Compliance Hub / FTC
Marketing law
Advertising & Claim Safety
A cosmetic cleanses, beautifies or changes appearance. The moment your wording says the product treats, prevents or changes how the body works, it becomes an unapproved drug in the eyes of the FDA — and a deceptive claim in the eyes of the FTC. One word can move you across that line.
Claim matrix
Search a phrase you were planning to use.
Avoid
Cures hyperpigmentation
Use instead
Helps visibly even the look of uneven tone
"Cures" states the product changes a disease state, which makes it an unapproved drug.
Avoid
Heals eczema / psoriasis
Use instead
Soothes the feel of dry, tight skin
Naming a diagnosed condition and claiming to heal it is a drug claim.
Avoid
Reverses alopecia / regrows hair
Use instead
Supports scalp comfort and helps reduce breakage
Hair regrowth claims put the product in the drug category (like minoxidil).
Avoid
Anti-inflammatory
Use instead
Helps calm the look of visible redness
Inflammation is a physiological process; treating it is a drug function.
Avoid
Blocks UV / prevents skin cancer
Use instead
Only labeled as sunscreen with an approved SPF filer and full OTC drug labeling
Sunscreens are regulated as OTC drugs in the US, not cosmetics.
Avoid
Penetrates to rebuild the dermis
Use instead
Conditions the surface and improves the feel of skin
Claiming structural change below the surface is a drug claim.
Avoid
Kills acne bacteria
Use instead
Helps cleanse skin prone to congestion
Antibacterial/acne treatment claims require OTC drug monograph compliance.
Avoid
Chemical-free
Use instead
Made without sulfates, parabens or synthetic fragrance
Everything is a chemical; the FTC treats this as deceptive puffery.
Avoid
100% natural (with synthetic preservative)
Use instead
Naturally derived, with a globally approved preservative for safety
The FTC requires natural claims to be literally true and substantiated.
Avoid
Hypoallergenic (untested)
Use instead
Formulated without the EU 26 declared fragrance allergens
The FDA does not define hypoallergenic; you must be able to back it up.
Avoid
Dermatologist approved (no testing)
Use instead
Reviewed by a licensed dermatologist (keep the record on file)
Endorsement claims must reflect a real, documented relationship.
Avoid
Clinically proven (no study)
Use instead
In a 20-person consumer use study, 18 reported softer skin after 4 weeks
"Clinically proven" requires competent and reliable scientific evidence.
Advertising, reviews and disclosures
Substantiate before you publish
You need the evidence in hand before the claim goes live — not after a complaint. Keep the study, the supplier data or the consumer panel results in your file.
Influencer and gifted-product disclosure
Any material connection must be disclosed clearly and up front — in the caption before the "more" cut, spoken in video and burned into the on-screen text. "#ad" or "paid partnership" works; "#sp", "collab" or a buried tag does not.
Your own employees and family count
Reviews from staff, founders or relatives must disclose the connection, including on retail sites and app stores.
Never suppress negative reviews
Hiding, deleting or filtering out honest negative reviews while publishing positive ones is prohibited. So are fake reviews and bought followers.
Testimonials must reflect typical results
If most customers will not get the pictured result, the ad must say what the typical result actually is. A generic disclaimer is not enough.
"Made in USA" is a strict standard
An unqualified claim requires the product be all or virtually all made in the United States. Imported shea, essential oils or packaging usually means you need a qualified claim such as "Made in USA with imported botanicals".
Before-and-after images
Same lighting, same angle, no filters, no retouching, no makeup change. State the time between the two photos.
Price and subscription clarity
Show the full price including any recurring charge, the renewal frequency and an easy way to cancel before you take payment.
Educational reference, not legal advice. Have an attorney review claims before a national campaign or retail launch.