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Published March 10, 2025 — Monday
A Note from Tamara Rubin:

Consistent with our XRF testing and reporting of this product back in 2022, which is linked here (including the cease and desist letter from the company’s attorney that’s a full-on drama you might want to read in the order it’s published!), this tooth powder product  from Primal Life Organics tested positive for an INCREDIBLY HIGH amount of Lead (7,800 parts per billion). It also tested positive for an alarming amount of Arsenic. See the full test result summary in both the sharable social media graphic and full original lab report below (scroll down). The lab report is at the bottom of the article.

We have already made the FDA aware of this product’s test results (via email, earlier today) and will be filing a formal complaint with both the FDA and the State of Washington today as well. While this product is not technically illegal using current FDA standards for cosmetics, it is egregiously in violation of the State of Washington’s new (2025) Toxic-Free Cosmetics Act, which limits Lead in cosmetics to 1,000 parts per billion (ppb).

While all flavors of this product will likely test similarly (consistent with our previous XRF testing of products from this brand), test results for this flavor are also particularly alarming as it is a flavor obviously marketed for use by children (and understood by consumers to be safe for children’s use by the very nature of the packaging, associated images online, and “bubblegum flavor” — if not for an understanding based on more explicit marketing statements seen below). It is for this reason that we hope the FDA will be able to take action in demanding a high-profile, public recall for this product, even though it is not in violation of current standards limiting Lead levels in modern cosmetics.

• Federal cosmetics regulations limiting Lead content are not protective of human health.
• These regulatory standards were specifically only implemented to provide guidelines as protections for industry, limiting the cosmetics’ industry liability related to human harm (liability for consumer-exposure to toxicants that cosmetics’ industry lobbyists have long-asserted are “unavoidable” in cosmetics).
• These limits were set to only somewhat protect adults from higher levels of exposure, which is unfortunate given all modern research on the subject of Lead exposure has clearly demonstrated that lower levels of Lead exposure (levels previously thought to not cause harm) can lead to life-long negative health impacts — including heart disease, memory impairments/ cognitive decline, and reproductive disorders.
• To my knowledge, current federal cosmetics guidelines that set allowable Lead content limits were not ever evaluated as a means of  limiting potential toxicant exposure for children who might use cosmetic products that are not specifically sold and marketed as items intended for use by children.
• Said another way, the current federal cosmetic limits for Lead were drafted with the understanding that cosmetics are used by adults, not children. This regulatory standard does not appear to have given appropriate weight to the fact that toothpaste and tooth powder products are regulated as cosmetics and are a specific class of cosmetic product that is normally regularly used by children (regardless of the product’s marketing or branding).
• The current FDA Lead Limits related to cosmetic products also specifically do not take into account potential direct oral pathways for exposure to toxicants (as one would experience with toothpaste or tooth powders) and the impact of this type of exposure on children — especially for products like toothpaste and tooth powders that are typically used multiple times a day!

Please scroll down to take a look at the six images from the Amazon listing for this product. I find it particularly interesting that the “Important Information” section of the Amazon listing says “Keep out of reach of children,” and “If swallowed, seek medical help immediately.” This is also particularly alarming when paired with the additional following statements that can be found in these images:

1. “You and your entire family can enjoy brushing your teeth…”
2. “Choose from Sweet Spearmint, Bubblegum, Cinnamon, Peppermint, Spearmint, Sweet Peppermint, and Cool Orange that kids love!”
3. “This is an all-natural product made of the healthiest ingredients”
4. “Natural Ingredients…”
5. “Crafted with healthy ingredients that will make your mouth happy”
6. “Loved by both kids & adults”
7. “Made with safe ingredients”
8. “A magical powder…”
9. “High-quality organic ingredients”

I personally find it quite satisfying (from a scientific perspective, although tragic from a human-impact perspective) that the lab report for this product resulted in Lead levels that match the XRF testing we have previously performed on tooth powder products from this brand. This is reassuring — reinforcing the usefulness and accuracy of XRF technology as an acceptable screening tool when testing for Lead in certain materials/ substrates/ coatings, etc.

