals in feminine hygiene products WVE WVE (Women’s Voices for the Earth)

2014 Aug Always Pads Testing Results WVE WVE (Women’s Voices for the Earth)

2014 Nov Product test: tampons and sanitary napkins

TV Tudatos Vasarlok (Association of Conscious Customers)

2015 Jul All sanitary pads in Indonesia contain chlorine Indonesian Consumers Foundation (YLKI) Indonesian Consumers Foundation (YLKI)

2016 Mar The toxic residues in tampons

60 Million Consumers Magazine

60 Millions Consumers Magazine

2016 Oct Tampon, Our intimate enemy Dream Way Productions Audrey Gloaguen with the collaboration of Victoria Kopiloff

2016 Dec Chemische Substanzen in Hygieneartikeln

Swiss Federal Food and Veterinary Office (OSAV)

Swiss Federal Food and Veterinary Office (OSAV)

4 different always pads Styrene, chloromethane, chloroethane, chloroform, acetone, toluene.

4 brands of pads and 5 brands of tampons

9 brands of pads, 6 brands of panty liners for the presence of chorine

4 brands of pads, 4 brands of panty liners, and 5 brands of tampons

6 brands of tampons for plasticizer chemicals

8 brands of tampons, 8 brands of pads for dioxins, furans, polycyclic aromatic hydrocarbons, phthalates and pesticides

Phthalates, triclosan, parabens.

https://womensvoices.org/ menstrual-care-products/chem-fatale-report/ USA

https://womensvoices.org/menstrual-care-products/detox-the-box/ always-pads-testing-results/

https://tudatosvasarlo. hu/termekteszt-tamponok-es-egeszsegugyi-betetek-0/

Chlorine

Organochlorine and pyrethroid pesticides, glyphosate, dioxins and halogenated organic compounds,

Phthalates and other plasticizers

https://www.thejakartapost. com/news/2015/07/07/all-sanitary-pads-indonesia-contain-chlorine-ylki.html

https://bibliotheque.60millions-mag.com/detail/publication/ detail-top-right/561?issue_ id=113545&switch_toc=archives&addon=false

Tampon, our intimate enemyDream Way productions

USA

Hungary

Indonesia

France

2017 May Contamination and health risk of phthalate esters in marketed sanitary

M. Chai et al. China Environmental Science Pads

Dioxins, furans, naphthalene, anthracene, benzo(a)pyrene, chrysene, (No Suggestions) acid (AMPA).

Link to swiss doc in folder or https://www.blv.admin.ch/dam/blv/ de/dokumente/gebrauchsgegenstaende/publikationen-und-forschung/bericht-chem-substhyg-produkte.pdf.download. pdf/Bericht_Chemische-Substanzen-in-Hygieneartikeln_DE.pdf

France

Phthalates

https://www.researchgate.net/ publication/319312934_Contamination_and_health_risk_of_phthalate_esters_in_marketed_sanitary_ napkins_from_China

Switzerland

China

2017 Jul 22 Toxic Substances Found in Disposable Menstruation Pads on the Market Including carcinogenic substances, reproductive toxicants and skin irritants. Kim Man-goo of Kangwon National University for Korean Women’s Environmental Network (KWEN)

2017 Sep Testing of pads and panty liners sold in South Korea

Korea Food and Drug Administration (KFDA)

Korean Women’s Environmental Network (KWEN)

10 brands of pads for Volatile Organic Compounds (VOCs)

Styrene, tricholorethylene, benzene, toluene, heptane, hexane, and other VOCs

https://www.slideshare.net/slideshow/20170529/76445594

Korean Food and Drug Administration

2018 April What’s in your tampon? WVE WVE (Women’s Voices for the Earth)

641 pads and panty liners sold in South Korea for 10 different volatile organic compounds (in response to the significant public reaction to the KWEN report)

6 brands of tampons (4 conventional containing rayon and 2 organic cotton brands) for VOCs.

