Can You Legally Call Your Skincare “Clean” in 2025? A Regulatory Guide for Founders

The word “clean” is everywhere in beauty marketing, but as of 2025, it’s no longer a free pass.

Between tightening regulations (hello, MOCRA), FTC crackdowns on greenwashing, and consumer demand for real transparency, brand founders now face a crucial question:

Can you legally label your skincare product as “clean”?

If you’re launching or scaling a clean beauty brand, this guide will help you understand how to protect your claims, and your business in today’s regulatory climate.

Why “Clean Beauty” Is Under Fire in 2025

For years, “clean” meant whatever a brand wanted it to mean, but those days are over.

  • MOCRA (Modernization of Cosmetics Regulation Act) is now in effect and gives the FDA more authority to inspect, recall, and hold brands accountable.

  • The FTC’s Green Guides are cracking down on terms like “non-toxic,” “safe,” and “eco-friendly” when they’re not properly substantiated.

  • Retailers like Sephora, Target, and Ulta have their own “clean” standards and many are revising them in 2025.

  • Consumers are demanding proof, not promises - they want to know what “clean” actually means in your product.

So… Can You Still Use the Word “Clean”?

Yes, but you need to be specific.

“Clean” is still legally allowed, but only if:

  • It is tied to a defined standard

  • You can support it with data, documentation, or credible third-party verification

  • It doesn’t imply medical safety, FDA approval, or misleading “non-toxic” claims

Examples of responsible use:

  • “Formulated without parabens, sulfates, or synthetic fragrance”

  • “Clean according to Sephora’s standards”

  • “Free from over 1,500 restricted ingredients globally”

Red flags to avoid:

  • “Clinically safe” (unless you’ve done actual clinical trials)

  • “FDA approved” (no cosmetics are FDA approved)

  • “Non-toxic” (implies medical safety and can trigger legal scrutiny)

  • “All natural and safe for everyone” (not true for all ingredients or skin types)

What Founders Often Overlook

If you’re using the word “clean” in your brand story, here’s what you should also be doing behind the scenes:

1. Have a Clear “No List”

Define what “clean” means for your brand - in writing. Reference banned or restricted ingredient lists (EU, Sephora, EWG, etc.) and ensure your lab and marketing team are aligned.

2. Ensure INCI Transparency

Make sure every ingredient in your INCI list matches what’s in the formula and that you’re not hiding anything behind vague terms like “fragrance” or “proprietary blend.”

3. Test for Safety Where Needed

If you’re making claims about sensitive skin, baby-safe, or barrier support, include pH testing, stability data, or dermatological testing to back those claims up.

4. Avoid Overstating What Clean Means

Be honest. Clean doesn’t mean your product works for every skin type, solves every concern, or is safer than medically regulated products.

How Vaulabs Helps Founders Stay Compliant

At Vaulabs, we work with both startup and scaling brands to ensure that every product we formulate can stand up to scrutiny.

Our process includes:

  • Ingredient screening against global “no lists”

  • Clean preservation systems and pH-balanced formulation

  • Transparent INCI documentation and supplier traceability

  • Label claim reviews based on your target market (U.S., Canada, EU)

You bring the vision - we make sure it’s credible, compliant, and clean in a way that actually matters.

In 2025, “clean” is no longer just a vibe - it’s a responsibility.

You can still build a brand around integrity, simplicity, and conscious formulation, but if you want to use that word, you need to do it right. And we’re here to help you do exactly that.

Ready to develop a clean beauty product that’s both effective and compliant?

Reach out to our team at info@vaulabs.com or contact us to start your R&D process today.

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