FDA Cosmetics Labeling: Rules for Online Sellers
Cosmetics sold in the United States must follow FDA labeling rules covering ingredient disclosure and the claims you may make. The most common compliance failures in online cosmetic listings are missing ingredient lists and claims that cross the line into drug territory. Disease and "FDA approved" claims are a leading cause of FDA warning letters, which can lead to product seizure, import refusal, and listing removal.
Claims that reclassify a product as a drug
FDA labeling rules govern the claims, disclosures, and ingredient information for cosmetics, dietary supplements, and food sold in the United States. The fastest way to draw a warning letter is a disease or treatment claim — wording such as "cures," "treats cancer," "prevents disease," or "lowers blood pressure" reclassifies the product as an unapproved drug.
Also avoid stating a product is "FDA approved." Cosmetics and dietary supplements are not approved by the FDA, so that wording is false. Use permitted structure/function language instead — for example, "supports joint health" rather than "treats arthritis."
Ingredient disclosure for cosmetics
Cosmetics should disclose a full ingredient list using INCI nomenclature, in descending order of predominance (FPLA / 21 CFR 701.3). For online sales, make that ingredient information available in the listing so consumers can review it before purchase.
Keep claims to cosmetic effects — cleansing, beautifying, altering appearance. The moment a claim implies the product affects the structure or function of the body or treats a condition (for example, "reduces wrinkles by rebuilding collagen"), it can be treated as an unapproved drug.
Frequently Asked Questions
Can I say my product is FDA approved?
No. The FDA does not approve cosmetics or dietary supplements, so an "FDA approved" claim on those products is false and a common trigger for enforcement.
What kinds of claims trigger FDA warning letters?
Disease and treatment claims — such as cures, treats, or prevents a named condition — are the leading cause. They reclassify the product as an unapproved new drug.
What are structure/function claims and are they allowed?
Structure/function claims describe how an ingredient affects normal body structure or function — for example, "supports joint health" or "helps maintain healthy skin." They are permitted for supplements and cosmetics provided they do not imply diagnosis, treatment, or prevention of disease and, for supplements, are accompanied by the DSHEA disclaimer.
Do I have to list cosmetic ingredients online?
Cosmetics must disclose a full ingredient list in INCI nomenclature, in descending order of predominance. Providing it in the online listing lets consumers review it before buying.
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