United States · Cosmetics

U.S. Cosmetic Claims Compliance in the United States

A practical guide to U.S. Cosmetic Claims Compliance for cosmetics sold in the United States: who it applies to, what to prepare, and the mistakes that cause rejection.

Who needs it
Cosmetic labels and advertising in the U.S.; Online product pages and influencer content
Authority
FDA and Federal Trade Commission (FTC)
Legal basis
FD&C Act; FTC Act
Local representative
Not applicable — the brand is responsible
Timeline
Before the claim is published
Cost
Testing and claim review costs vary
If you do not comply
Warning letters, enforcement, and false advertising liability

Who needs this

Documents you need

Compliance checklist

Tick each item as you collect it. Saved in this browser only.

How to comply

  1. Classify each claim
  2. Substantiate before publishing
  3. Remove drug-type claims

Brief for your lab or agent

Copy this into an email, then edit the product and channel.

Request: U.S. Cosmetic Claims Compliance — United States
Product category: Cosmetics
Authority: FDA and Federal Trade Commission (FTC)
Legal basis: FD&C Act; FTC Act

Documents we already have:
  1. Claim substantiation file
  2. Label and advertising review
  3. Clinical or consumer study data

Questions:
  1. Does our product fall under U.S. Cosmetic Claims Compliance in the United States?
  2. Which test standards or evidence do you accept?
  3. What is the current fee and lead time?
  4. Is a local representative required, and can you act as one?

Cost and timeline

Before the claim is published.

Testing and claim review costs vary.

Common rejection reasons

Registration, notification, or certification is not the same as approval. Keep the technical file current and make sure the label, listing, and submitted data match.

Official sources

FAQ

What is a drug claim?

A claim that the product treats, cures, mitigates, or prevents a disease, which moves it outside the cosmetic category.

Is puffery allowed?

Vague, non-material opinion statements are generally tolerated, but objective claims need substantiation.

Who enforces advertising claims?

The FTC enforces advertising substantiation, while the FDA enforces labeling and product classification.

How long does U.S. Cosmetic Claims Compliance take?

Before the claim is published.

How much does U.S. Cosmetic Claims Compliance cost?

Testing and claim review costs vary.

What happens if I sell without it?

Warning letters, enforcement, and false advertising liability.

Who regulates U.S. Cosmetic Claims Compliance in the United States?

FDA and Federal Trade Commission (FTC).

Related requirements

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