Carbon disulphide, methylene chloride, methyl ethyl ketone, ethyl acetate, xylene, heptane, hexane, toluene.

https://www.koreaherald.com/ article/1461304#:~:text=Preliminary%20results%20of%20a%20 study%20conducted%20by%20 the,potentially%20toxic%20chemicals%20only%20found%20in%20 trace%20amounts.

Carbon disulphide, methylene chloride, methyl ethyl ketone, ethyl acetate, xylene, heptane, hexane toluene.

https://womensvoices.org/menstrual-care-products/whats-in-yourtampon/

South Korea

2018 Jun Report 8/18: Survey of hazardous chemical substances in feminine hygiene products

Swedish Chemicals Agency (KEMI)

Swedish Chemicals Agency (KEMI)

7 brands of pads, 10 brands of panty liners, 10 brands of tampons and 8 brands of menstrual cups for a variety of chemicals of concern including pesticides, plasticizers, fragrances, siloxanes and other VOCs.

Formaldehyde, dibutyl phthalate, 1-ethyl-2-pyrrolidone, benzophenone, 1, 4butanediol diglycidyl ether, 2-ethyhexyl acrylate, sodium dodecylbenzene sulphonate, siloxanes (D4, D5, D6, D7, and D9).

https://www.kemi.se/en/ publications/reports/2018/ report-8-18-survey-of-hazardous-chemical-substances-in-feminine-hygiene-products

South Korea

2018 Jun Opinion: of the French Agency for Food, Environmental and Occupational Health & Safety on the safety of feminine hygiene products

French Agency for Food, Environmental and Occupational Health and Safety (Anses) French Agency for Food, Environmental and Occupational Health and Safety (Anses) Menstrual pads, panty liners, tampons and menstrual cups

2018 Aug Test: menstrual cups Danish Consumer Council (THINK) Danish Consumer Council (THINK)

2019 Jan Sanitary pads and diapers contain higher phthalate contents than those in common commercial plastic products

7 menstrual cups for phthalates, carcinogenic nitrosamines, heavy metals and chlorinated paraffins.

Chan Jin Park et al Reproductive Toxicology 11 pads sold in South Korea for phthalates and VOCs. Investigation sponsored by SEVEN TV.

Butylphenyl methylpropional, polycyclic aromatic hydrocarbons (PAHs), pesticides (glyphosate and its metabolite aminomethylphosphonic acid (AMPA), lindane, hexachlorobenzene), dioxins, furans, and Di-n-octyl phthalate (DnOP).

Polycyclic aromatic hydrocarbons (PAHs), naphthalene, diethyl phthalate, VOCs.

Toluene, xylene, methylene chloride, phthalates.

https://www.anses.fr/en/system/ files/CONSO2016SA0108EN.pdf

USA

https://taenk.dk/test/menstruationskopper

Sweden

France

Denmark

https://pubmed.ncbi.nlm.nih. gov/30659930/

South Korea

2019 Mar Period protection, not yet reassuring.

60 Million Consumers Magazine

60 Million Consumers Magazine

2019 Dec Occurrence and Distribution of Phthalates in Sanitary Napkins from Six Countries: Implications for Women’s Health

2020 Jan Sensitizing fragrances in absorbent hygiene products

2020 Jan Feminine Hygiene Products-A Neglected Source of Phthalate Exposure in Women

2020 Jan Phthalates, bisphenols, parabens, and triclocarban in feminine hygiene products from the United States and their implications for human exposure

Zhenwu Tang et al

7 brands of pads and 8 brands of tampons for pesticides, phthalates, dioxins and halogenated organic compounds.

Environmental Science and Technology Pads

Bart Desmedt et al Contact Dermatitis

Tampons, pads, panty liners

Glyphosate/AMPA, phthalates, dioxins and halogenated organic compounds.

https://bibliotheque.60millions-mag.com/detail/publication/ detail-top-right/561?issue_ id=97249&switch_toc=archives

Phthalates

Chong-Jing Gao et al

Chong-Jing Gao et al

Environmental Science and Technology pads (also douches, vulvar cleaning products)

Environment International pads, panty liners, tampons (also wipes, vaginal creams, vaginal sprays, and powders.