Again, please scroll down to see both the shareable social media graphic with the test results and the full original lab report for this product (the lab report is at the bottom of the article, as is the case with all our articles discussing and reporting the lab reports for each product). Our comparative chart for toothpaste and tooth powder products (including this product) is depicted in the image directly above. As you can see in that chart, this Primal Life Organics Dirty Mouth Tooth Powder in Bubblegum flavor is the most toxic tooth cleaning product we have tested to date.

• As always (to repeat what has become a bit of a mantra here at Lead Safe Mama, LLC), all federal agencies agree there is no safe level of Lead exposure for human beings (especially pregnant women and children).
• Serving size does not matter when we are talking about toxicants as potent and dangerous as Lead, Cadmium, and Mercury. (Manufacturers will ALWAYS try to emphasize the false perspective that the serving size is “so small” it does not cause harm!)
• Lead and other heavy metals bioaccumulate in the body over time — especially with persistent, chronic/ daily exposure.
• When a product positive for unsafe levels of toxicants (heavy metals) is used regularly, two or three times a day, for YEARS by the same individual (as many toothpastes are), the presence of toxicants in that product becomes a very real risk to the user.
• The fact that there is an oral ingestion pathway with toothpastes is also — of course — extra concerning (vs. other non-oral-use cosmetic products).

Please scroll to the bottom of the page to see the full original lab report for this product. For more context related to any of the levels on the chart below, please refer to our earlier toothpaste articles as well as this page, which will always have the most recent update of our comparative chart with test results for all of the toothpaste and tooth powder products we have tested to date (this is a good page to bookmark and check back on periodically)!

The levels of toxicants found in this toothpaste are 100% LEGAL by FEDERAL standards, but ILLEGAL by new 2025Washington State standards!

Fluoride-free toothpaste is classified by the FDA as a cosmetic product. Cosmetic products are legally allowed to have up to 10,000 parts per billion (ppb) Lead in them (10,000 ppb is the same as 10 ppm). The new (January 2025) Washington State Toxic-Free Cosmetic Act limits the amount of Lead in cosmetics to 1,000 ppb (1 ppm). So, the only two applicable total content standards for Lead (that are not serving size-based, given serving size-based standards are irrelevant when evaluating the concern for Lead exposure with any given product) result in this product being considered LEGAL by federal standards and ILLEGAL by Washington State standards.

Just because something is LEGAL does not mean it is ok, nor that it is actually safe for use by children or pregnant women. These regulatory standards were designed primarily to protect corporations from liability, not to protect human health (watch our documentary film linked here for more information). Even the new Washington State standard is not protective enough when it comes to oral ingestion pathways and the potential impact on children and women of childbearing age/ pregnant women.

In spite of the fact this product is LEGAL per current FDA regulatory standards, Lead Safe Mama, LLC  is working with the FDA by reporting these toothpaste toxicant levels (for all of the toothpaste and tooth powder testing we are doing) via their online complaint form. Our goal is that the FDA will take action with this new product-specific body of evidence and possibly propose new (much lower) toxicant thresholds/ limits for toothpaste — ESPECIALLY for toothpastes and tooth powder products marketed for use by young children or that may be used by women of childbearing age/ pregnant women.

If your child has been using this tooth powder (ANY tooth powder from this brand, in ANY flavor!) and you have concerns related to the potential health impacts from this product (and especially if your child has tested positive for low levels of Lead exposure and you have not been able to identify the exposure source prior to reading this article) you should stop using the product immediately and contact your doctor about the concern for toxicant exposure. (NOTE: We found this alternate product for young children that tested non-detect across the board.) 

