How to Shop Beauty Clean Products: A No-Nonsense Guide

The front of a skincare package is marketing. The back is the ingredient list, and in the United States that list follows federal labeling rules. Shopping for clean beauty products gets much easier once you learn to check every front-of-pack word against the back-of-pack ingredients. As a cosmetic formulator, that is exactly how I evaluate a product: I read the claim, then I read the INCI list, and I see whether they agree.

This page decodes the most common clean beauty marketing terms, tells you which ones have a legal definition and which do not, and shows you what to look for in the ingredient list to confirm or disprove each one. If you want product picks for firmer-looking skin, see our best clean beauty products for skin elasticity. For a line-by-line walkthrough of INCI names themselves, see our guide to how to read a skincare label INCI.

Front of Pack vs Back of Pack

The ingredient list is regulated. Under 21 CFR 701.3, cosmetic ingredients are declared in descending order of predominance. Ingredients present at more than 1% are listed first in descending order; ingredients at 1% or less may follow in any order; color additives may be listed last in any order. Fragrance and flavor can be declared simply as "fragrance" or "flavor" rather than listing every component, and an ingredient the FDA has accepted as a trade secret can be declared as "and other ingredients."

Most of the words on the front of the package are not regulated in the same way. That is the gap this page helps you close.

Which Clean Beauty Terms Have a Legal Definition?

"Clean"

I have not found any FDA or FTC definition of "clean" for cosmetics. In practice, "clean" means "free of the ingredients this brand or retailer chose to exclude," and those exclusion lists differ from company to company.

How to check it

1. Find the brand's or retailer's published list of excluded ingredients.
2. Read the INCI and confirm none of those ingredients are present.
3. Confirm the product still has a named preservative if it contains water. A water-based product without a preservative is a contamination risk, and that is not clean in any useful sense.

"Natural"

Neither the FDA nor the FTC has defined "natural" for cosmetics. A 2019 bill, the Natural Cosmetics Act, proposed a definition, but no federal definition is in place. A product can call itself natural and still be mostly water, emulsifiers and synthetic preservatives.

How to check it

• Look at the first five ingredients. They make up most of the formula.
• Identify the preservative. Brands marketing natural products often use potassium sorbate, sodium benzoate or silver dihydrogen citrate; many other products use phenoxyethanol. No preservative is automatically safer because of how it is marketed. What matters is that the product is properly preserved.
• Remember that "natural" says nothing about safety. Poison ivy is natural.

"Organic"

Organic is the one clean beauty term with real rules behind it, but only in a specific situation. According to the USDA, the FDA does not define or regulate "organic" for cosmetics. The USDA regulates the term only for products made with agricultural ingredients that seek organic certification under the National Organic Program. Percentages exclude water and salt.

How to check it

• If you see the USDA Organic seal, look for the certifying agent's name and address, which is required for sealed products.
• If there is no seal, look for "organic" next to individual ingredients in the INCI. That tells you which ingredients are organic, not that the product is.
• Products may also carry private or foreign organic standards, which the USDA does not regulate. Look up that standard's own rules.

Here is an example of ingredient-level organic labeling from our own Aloe Vera Gel Serum Base 4oz: "Deionized Water, Organic Aloe (Aloe Barbadensis Leaf Juice), Organic Gotu Kola (Centella Asiatica) Extract, Horsetail (Equisetum Arvense) Extract..." The aloe and gotu kola are organic; the horsetail is not labeled organic. That is the level of detail to look for.

"Hypoallergenic"

The FDA states plainly that there are no federal standards or definitions governing "hypoallergenic," and that the term means whatever a particular company wants it to mean. Manufacturers are not required to submit proof of a hypoallergenic claim to the FDA.

How to check it

• Scan the INCI for anything you already know you react to.
• Look for "fragrance," "parfum" and essential oils, which are common reasons people react to a product.
• Patch test every new product on the inner forearm for 24 to 48 hours, whatever the label says.