2020 Jan My Menstrual Underwear Has Toxic Chemicals in It Jessica Choy Sierra Magazine menstrual underwear

2020 Jan Monitoring of the Belgian market with regard to organic residues in tampons sanitary napkins - part 2 Target analyses

2020 April Volatile organic compounds in feminine hygiene products sold in the US market: A survey of products and health risks

2021 May Best (& Worst) Period Underwear & Period Panties Tested for Indications of PFAS

2022 Jul Wrapped in Secrecy: Toxic Chemicals in Menstrual Products

2022 Nov PFAS “Forever Chemicals” Inside Sanitary Pads & Incontinence Pads — Report 2022

2022 Oct Do Your Tampons Contain PFAS “Forever Chemicals?” They Might. –Report

2023 Aug We Had 44 Period and Incontinence Products Tested for Forever Chemicals. Many Were Contaminated.

Flemish Institute for Technological Research NV (VITO)

Health Food Chain Safety Environment Tampons and pads

Lin et al Environment International Pads

Fragrance allergens, (hexyl cinnamal, benzyl salicylate, limonene, linalool, citronellal, geraniol, hydroxycitronellal).

phthalates

Phthalates, parabens, bisphenols and triclocarban.

https://pubmed.ncbi.nlm.nih. gov/31694371/ Japan, South Korea, USA, UK, Australia, Germany

https://pubmed.ncbi.nlm.nih. gov/31951286/ Belgium

https://pubmed.ncbi.nlm.nih. gov/31859481/

China

https://pubmed.ncbi.nlm.nih. gov/31945693/ USA

PFAS, copper, zinc. https://www.sierraclub.org/sierra/ ask-ms-green/my-menstrual-underwear-has-toxic-chemicals-it

Phthalates, glyphosate, dioxins, furans, nonylphenol, methyl and chloromethylisothiazolinone

https://www.health.belgium.be/ en/report-organic-residues-tampons-sanitary-napkins

Phthalates, VOCs https://pmc.ncbi.nlm.nih.gov/ articles/PMC7958867/

USA

Belgium

reports/wrapped-in-secrecy-toxic-chemicals-in-menstrual-products

Pads, liners, incontinence products

https://www.mamavation.com/ beauty/pfas-forever-chemicals-sanitary-pads-incontinence-pads.html USA

https://www.mamavation.com/ beauty/pfas-tampons.html

New York TimesWirecutter

New York TimesWirecutter Tampons, menstrual cups, period underwear

https://www.nytimes.com/wirecutter/blog/forever-chemicals-in-period-incontinence-products/ USA

Year Month Research

2023 Aug Indicator of PFAS found in some — but not all — period products

Graham Peaslee et al

2023 Sep Chemicals in menstrual products: A systematic review

Joanna Marroquin et al

American Chemical Society 100 period productsincluding singleuse tampons and pads and their wrappers, period pants.

BJOG: An International Journal of Obstetrics and Gynaecology published

2023 Nov Some popular period pants contain unnecessarily high levels of silver, Which? warns

2024 Aug Tampons as a source of exposure to metal(loid)s

Which? And AltroConsumo Which? Magazine and AltroConsumo

Review of 15 papers over 10 reporting on testing of period products

PFAS and organic fluorine

Period underwear for chemicals of concern - Silver, Forever chemicals (PFCAs, PFOs and PFOAs), Chromium VI, Cadmium, lead, Arsenic

Shearston JA, et al Environment International Tampons

Phthalates, volatile organic compounds, parabens, environmental phenols, fragrance chemicals, dioxins and dioxin-like compounds were detected in menstrual products

Silver (used as an antimicrobial)