Ask your doctor if they can order a blood Lead level test for your child immediately (today or tomorrow) — getting tested sooner is better since Lead has a short half-life in the blood and blood Lead levels will start dropping as soon as exposure stops. It is important to try to document the highest level of exposure both as a useful tool in helping to assess potential long-term medical impacts (and learning disabilities), but also if you are considering pursuing the manufacturer for liability related to impacts on your child’s health from using this product (more on that here). You can also file a report with the FDA, here.

I would NEVER allow my own children to use this product (nor any tooth cleaning product with bentonite clay — or any other kind of clay — as a primary ingredient) because any known/ identified sources of potential Lead exposure are a strict and firm “no” in our home.

If you are interested in knowing more about detox protocols to support your family’s health (in response to learning this new information about toothpaste toxicant concerns), please read this article first — here’s the link. Most detox protocols and potions sold are hoaxes (ineffective or even dangerous) that are a waste of money and can often result in additional Lead exposure for your family.

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The full lab report for this product is at the bottom of this article.

As far as safer choices for foods, supplements, and cosmetics go (including toothpastes), we have a few lists on our food and supplement testing landing page (linked here) that you may find helpful in making safer choices for your family. We even have one dedicated to safer snack choices here. You may also find this link helpful as it takes you to our most recently updated safer choices list of 50 lab-tested safer foods, cosmetics and supplements!

Here’s the link to our landing page with ALL of the lab reports for the independent, third-party, laboratory testing Lead Safe Mama, LLC has coordinated since March 2024 — this is also a good page to bookmark and check back on periodically (it is also always pinned at the top of the website’s Menu via the button graphic below, and the Menu can be found at the top of every page on this site).

Please check out our open/ not-yet-funded campaigns on GoFundMe if you would like to support some of our additional independent, crowd-funded, third-party laboratory testing. Thank you!

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For those new to the Lead Safe Mama website:

Tamara Rubin is a multiple-federal-award-winning independent advocate for childhood Lead poisoning prevention and consumer goods safety, and a documentary filmmaker. She is also a mother of Lead-poisoned children (two of her four sons were acutely Lead-poisoned in 2005).

• Tamara owns and runs Lead Safe Mama, LLC — a unique community collaborative woman-owned small business for childhood Lead poisoning prevention and consumer goods safety.
• Since July 2022, the work of Lead Safe Mama, LLC has been responsible for six product recalls (FDA and CPSC).
• All test results reported on this website are science-based, accurate, and replicable.
• Please check out our press page to see some of the news coverage of our work, linked here.

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This is an ad-free article.

Advertising and affiliate income help Lead Safe Mama, LLC cover the costs of the work we do here (independent consumer goods testing and childhood Lead poisoning prevention advocacy). We have removed ads from most of our more widely-read articles (and newly published articles, too — like this one!) to make them easier for you to read. In addition to supporting this work by starting any shopping you might be doing with a click on our affiliate links, if you would like to support the independent consumer goods testing and childhood Lead poisoning prevention advocacy of Lead Safe Mama, LLC by making a contribution (which will also help us keep our more widely-read articles ad-free), click here. Thank you!

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Are you interested in seeing MORE safer choices?

Below is an expanding list of products (foods, supplements, cosmetics, and personal care items) that tested “non-detect” for Lead, Mercury, Cadmium, and Arsenic with independent, third-party, community-funded laboratory testing coordinated by Lead Safe Mama, LLC (an Oregon-based small business with a unique community-collaborative business model and a focus on consumer goods safety and childhood Lead poisoning prevention). The product examples below clearly demonstrate that companies can manufacture safer choices (at least from the perspective of a concern for heavy metals contamination).
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The limits of detection (low-threshold of detection) for each of the metals tested are noted in the lab report for the specific product listed. To see the full original lab report for any of these products, type the brand name into the search bar at the top of any page on Lead Safe Mama dot com (and scroll down to the bottom of the related article). All our published lab reports are also linked here, on our lab testing landing page.
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Flavors (or specific variations) tested are noted, and other flavors of the same product (or other products from the same brand) have either not been tested or have been tested but did not yield similar results. Test results only apply to the specific products linked below.