"Cruelty-Free" and "Not Tested on Animals"

The FDA says these terms have no legal definitions. It also explains how they can be used: a company may apply the claim only to its finished product while relying on raw material suppliers or contract labs for any animal testing, or may use only ingredients that were tested on animals in the past but are not currently tested.

How to check it

• Look for an independent certification with published criteria that cover ingredient suppliers, such as Leaping Bunny.
• Without a certification, ask the brand whether its claim covers raw materials or only the finished product.

"Fragrance-Free" vs "Unscented"

These are not the same thing. Because the ingredient list can say simply "fragrance," one word can stand for many components. A truly fragrance-free product should show no "fragrance," "parfum" or "aroma" on the INCI. Watch for essential oils, such as lavender oil or citrus peel oils, which add scent but are listed by their botanical names. "Unscented" usually means the product does not smell, which can still involve an ingredient added to mask the base odor.

"Free-From" Claims

"Paraben-free," "sulfate-free," "silicone-free" and similar claims are the easiest to verify because the ingredients have recognizable INCI names.

One caution: "preservative-free" on a water-based product is not a selling point. Water-based products need a preservative to stay free of microbial contamination once opened. Our guide to natural skin care preservatives explains the options.

A Five-Step Label Check You Can Do in the Store

1. Read the front claim. Write down the exact words: clean, natural, organic, hypoallergenic, free-from.
2. Flip to the INCI. If there is no complete ingredient list, put it back.
3. Check the first five ingredients. Do they match the story on the front? A "rosehip serum" should have rosehip oil near the top, not near the end.
4. Find the preservative. If the product contains water, a preservative should be named.
5. Verify any seal. USDA Organic should show the certifier. Cruelty-free seals should name the certifying organization.

Worked Example: Reading a Short INCI

Here is the full INCI of our Bakuchiol Serum Booster: Vegetable Glycerin, Water, Bakuchiol Extract, Silver Dihydrogen Citrate.

• Glycerin first: the carrier is glycerin, so it blends into water-based formulas.
• Water second: because there is water, a preservative is needed.
• Bakuchiol extract third: the active is present, carried in the glycerin and water.
• Silver dihydrogen citrate: that is the preservative.

Four ingredients, each with a clear job, and the claims on the product page, such as fragrance-free and paraben-free, can be confirmed directly from the list. That is the standard to hold every "clean" product to.

Frequently Asked Questions

Is "clean beauty" regulated by the FDA?

I have not found any FDA definition of "clean" for cosmetics. What the FDA does regulate is the ingredient list, which must follow 21 CFR 701.3. Use the ingredient list to judge any clean claim.

What is the difference between natural and organic skincare?

"Natural" has no FDA or FTC definition for cosmetics. "Organic" is regulated by the USDA when a product seeks organic certification: "organic" requires at least 95% organic ingredients, excluding water and salt, and "made with organic ingredients" requires at least 70%.

Does hypoallergenic mean I will not react to a product?

No. The FDA says there are no federal standards or definitions for hypoallergenic. Read the INCI for ingredients you know you react to and patch test for 24 to 48 hours.

How can I tell if a product is really cruelty-free?

The FDA says "cruelty-free" has no legal definition, and a claim may cover only the finished product. Look for an independent certification that covers ingredient suppliers.

Is preservative-free skincare cleaner?

Not for water-based products. Without a preservative, a product that contains water can grow bacteria, yeast and mold after opening. Look for a named preservative instead.

These statements have not been evaluated by the Food and Drug Administration. These products are not intended to diagnose, treat, cure, or prevent any disease.

About the Author
Written by Kari Thomas, cosmetic formulator and founder of Skin Perfection.

Sources

• Code of Federal Regulations. 21 CFR 701.3, Designation of ingredients. Order of predominance, the 1% rule, fragrance and trade secret declarations.
• U.S. Department of Agriculture, National Organic Program. Cosmetics, Body Care Products, and Personal Care Products fact sheet. Organic labeling categories and seal rules.
• U.S. Food and Drug Administration. Cosmetics Safety Q&A: Hypoallergenic.
• U.S. Food and Drug Administration. "Cruelty Free" / "Not Tested on Animals".