Link Country

https://www.acs.org/pressroom/ newsreleases/2023/Aug/indicatorof-pfas-found-in-some-but-not-allperiod-products.html https://www. youtube.com/watch?v=bmOTfSanVVQ&list=PL-qHxGvFeZV3ftwffkiRifq6E0CvXexwU&index=2 USA

https://pubmed.ncbi.nlm.nih. gov/37743685/ International

Heavy metals (arsenic, lead, barium, calcium, cadmium, cobalt, copper, iron, manganese, nickel, selenium, strontium, vanadium, zinc)

https://www.which.co.uk/ policy-and-insight/article/ some-popular-period-pants-contain-unnecessarily-high-levels-of-silver-which-warns-aFFwv6E0Sb8r

UK and Italy

https://www.sciencedirect. com/science/article/pii/ S0160412024004355?via%3Dihub USA

2024 Dec Analysis of single-use menstrual products from the Spanish market detect 19 substances associated with plastic that can compromise the health of women and future generations

Rezero Rezero Pads, tampons

Phthalates, Organophosphates ethers (OPEs), Alternative plasticizers to phthalates (NPPs) - to be defined.

https://www.rezero.cat/en/toxic-plastic-menstruals-products/ Spain

REFERENCES

1 Women’s Environmental Network. (2024). Environmenstrual factsheet 2024. https://www.wen.org.uk/wp-content/ uploads/Environmenstrual-Factsheet-2024.pptx-1.pdf

2 Bloem, Bastiaan R et al. (2023). The inadequacy of current pesticide regulations for protecting brain health: the case of glyphosate and Parkinson’s disease. ://doi.org/10.1016/ S2542-5196(23)00255-3

3 Women’s Environmental Network. Wen’s Menstrual Health, Dignity, and Sustainability Act. https://www.wen.org.uk/ wp-content/uploads/Wens-Menstrual-Health-Dignity-andSustainability-Act-.pdf

4 National Institute for Health Research. (2024, Feb 27). Inclusion now a key condition for NIHR funding. Retrieved from https://www.nihr.ac.uk/news/inclusion-now-keycondition-nihr-funding

5 NHS. Fertility in the menstrual cycle. https://www.nhs.uk/ conditions/periods/fertility-in-the-menstrual-cycle/

6 Houghton, Lauren C. (2024). Menstruation as the Next Vital Sign. https://jamanetwork.com/journals/jamanetworkopen/ fullarticle/2819142

7 Statista. Feminine hygiene - Worldwide. https://www.statista. com/outlook/cmo/tissue-hygiene-paper/feminine-hygiene/ worldwide

8 Mintel. UK intimate hygiene and sanitary protection market report 2024. https://store.mintel.com/report/uk-intimatehygiene-and-sanitary-protection-market-report

9 Transparency Market Research. Reusable and washable hygiene products market. https://www. transparencymarketresearch.com/reusable-washablehygiene-products-market.html

10 ActionAid UK. (2023, May 26). The cost of living in the UK: Period poverty has risen. https://www.actionaid.org.uk/ blog/2023/05/26/cost-living-uk-period-poverty-risen

11 Plan International UK. (2018). Break the barriers: Girls’ experiences of menstruation in the UK. https://plan-uk. org/file/plan-uk-break-the-barriers-report-032018pdf/ download?token=Fs-HYP3v

12 Bobel, C et al. (2020). The Palgrave Handbook of Critical Menstruation Studies https://doi.org/10.1007/978-981-150614-7

13 Tomlinson, Maria K. (2025). The Menstrual Movement in the Media: Reducing stigma and tackling social inequalities. :// doi.org/10.1007/978-3-031-72195-3

14 UK Clinical Research Collaboration. (2015). UKCRC health research analysis 2014. https://www.ukcrc.org/wp-content/ uploads/2015/08/UKCRCHealthResearchAnalysis2014-WEB.pdf

15 Devlin, H. (2019, Dec 18). ‘Women have been woefully neglected’: Does medical science have a gender problem? The Guardian. https://www.theguardian.com/education/2019/ dec/18/women-have-been-woefully-neglected-does-medicalscience-have-a-gender-problem

16 TAP Project. (2022). Black Women’s Reproductive Health. https://tapproject.co.uk/wp-content/uploads/2022/08/ a40c0490-2880-4ffc-b231-386415f0bd3f.pdf

