In the world of cosmetics, labeling plays a crucial role in communicating a product’s benefits to consumers. Claims such as “Cruelty-Free” and “Alcohol-Free” are commonly seen on product labels. However, many people wonder whether these claims are regulated by the FDA. In this article, UCC will explain the essentials of cosmetics labeling claims and provide guidance on what they mean.

1. Overview
1.1. Definition of Cosmetics Labeling Claims
Cosmetics labeling claims are statements, images, or symbols that brands use to describe a product’s attributes. These claims play a crucial role in marketing and are frequently found on product labels, advertisements, websites, and in magazines. For example, labels may include statements such as:
- “Paraben-free, safe for sensitive skin”
- “100% natural, cruelty-free”

1.2. FDA Regulations on Cosmetics Labeling Claims
The law does not require FDA approval before cosmetic products hit the market. Furthermore, the FDA does not maintain a list of accepted cosmetic claims. However, the claims on cosmetic labels must be truthful and non-deceptive. If a product claims to treat a disease or alter the body’s structure or function, it will be classified as a drug. In that case, it must meet the FDA’s drug requirements.
Although the FDA does not pre-approve cosmetic claims, the agency monitors the market and can take legal action against companies that violate regulations. For example, FDA has issued warning letters to firms making unapproved drug claims on products marketed as cosmetics.
2. Common Cosmetics Labeling Claims
Several common claims appear on cosmetic product labels. Specifically, these claims include:
- Alcohol-Free: The product does not contain ethyl alcohol, making it suitable for people with sensitive skin or those who prefer alcohol-free formulas.
- Aromatherapy: Products with this claim often contain essential oils or fragrances that promote relaxation and reduce stress.
- Cosmeceuticals: These products combine aesthetic and therapeutic benefits, often marketed for anti-aging or skin improvement.
- Cruelty-Free/Not Tested on Animals: Products with these claims are not tested on animals, appealing to consumers who prioritize ethical choices.
- Hypoallergenic: Manufacturers formulate these products to reduce the likelihood of causing allergic reactions, making them suitable for sensitive skin.
- Organic: Manufacturers make these products from ingredients grown without pesticides or synthetic fertilizers, appealing to environmentally conscious consumers.

3. Detailed Explanation of Some Cosmetics Labeling Claims
3.1. Alcohol-Free Claim
Many consumers choose alcohol-free products believing that ethyl alcohol dries out the skin or hair. However, alcohol refers to a large family of chemicals. Not all alcohols have the same drying effect. For example, cetyl alcohol and stearyl alcohol are fatty alcohols that do not dry out the skin as ethyl alcohol does.
To prevent people from illegally consuming ethyl alcohol as a beverage, manufacturers may “denature” it by adding an additive that makes it undrinkable. Consequently, they may label denatured alcohol as “SD Alcohol” or “Alcohol Denat.” depending on the formulation.

3.2. Cruelty-Free/Not Tested on Animals
Some cosmetic brands use the claim “Cruelty-Free” or “Not Tested on Animals” on their labels. However, these terms do not have clear legal definitions, so companies can use them freely. Some companies may apply this cosmetics labeling claims to finished products, while still relying on raw material suppliers or laboratories to conduct animal testing for safety. Additionally, many companies base their “cruelty-free” claim on the fact that raw materials, which were initially tested on animals, are no longer tested on animals.

3.3. Hypoallergenic Claim
There are no federal standards or definitions for the term “hypoallergenic.” Therefore, this term can mean different things depending on the manufacturer. Moreover, companies that label their products as hypoallergenic do not need to provide FDA proof of their claims. While this claim holds marketing value, dermatologists argue that it has little scientific meaning and does not guarantee that the product will not cause allergic reactions.

Understanding cosmetics labeling claims is crucial for consumers to make well-informed decisions. While these claims are commonly utilized to promote products, it is imperative that they are truthful and comply with established regulatory standards. Should you have any further inquiries regarding FDA regulations or require assistance with your product’s labeling, we invite you to contact UCC for professional guidance and support.
For more information: Nutrient Content Claim: Understanding FDA Standards