Products on our “safer choices” list are retested periodically (annually or more frequently, as funding permits). If a product no longer tests clean, it is removed from the list.

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LIST UPDATED — June 4, 2025
Now at 68 products + 6 “bonus” options. Scroll down to see all 74 Lab-tested Safer Choices:

1. Baby Food — 1 — Little Spoon Kale, Carrot + Pear BabyBlends
2. Baby Food — 2 —Little Spoon Butternut Squash + Blueberry BabyBlends
3. Baby Food — 3 — Little Spoon Sweet Potato BabyBlends
4. Baby Food — 4 — Little Spoon Sweet Potato + Carrot BabyBlends
5. Baby Food — 5 — Little Spoon Banana + Pitaya BabyBlends
6. Beverage — 1 — Honest Kids Organic Appley Ever After Apple Juice Drink: https://amzn.to/4fjGhov
7. Beverage — 2 —  Olipop Grape Tonic: https://amzn.to/4cjFYZu
8. Breakfast Cereal — 1 — Nature’s Path Envirokidz Organic Panda Puffs: https://amzn.to/4fo1crf
9. Breakfast Cereal — 2 — Nature’s Path Envirokidz Organic Corn Puffs Gorilla Munch: https://amzn.to/3FHZCDO
10. Candy — 1 — Cavendish & Harvey Wild Berry Drops, not organic (Germany): https://amzn.to/3Z1Jxjr
11. NEW! Candy — 2 — Haribo Gummy Bears** (Made in Germany, Not USA Produced): https://amzn.to/3FCGVlu
12. Candy — 3 — Lindt White Chocolate Bar (Made in USA, New Hampshire): https://amzn.to/3OXkyIm
13. Coffee & Tea — 1 — Chameleon Handcrafted Organic Cold Brew Concentrate: https://amzn.to/3OcrH77
14. Coffee & Tea — 2 —Tao of Tea Organic Genmaicha (Tamara’s favorite, from Japan, sold by a Portland, Oregon-based company!): https://amzn.to/3Dp8Fsd
15. Coffee & Tea — 3 — Califia Farms Almond Latte Cold Brew (XX Espresso): https://amzn.to/4gTTGoJ
16. Coffee & Tea — 4 — Death Wish Organic Espresso Roast Ground Coffee (Multi-country origin, non-USA): https://amzn.to/3yo1eiL
17. Cosmetic— 1 — Babo Botanicals Sensitive Baby Lotion: https://amzn.to/3YmKxy1
18. Cosmetic — 2 — Kora Organics Noni Face Oil: https://amzn.to/43hy2XO
19. Dairy — 1 — (cheese) — Babybel Mini Original Snack Cheese: https://amzn.to/3ZY5noO
20. Dairy — 2 — (coffee creamer) —  Organic Valley Grassmilk Half and Half: https://amzn.to/4fHJIWT
21. Fruit Snack — 1 — (bar) — Pure Organic Layered Fruit Bars in Raspberry Lemonade Flavor: https://amzn.to/3XcFsIp
22. Fruit Snack — 2 — (bar) —Pure Organic Layered Fruit Bars in Strawberry Banana Flavor: https://amzn.to/3WQEekA
23. Fruit Snack — 3 — (pouch) — Costco’s Kirkland Organic Apple Sauce Pouch: https://amzn.to/4gOYpZ9
24. Fruit Snack — 4 — (pouch) — GoGo Squeez Organic Apple Sauce Pouch: https://amzn.to/3XhWYLe
25. Fruit Snack — 5 — (pouch) — Once Upon A Farm Dairy Free Fruit Smoothie Pouch in Strawberry Banana Swirl Flavor: https://amzn.to/3CPMbAw
26. Infant Formula — 1 — Bobbie Organic Gentle Infant Formula Milk-Based Powder with Iron (pink and white can): https://amzn.to/3YYb849 
27. Infant Formula — 2 — Bobbie Organic Infant Formula Milk-Based Powder with Iron (green and white can): https://amzn.to/3VOr4Vy
28. Infant Formula — 3 — Bobbie Grass-Fed Milk-Based Powder with Iron (green can): https://amzn.to/3ZlAaeJ
29. Infant Formula — 4 — ByHeart Infant Formula (USA-made, not organic): https://amzn.to/48DJjTb
    