17 TAP Project. (2022). Black Women’s Reproductive Health. https://tapproject.co.uk/black-women-reproductive-health/

18 Briancesco, R et al. (2018). A study on the microbial quality of sealed products for feminine hygiene https://doi.org/10.1002/ maq.31024

19 Women’s Voices for the Earth. (2021, May 10). How are menstrual and intimate care products regulated? https:// womensvoices.org/2021/05/10/how-are-menstrual-andintimate-care-products-regulated/

20 Pesticide Action Network UK. Impacts of pesticides on our health.www.pan-uk.org/health-effects-of-pesticides/

21 Lee, C. (2023, Feb 15). How pesticides impair our senses. . www.bbc.com/future/article/20230215-how-pesticides-harmhuman-health

22 Organic Trade Association. Get facts about organic cotton. https://ota.com/get-facts-about-organiccotton#:~:text=Organic%20cotton%20currently%20makes%20 up%20approximately%200.95%25%20of%20global%20cotton

23 PAN International. PAN HHP list. https://pan-international.org/ wp-content/uploads/PAN_HHP_List.pdf

24 We received the results back from Primoris Lab, Belgium on the 6th Aug 2024.

25 Health Service Executive. FAQ: Pesticides in drinking water. https://www.hse.ie/eng/health/hl/water/drinkingwater/faqpesticides.pdf

26 European Union. (2020). Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 Dec 2020 on the quality of water intended for human consumption. Official Journal of the European Union. https://eur-lex.europa.eu/eli/ dir/2020/2184/oj

27 Reuters. (2024, Dec 23). Mass tort litigation watch: 2025. https://www.reuters.com/legal/government/mass-tortlitigation-watch-2025-2024-12-23

28 French Agency for Food, Environmental and Occupational Health & Safety (ANSES). (2018). OPINION of the French Agency for Food, Environmental and Occupational Health & Safety on the safety of feminine hygiene products. https:// www.anses.fr/en/system/files/CONSO2016SA0108EN.pdf

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92 Acker, J et al. (2023). Neighborhood Racial and Economic Privilege and Timing of Pubertal Onset in Girls. https:// www.sciencedirect.com/science/article/abs/pii/ S1054139X2200708X

93 Wen (Women’s Environmental Network) and Women’s Voices for the Earth (2025). Timeline of Testing. https://docs.google. com/spreadsheets/d/1xSN7rxyrX7EckpyZOaZBis7Whc9VQ8 _G/edit?gid=1087552935#gid=1087552935

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95 Holdcroft, A et al. (2023). The Vaginal Microbiome in Health and Disease—What Role Do Common Intimate Hygiene Practices Play? https://pmc.ncbi.nlm.nih.gov/articles/ PMC9959050/

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97 Blanc, PD. (2017). Rayon, an Epidemic of Insanity, and the Woman Who Fought to Expose It. Undark. https://undark. org/2017/06/09/viscose-rayon-occupational-health/

98 Wong, EY et al. (2010). Dust and Chemical Exposures, and Miscarriage Risk Among Women Textile Workers in Shanghai, China. https://pmc.ncbi.nlm.nih.gov/articles/PMC2862777/

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100 UK Government. (2005). General product safety regulations 2005 (Great Britain). https://www.gov.uk/government/ publications/general-product-safety-regulations-2005/generalproduct-safety-regulations-2005-great-britain

101 OEKO-TEX®. OEKO-TEX® STANDARD 100 factsheet. https:// www.oeko-tex.com/fileadmin/user_upload/Marketing_ Materialien/STANDARD_100/Factsheet/STANDARD_100/ OEKO-TEX_STANDARD_100_Factsheet_EN.pdf

102 OEKO-TEX®. OEKO-TEX® STANDARD 100: Standard. https:// www.oeko-tex.com/importedmedia/downloadfiles/OEKOTEX_STANDARD_100_Standard_EN_DE.pdf

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105 PAN UK. Ending Pesticide Use in Schools. https://www.pan-uk.org/ site/wp-content/uploads/Ending-pesticide-use-in-schools.pdf

