Skincare Claim Checker
Paste a skincare title, bullet points or product description. The checker flags wording that turns a cosmetic into a drug, proof claims that need evidence, and "natural" or "non-toxic" claims, and names the FDA, FTC or Amazon rule behind each finding.
Free check: rule library only, first 3 findings shown. The text you check here is not saved.
What this checker flags
Drug claims on cosmetics
"Boosts collagen", "regenerates skin cells" and "hair regrowth". FDA names increasing collagen, regenerating cells and restoring hair growth as drug claims.
Skin-condition claims
"Treats acne", "cures acne" and "heals eczema". Acne medications are an FDA over-the-counter drug category, so a cosmetic cannot claim to treat acne.
Whitening and bleaching
Product terms such as "whitening cream" and "bleaching serum", and the ingredient hydroquinone. FDA lists increasing or decreasing melanin production in the skin as a drug claim.
Proof and authority claims
"Clinically proven", "dermatologist recommended" and "hypoallergenic", each of which needs evidence for the product and the specific claim.
Natural, clean and non-toxic
"All natural", "chemical-free", "non-toxic" and "clean beauty", flagged for review because each one needs a clear, supportable meaning.
Antibacterial wording
"Antibacterial" and "kills 99.9%" are marked for review on every platform. On Amazon listings, the hyphenated "anti-bacterial", a term Amazon's bullet point rules list, is marked must fix. FDA treats antibacterial cleansers as drugs.
Cosmetic or drug: intended use decides
Whether a product is a cosmetic or a drug under the law is determined by a product's intended use.
A cosmetic is for cleansing, beautifying, promoting attractiveness or altering the appearance. A drug is intended to affect the structure or any function of the body. FDA reads intended use from the claims on the label, in advertising and on the internet, so a product page counts. FDA's examples of drug claims made for "cosmetics" include restoring hair growth, reducing cellulite, treating varicose veins, increasing or decreasing melanin production, and regenerating cells.
if a product is intended, for example, to remove wrinkles or increase the skin’s production of collagen, it’s a drug or a medical device.
| Cosmetic wording | Drug wording | Source |
|---|---|---|
| Makes lines and wrinkles less noticeable by moisturizing the skin | Removes wrinkles; increases collagen production | FDA anti-aging page |
| Reduces the appearance of wrinkles | Eliminates wrinkles | Amazon cosmetics policy |
| Cleanses the skin | Antibacterial cleanser; cleanser intended to treat acne | FDA cosmetic or drug page |
Acne medications are an over-the-counter (OTC) drug monograph category. A product that claims to treat acne is a drug and must follow the monograph. Some products are both, such as a moisturizer with sun protection or an anti-dandruff shampoo, and must meet the rules for both. "Cosmeceutical" has no meaning in the FD&C Act. Amazon applies the same split: a product that is both a cosmetic and a drug must keep its claims within the applicable OTC monograph or approved new drug application.
FDA's examples do not include the word "repairs". In our reading, it depends on what is repaired: the look of dry skin is an appearance claim, while repairing damaged cells describes a change in the body.
"Clinically proven" needs the proof it claims
The FTC's 1984 Policy Statement Regarding Advertising Substantiation covers claims that state a level of proof, such as "tests prove", "doctors recommend" and "studies show". For those claims:
the Commission expects the firm to have at least the advertised level of substantiation.
The FTC applied this to skincare in 2014. It charged that L'Oréal made false and unsubstantiated claims that its Lancôme Génifique and L'Oréal Paris Youth Code products provided anti-aging benefits by targeting users' genes, including that Génifique was "clinically proven" to boost genes' activity. The proposed settlement was announced on June 30, 2014, and the FTC approved the final order on September 26, 2014. The order bars gene-related anti-aging claims unless they are backed by competent and reliable scientific evidence.
So if you say your claims are “clinically proven,” don’t be surprised when the FTC insists you live up to the standard you’ve set.
When a claim is health-related, the FTC's Health Products Compliance Guidance adds two points: anecdotal evidence about consumers' experiences, including consumer surveys, is never sufficient to substantiate claims about a health product's effects, and "clinically tested ingredient" implies that the test results prove a benefit. That guidance covers health-related claims; for appearance claims such as "looks smoother", the 1984 Policy Statement is the reference.
"All natural", "non-toxic" and free-from claims
In April 2016, four personal-care companies settled FTC charges that they claimed their products were "all natural" or "100% natural" although the products contained synthetic ingredients such as dimethicone and phenoxyethanol. The final orders, approved in July 2016, require competent and reliable evidence for any ingredient-related, environmental or health claim. In December 2016, the Commission ruled that California Naturel's "all natural" sunscreen claim was deceptive; the company admitted that 8% of the formula was dimethicone.
A non-toxic claim likely conveys that a product, package, or service is non-toxic both for humans and for the environment generally.
On Amazon, purity and free-from claims need proof or must come off the listing. Examples Amazon gives are "100% pure", "no artificial ingredients", "certified organic", "free-from" and "chemical-free". For natural or organic claims, Amazon accepts third-party certification; for other purity claims, a lab test report from an ISO-certified lab. Supplier statements alone are not enough. Amazon's cosmetics policy separately prohibits unverified health, therapeutic or purity claims.
"Clean" is not defined in the FDA and FTC sources cited on this page. If you use it, say what it means for your product, such as which ingredients are excluded, and make sure every product you label "clean" matches that definition.
Rewrite examples
Each rewrite describes how the product looks or feels in use instead of what it changes in the body. The rewritten lines return no rule match in the free check; the platform still makes the final decision.