30. Infant Formula — 5 — HiPP Bio Combiotik Infant Formula Powder, Stage 1 (imported)
31. Infant Formula — 6 — HiPP HA Stage PRE (0+ Months) Combiotic Formula  (imported)
32. Infant Formula — 7 — Holle Bio Goat Stage 2 Infant Formula (for 6-10 months, organic, European — Swiss/ German/ Austrian) is not available on Amazon, but the Stage 3 version of this product is (not yet tested, but will likely test similarly): https://amzn.to/3BVU7zI
33. Infant Formula — 8 — Kendamil Goat Infant Formula (not organic): This product may be available at Target (it is not available on Amazon)
34. Infant Formula — 9 — Kendamil Organic Follow-On Milk (European/ British Toddler Formula, for 6-12 months, Cow Milk): Not available on Amazon 
35. Infant Formula — 10 — Kendamil Whole Milk Infant Formula (from Europe, pink can, not organic), available at Target
36. Infant Formula — 11 — Kendamil Organic Infant Formula (Cow Milk): Not available on Amazon but may be available at Target
37. Ingredient — 1 — (baking flour) — Jovial Organic Einkorn Flour (Italy): https://amzn.to/3LIqxix 
38. Ingredient — 2 — (beans) — Jovial Organic Chickpeas, Product of Italy: https://amzn.to/4iRON1l
39. Ingredient — 3 — (vinegar) — Napa Valley Naturals Organic Red Wine Vinegar (California): https://amzn.to/4jWhHOg
40. Oil — 1 — (avocado) — Chosen Foods 100% Avocado Oil (not organic): https://amzn.to/3YDZSuv
41. Oil — 2 — (coconut) — Dr. Bronner’s Regenerative Organic Coconut Oil: https://amzn.to/40xwBmv
42. NEW! Oil — 3 —  (olive) — Bryan Johnson BluePrint Snake Oil Olive Oil** (not organic): https://amzn.to/4mMieUj
43. Oil — 4 — (perilla seed) —  Dr. Adorable’s Organic Perilla Seed Oil (Korea): https://amzn.to/3NDt7Yc
44. Plant-Based Milk — 1 — (coffee creamer) — Laird Superfood Coconut Creamer: https://amzn.to/4fItA7A
45. Plant-Based Milk — 2 — (plant milk) — Kiki Milk Organic Plant-Based Milk (original flavor): https://amzn.to/3AA6Qrt
46. Plant-Based Milk — 3 — (soy milk) — West Soy Unflavored Unsweetened Organic Soy Milk: https://amzn.to/4dwev8l
47. Salt — 1 — Jacobsen’s Sea Salt (Oregon, USA): https://amzn.to/4dcbk5L
48. NEW! Salt — 2 —Maldon Sea Salt Flakes**: https://amzn.to/4iTzWTE
49. NEW! Salt — 3 — Diamond Crystal Kosher Salt** : https://amzn.to/4cVQMiy
50. Seeds — 1 — (chia) —Navitas Organic, Gluten-Free Chia Seeds (Mexico): https://amzn.to/3YvE7xC
51. Seeds — 2 —  (hemp) — Costco Kirkland Organic Hemp Seeds: https://amzn.to/4e05RP9
52. Supplement — 1 — (adult) — Doctor’s Best Vitamin C with Q-C: https://amzn.to/4hlVvea
53. Supplement — 2 — (adult) —Nordic Naturals Omega-3 Fish Oil: https://amzn.to/48q1j2V
54. Supplement — 3 — (adult) — Pectasol Modified Citrus Pectin, Formulated in the USA: https://amzn.to/3QUmZfN
55. Supplement — 4 — (adult) — Pendulum Metabolic Daily Dietary Supplement: https://amzn.to/4gY5wOm
56. Supplement — 5 — (kids) —Baby Ddrops, Organic Vitamin D3 Supplement for Babies: https://amzn.to/49C3ktH
57. Supplement — 6 — (kids) — Mary Ruth’s Organic Toddler Multivitamin Liquid Drops with Iron: https://amzn.to/3YPhcgx
58. Supplement — 7 — (kids) —Mary Ruth’s Organic Toddler Elderberry Liquid Drops: https://amzn.to/42617TU
59. Supplement — 8  — (kids) — Nordic Naturals Kids Vitamin D3 Gummies (Ages 3+): https://amzn.to/4l7117a
60. Sweetener — 1 — (sugar) — Anthony’s Organic Granulated Cane Sugar: https://amzn.to/4jf6vLv
61. Sweetener — 2— (xylitol) — Espure Organic Xylitol: https://amzn.to/3GsCSrU
62. Sweetener — 3— (xylitol) —Now Real Food Granulated Xylitol: https://amzn.to/4cNWDpM
63. Toothpaste — 1 — Fluoride-free Orajel Kids Training Toothpaste in Natural Berry Fruity Flavor with Elmo Sesame Street Packaging: https://amzn.to/41wxtrY
64. Toothpaste — 2 — Fluoride-free Miessence Mint Toothpaste: https://amzn.to/4bJc4PO
65. Toothpaste — 3 — Dr. Brown’s Fluoride-free Baby Toothpaste in Strawberry Flavor: https://amzn.to/3DCehzZ
66. Toothpaste — 4 — Pegciz Kids Foam Toothpaste in Watermelon Flavor, Low Flouride (packaging varies, see report): https://amzn.to/3YzP68e
67. Toothpaste — 5 — Kid’s Spry Fluoride-free Tooth Gel with Xylitol in Original Flavor: https://amzn.to/41GZb4e
68. Toothpaste — 6 — Fluoride-free Essential Oxygen BR Certified Organic in Peppermint Flavor: https://amzn.to/4lARZ2J