106 U.S. Right to Know. (2023, Feb 23). Glyphosate harms infants’ health in rural areas, new research suggests. https://usrtk.org/ healthwire/glyphosate-harms-infants-health-in-rural-areas/

107 ISO. Menstrual products. https://www.iso.org/ committee/8933440.html

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111 Tampax. What are Tampax tampons made of? https://tampax. co.uk/en-gb/tampon-truths/what-are-tampax-tampons-madeof/

112 The Organic Center. Pesticide, fertilizer, and genetic modification use in conventional cotton in the U.S. and globally. https://organic-center.org/pesticide-fertilizer-andgenetic-modification-use-conventional-cotton-us-and-globally

113 PAN UK. Pesticide concerns in cotton. https://www.pan-uk. org/cotton/

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115 Public Eye. (2017, Nov 6). A Syngenta pesticide produced in Switzerland is implicated in deadly poisonings in India. https:// www.publiceye.ch/en/media-corner/press-releases/detail/asyngenta-pesticide-produced-in-switzerland-is-implicated-indeadly-poisonings-in-india

116 Public Eye. (2017, Nov 6). Yavatmal poisonings: Syngenta’s pesticide far more heavily involved. https://www.publiceye. ch/en/topics/pesticides/yavatmal-poisonings-syngentaspesticide-far-more-heavily-involved

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120 Heinrich Böll Foundation. Pesticide atlas: Gender & pesticides. https://eu.boell.org/en/PesticideAtlas-gender

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PHOTO CREDITS

Cover JLco Julia Amaral/Shutterstock.

Modified from Woman contemplating the best sanitary choice to make

p 3 Nur Yilmaz/Pexels.

Modified from Cotton on White Background

p 4 WEN

p 5 WEN

p 7

Mark Stebnicki/Pexels.

Modified from Close-Up Shot of Cotton

p 8 WEN

p10 WEN

p12-13 WEN

p14 WEN

p15 WEN

p17

Rocketclips, Inc./Shutterstock.

Modifided from African American patient explaining issues to Asian doctor using tablet

p18-19 WEN

p21

Sabrina Janelle Gordon/Shutterstock.

Modified from Cotton silos in a field of cotton near Frost, Texas

p23 Canan YAŞAR/Pexels.

Modified from Woman Picking up Cotton on Field, Turkey

p24

EqualStock IN/Pexels.

Modified from Farmers in India, Nagpur, MH, India

p25 Gbèmèho Elisé Fanou

p26 Fellipe Abreu

p27

Apoorva Salkade

p28 WEN

p29 WEN

Natracare donated £5,000 to PAN UK in July 2023 and again in February 2025.  The decision to undertake this work was unconnected to the funding received and Natracare had no involvement in the scope of the work or the content of the report.

Women’s Environmental Network

We are an environmental charity working on issues that connect women, health, equity and environmental justice. We take an intersectional feminist approach to tackling the climate and nature emergencies.

We support women and communities to take action, amplifying racialised and marginalised women’s voices, and advocate for change. We cultivate grassroots projects, connect women to nature, create blueprints for just food systems and put gender and intersectional equality at the heart of the green economy.

We were the first charity to connect gender, health, equity and environmental justice. Since our radical beginnings in 1988, Wen’s groundbreaking campaigns have tackled issues from air pollution and plastic packaging to toxic chemicals in menstrual products and cosmetics.

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Telephone: 0207 481 9004

Email: info@wen.org.uk

Pesticide Action Network UK

PAN UK is the only UK charity focused on tackling the problems caused by pesticides and promoting safe and sustainable alternatives in agriculture, urban areas, homes and gardens. We work tirelessly to apply pressure to governments, regulators, policy makers, industry and retailers to reduce the impacts of harmful pesticides to both human health and the environment.

Our work includes campaigning for change in policy and practices at home and overseas, co-ordinating projects which help smallholder farming communities escape ill-health and poverty caused by pesticides, and contributing our wealth of scientific and technical expertise to the work of other organisations who share our aims.

www.pan-uk.org

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