Boosts collagen production for firmer skin
Helps skin look firmer and smoother
Why: FDA says a product intended to increase the skin's production of collagen is a drug or a medical device. The rewrite describes appearance only.
Eliminates wrinkles in 2 weeks
Reduces the appearance of fine lines and wrinkles
Why: Amazon's cosmetics policy gives this exact contrast: a cosmetic may claim to reduce the appearance of wrinkles but may not claim to eliminate them. A timeline would also need evidence.
Regenerates skin cells while you sleep
Moisturizes overnight so fine lines look less noticeable
Why: Regenerating cells is one of FDA's examples of a drug claim. FDA says a product that makes lines less noticeable simply by moisturizing is a cosmetic.
Clinically proven, all natural and non-toxic
Made with squalane, shea butter and jojoba oil
Why: "Clinically proven" requires clinical evidence for this product, "all natural" fails if the formula contains synthetic ingredients, and "non-toxic" implies safety for people and the environment. Naming real ingredients is specific and verifiable.
Antibacterial face wash that treats acne
Gentle foaming face wash that removes dirt and excess oil
Why: FDA treats antibacterial cleansers and cleansers intended to treat acne as drugs. If your product is a compliant OTC acne drug, its claims must follow the monograph instead.
MoCRA basics, and what this check does not cover
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) added duties that wording cannot satisfy. Facilities register with FDA and renew every two years. A responsible person lists each product with its ingredients, updates the listing annually, keeps safety substantiation records, and reports serious adverse events within 15 business days. Certain small businesses are exempt from registration and listing, except for products such as those that contact the eye's mucous membrane or are meant to last more than 24 hours. FDA does not issue certificates for facility registration, and its MoCRA page lists no final cosmetic GMP rule yet.
- Must fix findings are wording the rule library treats as a likely violation. Review findings depend on context or evidence, such as "clinically proven" when you hold a study for that product and that claim.
- The free check runs the rule library only and shows the first 3 findings. Some wording discussed on this page, such as "eliminates wrinkles", "100% pure" and "paraben-free", is not marked by the rule library, so review those claims yourself. The full check adds an AI context review for implied claims and a rewrite for each finding.
- Your formula. On Amazon listings, the rule library flags some prohibited ingredients and over-limit acid concentrations when they appear in the text, but it cannot see your formula or your MoCRA registration and listing.
- Images. In the e-commerce scenario, ByeRisk checks text. Image checks for listings are planned for a later stage. TikTok videos can be checked under the TikTok scenario.
The full check goes further
The free check above runs the rule library only. Create a free account for the full check; new accounts get 100 credits.
- AI context review: implied claims, missing disclosures and wording that rules alone cannot judge
- One-click rewrite of flagged wording, checked again before you use it
Frequently asked questions
Can a cosmetic be marketed as "anti-aging"?
It depends on what the claim says the product does. FDA says a product that makes lines and wrinkles less noticeable simply by moisturizing is a cosmetic, while one intended to remove wrinkles or increase collagen production is a drug or a medical device.
Can I say my serum is "clinically proven"?
Only if you have clinical evidence for that product and that specific claim. Under the FTC Policy Statement on substantiation, a claim that states a level of proof requires at least that level, and the FTC applied this to "clinically proven" skincare claims in its 2014 L'Oréal case.
Is "all natural" allowed on skincare?
Only if it is true. In 2016 the FTC settled with four personal-care companies whose "all natural" products contained synthetic ingredients such as dimethicone and phenoxyethanol, and ruled against California Naturel for the same kind of claim on a sunscreen.
Does Amazon require proof for "paraben-free" or "100% pure"?
Amazon treats purity and free-from claims as claims that need third-party certification or an ISO-certified lab test report, or must be removed. Supplier statements alone are not accepted.
Is an acne claim a cosmetic claim?
No. Acne medications are an FDA over-the-counter drug monograph category. A product that claims to treat acne is a drug and must follow the monograph; a cleanser that only removes oil and dirt makes a cosmetic claim.
Do I need an FDA certificate to sell cosmetics in the US?
FDA does not issue certificates for cosmetic facility registration. MoCRA requires facility registration and product listing, with an exemption for certain small businesses.
Sources
The official pages this page relies on. Policies change, so check the source before you act on it.
- FDAIs It a Cosmetic, a Drug, or Both? (Or Is It Soap?)
- FDAWrinkle Treatments and Other Anti-aging Products
- FDA"Cosmeceutical"
- FDAModernization of Cosmetics Regulation Act of 2022 (MoCRA)
- FDARegistration & Listing of Cosmetic Product Facilities and Products
- FTCFTC Policy Statement Regarding Advertising Substantiation
- FTCL’Oréal Settles FTC Charges Alleging Deceptive Advertising for Anti-Aging Cosmetics
- FTCFTC Approves Final Order Settling Charges that L’Oréal USA, Inc. Made Deceptive Advertising Claims for its Anti-Aging Cosmetics
- FTCFTC to L’Oréal: Scientific claims need proof that’s more than just skin deep
- FTCHealth Products Compliance Guidance
- FTCFour Companies Agree to Stop Falsely Promoting Their Personal-Care Products as “All Natural” or “100% Natural”; Fifth is Charged in Commission Complaint
- FTCFTC Approves Four Final Orders Barring Companies from Making False All-Natural Claims
- FTCFTC Rules California Naturel, Inc. Misled Consumers, Violated the FTC Act
- eCFR16 CFR 260.10 Non-toxic claims
- AmazonCosmetics, skin, and hair care
- AmazonMisleading claims categories and resolution
- AmazonProduct bullet point requirements
This page explains published rules for general information. It is not legal advice, and the platform or regulator makes the final decision.