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The Small Print on Cosmetics, Explained

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Cosmetics sold in the US do not need approval from the Food and Drug Administration before they reach the shelf. Colour additives are the main exception. That leaves the package as the best evidence most shoppers have, and it mixes two kinds of text: details the law requires, and marketing the law mostly leaves alone. Taking the package front to back, here is what each part can and cannot tell you.

The front panel

Only two things here are required: a statement of identity saying what the product is ("facial moisturiser", "shampoo") and the net quantity of contents. Everything else on the front is the brand talking.

Claims and slogans

The words that sound most reassuring tend to be the least regulated.

  • "Clean", "non-toxic" and "natural" have no legal definition for US cosmetics. Each brand or retailer writes its own rules, usually a list of ingredients it excludes, so two "clean" products can follow entirely different lists. The Federal Trade Commission can act against deceptive advertising, and in 2016 it settled with several companies over "all natural" claims on products containing synthetic ingredients, but there is no approved meaning to check a label against.
  • "Hypoallergenic" has no binding definition either. The FDA tried to set one in the 1970s, and a federal appeals court struck it down in 1977 after cosmetics makers challenged it. A hypoallergenic product can still cause a reaction.
  • "Dermatologist tested" means a dermatologist took part in some test. It says nothing about how many people, for how long, or what happened.
  • "Organic" is the partial exception. Products with the USDA Organic seal must meet the US Department of Agriculture's National Organic Program standards for their agricultural ingredients. The word alone, without the seal, carries much less weight.

The Drug Facts box

Sunscreens, antiperspirants, antidandruff shampoos and acne washes with benzoyl peroxide or salicylic acid are over-the-counter drugs in the US, so they carry a standard Drug Facts panel listing each active ingredient with its percentage, followed by uses, warnings, directions and inactive ingredients. A product that claims to treat acne or prevent sunburn without that panel deserves a second look.

The ingredient list

Ingredients appear under standardised names, usually the International Nomenclature of Cosmetic Ingredients (INCI), which is why a label says "aqua" and "tocopherol" rather than "water" and "vitamin E". Under US rules (21 CFR 701.3) the list runs in descending order of predominance, with one important exception: anything present at 1 percent or less can follow in any order, and colour additives can be grouped at the end. In practice the first five or so ingredients make up most of the formula. Once you reach the preservatives (phenoxyethanol is a common marker), you are usually in the under-1-percent zone, so an ingredient advertised on the front that sits below that point may be present only in a trace. Water at the top is normal; it is the base of most creams and lotions.

Colour additives often show up as numbers such as "CI 77891" (titanium dioxide) or "Red 40". Each must be approved by the FDA for its use in cosmetics.

"Fragrance" or "parfum"

US rules let a company list a whole blend of scent chemicals as the single word "fragrance" or "parfum", which keeps the formula a trade secret. For most people that does not matter. For people with a fragrance allergy it does, because fragrance is among the most common causes of allergic contact dermatitis. "Unscented" only means the product does not smell of much; it may still contain a masking fragrance. The reliable check is whether "fragrance", "parfum" or individual essential oils appear in the list.

The EU goes further and requires specific fragrance allergens to be named once they pass set thresholds, a list it expanded considerably in 2023. The Modernization of Cosmetics Regulation Act required the FDA to propose a similar US allergen-labelling rule, but the agency had not finalised one as of 2025, so most US labels still just say "fragrance".

The company name and contact details

Every label must name the manufacturer, packer or distributor and its place of business. The Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the largest change to US cosmetics law since 1938, added more behind that line. Companies must now:

  • register manufacturing facilities with the FDA and list each product with its ingredients;
  • report serious adverse events, such as hospitalisation or significant disfigurement, to the FDA within 15 business days;
  • keep records showing each product is adequately supported as safe;
  • print a US address, phone number or electronic contact through which consumers can report bad reactions.

MoCRA also gave the FDA power to order recalls and required it to set asbestos testing standards for talc-containing products. If a product causes a reaction, use the contact on the label, and report it yourself through the FDA's MedWatch system as well.

The base of the jar

  • Open-jar symbol. A small open jar marked "6M", "12M" or similar is the period-after-opening mark, showing how many months the product should stay good once opened. The EU requires it on products that last more than 30 months; in the US it is voluntary but common. US law does not require expiry dates on cosmetics, although sunscreens, as drugs, carry one unless testing shows they stay stable for at least three years.
  • Batch or lot code. A string of letters and numbers stamped on the base or crimp that identifies the production run. It matters if there is a recall or you report a reaction.
  • Certification logos. The FDA does not regulate animal-testing claims, and "not tested on animals" has no federal definition. Leaping Bunny, run by the Coalition for Consumer Information on Cosmetics, audits the supply chain; PETA's bunny logo is a separate programme with its own criteria. California began restricting sales of cosmetics developed with new animal testing in 2020, several states followed, and the EU has banned such sales since 2013.

"Made without" lists

Brands that advertise what they leave out often point to Europe. The EU Cosmetics Regulation (EC) No 1223/2009 prohibits well over a thousand substances, against roughly a dozen prohibited or restricted by FDA regulation. The gap is real but partly misleading, since many substances on the EU list were never used in cosmetics.

Parabens show how a reputation can outrun the evidence. A 2004 study that found parabens in breast tumour tissue drew wide attention, but it had no comparison group and showed no cause. In lab tests parabens act like a very weak oestrogen, thousands of times weaker than the body's own. The EU's scientific committee banned five little-studied parabens in 2014 for lack of safety data, kept the common ones, and set tighter limits on propylparaben and butylparaben. The FDA says it has no evidence that parabens as used in cosmetics harm health. Dropping well-studied preservatives has its own cost: replacements can be more allergenic, as methylisothiazolinone proved in the 2010s.

If you have a diagnosed allergy, the "made without" claim on the front is not enough. Search the full ingredient list for that exact INCI name every time you buy, including on repurchases, because brands sometimes reformulate while keeping the same name and packaging design, and the small print on the back is where the change shows up.