**Lab reports pending/ Not yet published as of 6/4/2025

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Here’s a link to our landing page featuring all the third-party lab reports for the foods, supplements, and cosmetic products we have published to date, including those listed above: https://tamararubin.com/2024/05/food-articles/

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Stand by for more!

BONUS: Below are SIX additional products that each tested positive for trace (very low levels of) Arsenic — at levels considered safe by all standards (with the limits of detection noted in the lab report for the specific product listed).

1. Infant Formula — Kendamil Goat Toddler Milk, not organic (positive for traces of Arsenic): May be available at Target or through other online retailers of European infant formulas
2. Ingredient — Maseca Instant Corn Masa Flour, Product of Mexico (positive for traces of Arsenic):  https://amzn.to/4iR8qWN
3. Fruit Snack —  That’s It Apple Cherry Bars, not organic (positive for traces of Arsenic): https://amzn.to/4fHkSWV
4. Oil — Chosen Foods 100% Pure Avocado oil, organic (postive for traces of Arsenic): https://amzn.to/3BVQYQa
5. Supplement — (adult) —  Now Sunflower Lecithin, not organic (positive for traces of Arsenic): https://amzn.to/3AFdHzO
6. Supplement — (adult) —  WishGarden Immune Boost Seasonal Rescue for Pregnancy: https://amzn.to/3Cd940N

Amazon links are affiliate links. 

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Amazon links are affiliate links. If you purchase something after clicking on a Lead Safe Mama, LLC Amazon affiliate link, Lead Safe Mama, LLC may receive a percentage of what you spend, at no extra cost to you.

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Lab report for the product pictured above: