Warning checklist
What Not to Claim on Cosmetic Labels
Your label, product listing, image text, social captions, and seller-written FAQs can all create claim questions. Review the public promise before you print or publish.
Quick answer: FDA says cosmetic labeling claims must be truthful and not misleading, and claims about treating or preventing disease or affecting the structure or function of the body can make a product a drug under the law. Small sellers should flag medical, therapeutic, SPF, antibacterial, pain, infection, acne, eczema, and healing claims for professional review.
Acne, eczema, psoriasis, infection, rash, cold sores, or fungal language.
Repairs skin barrier, stimulates collagen, changes inflammation, or alters function.
SPF, sunscreen, antibacterial, antimicrobial, germ-killing, or infection prevention.
FDA approved, certified, guaranteed compliant, or medically proven without review.
Where to review claims
- Product label, box, insert, and directions.
- Etsy, Shopify, Amazon, or marketplace title and description.
- Image text, badges, before-and-after captions, and alt text.
- Social posts, ads, email marketing, and customer support scripts.
- Seller-written FAQ answers and review replies.
Examples to move into review
| Claim | Why to flag it | Tracker note |
|---|---|---|
| Heals eczema | Disease-treatment language | Professional review needed |
| Antibacterial soap | Germ-killing or disease-prevention implication | Drug-like claim flag |
| SPF lip balm | Sunscreen claim | Escalate before sale |
| Reduces inflammation | Body-function language | Claims review needed |
| FDA approved formula | Cosmetics are generally not FDA premarket approved, except color additives | Remove or review |
Safer workflow
- Copy every public-facing claim into a label and claims review sheet.
- Highlight disease, structure/function, SPF, antibacterial, pain, infection, and approval language.
- Separate ordinary cosmetic benefit language from claims that need professional review.
- Save the exact label version and listing URL that was reviewed.
- Do not rely on competitor labels as proof that a claim is allowed.
FAQ
Can cosmetic labels be FDA approved?
FDA says cosmetic labeling is generally not subject to premarket approval, although color additives have separate approval requirements. Avoid language that suggests FDA has approved the product or label.
Do online listings count?
They can matter because they shape intended use and consumer expectations. Review marketplace copy alongside the physical label.
Is "natural" enough to make a claim safe?
No. FDA notes that the same safety and labeling responsibilities apply regardless of whether ingredients are plant, animal, mineral, or synthetic.