The short answer
FDA does not define “clean”, “natural”, “vegan”, “cruelty-free” or “non-toxic” for cosmetics, and it has no list of approved claims. But every claim on a cosmetic label must be truthful and not misleading, and the Federal Trade Commission (FTC) polices advertising claims. “Organic” is the exception: it is defined by the USDA National Organic Program, not FDA.
Common claims and what stands behind them
| Claim | Official definition? | What to have on file |
|---|---|---|
| “Organic”, “USDA Organic” | Yes — USDA NOP for agricultural ingredients | Organic certification; USDA seal only if certified at the required percentage |
| “Cruelty-free”, “Not tested on animals” | No legal definition (FDA) | Supplier statements for ingredients and finished product; certifier if you use a logo |
| “Vegan” | No | Ingredient review — no beeswax, lanolin, carmine, collagen, keratin, honey |
| “Natural”, “100% natural” | No | Ingredient sources and processing; avoid “100%” with synthetic preservatives |
| “Clean”, “non-toxic”, “free of 1,000 chemicals” | No | A written definition of what you mean — and avoid implying other products are unsafe |
| “Hypoallergenic”, “dermatologist tested” | No | Test reports supporting the exact claim |
Rules that still apply
- FDA does not require animal testing for cosmetics; the manufacturer chooses how to substantiate safety. See safety substantiation.
- Some U.S. states, including California, restrict the sale of cosmetics developed or made using animal testing.
- “Natural” is not a safety claim — FDA says an ingredient’s source does not determine its safety.
- Drug claims are never saved by a “natural” label: “heals eczema naturally” is still a drug claim.
- The FTC has acted against companies that called personal care products “all natural” when they contained synthetic ingredients.
- Claims count on the label, website, Amazon listing and social media alike.
Example: a skincare brand from Australia
An Australian brand wants to use “clean, vegan, cruelty-free and natural” on its U.S. packs. It keeps “vegan” after confirming no animal-derived ingredients, keeps “cruelty-free” with signed supplier statements and a recognized certification, replaces “100% natural” with “made with 95% naturally derived ingredients” because it uses a synthetic preservative, and defines “clean” on its website as a list of ingredients it does not use.
Cosmetics label review with claims check $250. Cosmetic facility registration with U.S. Agent from $300 (1 year) or $450 (2 years). Product listing $150 per product.
Frequently asked questions
Does FDA define “cruelty-free”?
No. FDA says there are no legal definitions for “cruelty-free” or “not tested on animals”.
Who regulates “organic” cosmetics?
The USDA National Organic Program defines “organic” for agricultural ingredients. FDA rules on labeling and safety still apply.
Can I call my cosmetic “clean”?
There is no definition, so the claim must be truthful and not misleading. Explain what you mean and do not imply other products are unsafe without evidence.
Does FDA require animal testing for cosmetics?
No. The law does not specifically require animal testing; companies must substantiate safety using appropriate methods.
Sources
- FDA — “Cruelty Free” / “Not Tested on Animals”
- FDA — “Organic” cosmetics
- FDA — Cosmetics safety Q&A: animal testing
- FDA — Cosmetics labeling claims
Requirements checked on November 12, 2026. This article is general information, not legal advice.