Is 'Clean Beauty' Regulated? What the FDA Actually Requires

Is "Clean Beauty" Regulated? What the FDA Actually Requires

Short answer: no. There is no federal definition of "clean," "non-toxic," "green," or "pure" in cosmetics, and no government agency certifies a product as clean before it reaches a shelf. Any brand can put those words on a label.

Why "clean" has no legal meaning

The FDA regulates cosmetics, but its authority is narrower than most shoppers assume. Under the Federal Food, Drug, and Cosmetic Act, cosmetics do not need FDA approval before they go on sale. A brand can formulate a product, label it "clean," and ship it without anyone outside the company reviewing the ingredient list for safety first.

"Clean" is a marketing term, not a regulatory category. So is "non-toxic," "green," and "pure." Two products can both carry the word "clean" and contain completely different ingredients, including ones on Label Lookout's own avoid list, because nothing stops a brand from using the word.

What changed with MoCRA

In December 2022, Congress passed the Modernization of Cosmetics Regulation Act (MoCRA), the first major update to US cosmetics law since 1938. It gave the FDA some new tools:

• Cosmetics manufacturers must register their facilities with the FDA.
• Companies must submit a list of products and their ingredients.
• Brands must report serious adverse events linked to their products within 15 business days.
• The FDA is directed to eventually issue Good Manufacturing Practice (GMP) rules for the industry.

These are real, meaningful additions. Before MoCRA, the FDA did not even have a reliable list of what cosmetics companies existed or what they were selling.

What MoCRA still does not do

MoCRA does not require pre-market approval. No agency tests a formula for safety before it is sold. It does not define "clean," "non-toxic," "green," or "pure," and it does not require a brand to prove those claims before printing them on a bottle. Ingredient safety substantiation is still largely left to the manufacturer's own judgment, not an independent review.

In practice, this means the word "clean" on a label tells you about the brand's marketing, not about what is in the jar. It is a self-selected term the FDA neither grants nor polices.

What actually functions as a check

Because there is no legal referee, the closest things to independent verification come from third parties, not the government:

• Certifications like EWG Verified, Leaping Bunny, and USDA Organic each have their own published standards a product has to meet.
• Ingredient-level review, reading what is actually listed rather than trusting the front-of-package claim, is the only way to check a "clean" label yourself.

This is also why a published rubric matters more than a marketing word. When we evaluate a beauty product, we are checking the ingredient list against a fixed set of criteria, not taking "clean" at face value. A 10-free nail polish or a talc-free concealer earns a spot here because of what is confirmed absent from the formula, not because the brand called it clean.

The takeaway

"Clean beauty" is a real shift in what shoppers want, and MoCRA is a real (if limited) step toward oversight. But right now, no one in government defines or checks the word "clean" before it goes on a label. Skip the label term and look at the ingredient list, certifications, and whether a brand tells you what is actually in the product.