The Beginner’s Guide to FDA Cosmetic Claims

What New Beauty Brands Need to Know Before Launching

If you’re starting a beauty brand, it’s easy to get caught up in packaging, scent profiles, ingredients, and everything that makes your product feel exciting. But one thing many new founders miss is how the FDA views the claims you make.

At Freelance Formulations, we work with brands of every size, and one of the most common early mistakes is using the wrong language. Even a simple sentence can shift your product from “cosmetic” to “drug” in the eyes of the FDA.

Before you publish your product page or design your labels, here’s everything beginners should know about FDA cosmetic claims...

What the FDA Looks At

The FDA doesn’t regulate cosmetics the same way it regulates drugs. Its main focus is your language.

Your claims decide your product category.

Cosmetics are products that change appearance.  Drugs are products that treat or change the body.

That single difference affects everything from your labeling to how you market your brand.

What Counts as a Cosmetic Claim

Cosmetic claims stay in the lane of appearance, texture, and experience. These are safe, beginner-friendly examples:

• Hydrates the skin

• Helps skin look smoother

• Softens visible dryness

• Brightens the look of dull skin

• Reduces the appearance of fine lines

• Helps hair look thicker or fuller

• Improves the feel of texture

• Gently exfoliates the surface

These claims focus on what the consumer can see and feel, not what the product is doing on a biological level.

What Turns a Cosmetic Into a Drug

This is the part that trips up a lot of new beauty brands. If you make a claim that suggests your product is treating a condition or altering how the body works, the FDA considers it a drug.

These claims require scientific evidence, stability testing, and typically clinical trials.

Avoid claims that suggest your product:

• Treats acne

• Repairs the skin barrier

• Stimulates collagen

• Regenerates skin

• Reduces inflammation

• Kills bacteria

• Heals eczema, psoriasis, or dermatitis

• Lightens hyperpigmentation

• Boosts cell turnover

Even if your product uses powerful actives, the final wording must stay within cosmetic guidelines unless you plan on entering the drug category.

How To Reword Claims Safely

You can still communicate results without drifting into drug-claim territory. Here are some safer options:

Instead of: “Repairs the skin barrier” Try: “Helps skin feel more nourished and balanced”

Instead of: “Treats acne” Try: “Helps clarify the look of congested skin”

Instead of: “Stimulates collagen production” Try: “Helps skin look firmer and more supple”

It’s all about describing the visible result, not the internal mechanism.

Why FDA Cosmetic Claims Matter for New Brands

Understanding the difference between cosmetic and drug claims protects you from:

• Delays during manufacturing

• Costly label reprints

• Flagged marketing claims

• FDA warning letters

• Retail rejection

• Customer confusion

As beauty regulations continue expanding, staying compliant is becoming a core part of launching a successful product line.

If your brand plans to scale, secure investors, or enter major retailers, getting your claims right from day one makes everything smoother.

Need help understanding FDA claims or building a compliant beauty product?

Freelance Formulations works with founders, influencers, and established brands to develop custom formulas, guide regulatory decisions, and help ensure your product meets FDA cosmetic guidelines.

If you have questions about your claims, your ingredients, or whether your product is classified correctly, you can book a discovery call with our team.

We’ll walk you through your formula, claims, compliance, and next steps for development.

References:

“Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?)” https://www.fda.gov/cosmetics/cosmetics-laws-regulations/it-cosmetic-drug-or-both-or-it-soap

“Truth in Advertising” — Advertising and Marketing Basics

 https://www.ftc.gov/business-guidance/advertising-marketing