In this article, learn about:
Why "clean beauty" has no single definition, and who fills the gap
The three layers suppliers must meet: federal disclosure rules, state ingredient bans, and retailer restricted-substance lists
How to treat clean as an ingredient-data discipline, not a marketing label
"Clean beauty" is one of the most powerful labels in cosmetics retail. However, unlike what many consumers assume, the term has no legal meaning associated with it.
In retail, clean beauty generally refers to products made without ingredients a brand or retailer considers potentially harmful, like parabens, phthalates, and per- and polyfluoroalkyl substances, generally known as PFAS. The FDA does not approve or define cosmetic ingredients before market, apart from color additives and a short prohibited list, and neither the FDA nor the FTC defines "clean" at all. Each retailer sets its own standard and marks qualifying products with a badge.
That is why a skincare brand can formulate a product carefully, earn a clean badge at one major retailer, then get rejected by the next for an ingredient the first one allowed. For example, Clean Sephora restricts roughly 50 ingredients, while Credo, a competing clean beauty retailer, restricts more than 2,700. A product can easily clear one retailer’s restrictions and still fall afoul of another.
A brand marketing a product as “clean” is meeting a stack of separate standards at once: federal disclosure rules, state ingredient bans, and divergent retailer lists, each enforced independently. The brands that handle it well treat clean as a data problem, not a label, keeping ingredient data accurate enough to map one product against every standard that applies.
There Is No Federal Definition of “Clean”
No federal agency defines what "clean" means in cosmetics. The FDA regulates cosmetics mainly through rules on adulteration and labeling, and it does not approve or define ingredients before they reach the market, apart from color additives and a short list of prohibited or restricted substances. "Clean," "natural," and "non-toxic" are marketing terms, and a brand can use them without meeting any federal standard.
In the absence of federal regulation, the definition is filled in by everyone else, which is why a brand ends up answering to three separate layers of rules at once:
Federal disclosure and labeling laws
State ingredient bans and disclosure laws, first introduced by California
The private restricted-substance lists that major retailers enforce as a condition of shelf space
The rest of this article walks through each one and shows why a product that satisfies all of them still has no single thing called "clean" to point to.
Federal Disclosure and Labeling Rules
Before any "clean" claim enters the picture, every cosmetic supplier owes a baseline set of federal obligations.
Under the Federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act, a cosmetic label has to carry an ingredient list, a statement of identity, the net quantity of contents, and the name and place of business of the manufacturer, packer, or distributor. This is disclosure law and it governs what you have to tell the buyer.
The rules expanded sharply with MoCRA, the Modernization of Cosmetics Regulation Act of 2022. It is the most significant change to U.S. cosmetics law since 1938, and it added enforceable obligations that fall directly on brands. The operative ones:
Facility registration on Form FDA 5066, renewed every two years
Product listing on Form FDA 5067, which requires a full ingredient list and has to be updated annually
Both are filed through the FDA's Cosmetics Direct portal, and missing either one can render a product misbranded.
MoCRA also formalizes a documentation expectation. Brands are expected to hold records substantiating each product's safety under its labeled use, including ingredient data, stability studies, and toxicology reports. The formula itself is no longer separable from the paperwork behind it. If the FDA asks, the proof has to already exist.
The takeaway for brands: Federal law is almost entirely about disclosure and documentation. It tells you what to reveal and what to keep on file but does not certify anything as "clean." That judgment is left to the states and the retailers, which is where the requirements start to diverge.
State Ingredient Bans and Disclosure Laws
Where federal law mostly governs disclosure, the states go a step further and ban specific ingredients outright. California moved first, and the rest of the country is filling in behind it.
The foundation is the California Toxic-Free Cosmetics Act, signed in 2020 as AB 2762. It bans 24 specified intentionally added ingredients, including carcinogens, reproductive toxicants, and endocrine disruptors, from cosmetics sold in the state beginning January 1, 2025.
Two years later, the state added the PFAS-Free Cosmetics Act (AB 2771), which bars intentionally added PFAS as an entire class, also effective January 1, 2025. Then came AB 496, signed in 2023, which adds 26 more banned ingredients effective January 1, 2027, bringing the running total to roughly 50 and aligning California closely with the EU's prohibited list.
A separate law, the Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (SB 312), takes the disclosure angle rather than the ban angle: It requires companies to report fragrance and flavor ingredients linked to health or environmental harm to the state's Safe Cosmetics Program database, which then makes that information public.
The reason to start with California is that the others followed its template. As of early 2026, eight states had enacted class-wide bans on intentionally added PFAS in cosmetics: Washington, Oregon, California, Colorado, Minnesota, Maine, Vermont, and Connecticut, with more pending. Each of these laws differ on which ingredients are covered, how trace contaminants are treated, and when each ban takes effect.
For a brand, that is the real difficulty. A formula that is legal to sell in one state may be barred in another, and the bans are written against specific ingredients and their Chemical Abstracts Service (CAS) numbers. Checking compliance is a matter of matching every ingredient in a formula against every applicable state list, by identifier, and keeping that match current as new states are added.
Retailer Restricted-Substance Lists
This is the layer that actually controls shelf space. Federal and state rules set the legal floor, but a retailer decides whether a product is "clean" enough to carry, and each one draws its own line. These are private standards, not laws, enforced as a condition of stocking the product.
Here are some examples how widely each retailer’s “clean” list can vary:
Credo's "Dirty List" is the strictest. It restricts more than 2,700 ingredients and extends past the formula itself into sourcing, third-party certifications, and packaging.
Clean at Sephora is far shorter, built around a list of more than 50 banned ingredients.
Ulta's Conscious Beauty program treats clean ingredients as one of several pillars. Its "Made Without List" sets specific PPM limits for certain contaminants rather than banning them outright, and ethoxylated ingredients are permitted only if each batch meets contamination limits for 1,4-dioxane and ethylene oxide.
Because each retailer's list is its own, a formula can clear one and be turned away by the next. For a brand, "passing" is a separate screen against every list that matters to where the product needs to sell.
“Clean” Is Not One Set of Standards
Take one SKU within health, beauty, and wellness. To be considered compliant and “clean,” it has to:
Satisfy federal disclosure and labeling rules.
Clear every state ban that applies wherever it ships, with those bans differing by state and by effective date.
Pass the restricted-substance list of each retailer that carries it, lists that range from roughly 50 ingredients to more than 2,700.
Each regulation is written separately and enforced separately, and the product has to hold up against all of them simultaneously.
This is where treating “clean” as a marketing decision becomes expensive. A brand that picks the word first and checks the requirements later tends to discover the conflicts: during retailer onboarding, when a buyer's compliance team rejects the formula, or at a state border, when a product already in production can no longer ship there. But by then the options are narrow. Reformulating a finished product, re-testing it, and re-doing its documentation costs far more than screening the formula against every applicable standard before launch.
That is why "clean" is not a claim to make and defend. It is a set of overlapping requirements to track against accurate ingredient data.
Clean Compliance and Ingredient-Data Discipline
Here is what ingredient-data discipline looks like in practice:
Maintain one authoritative formulation record per SKU. Identify every ingredient by INCI name and CAS number, not free-text descriptions. Ban lists are written against identifiers, so a formula recorded that way can be matched against them automatically instead of read and judged by hand.
Capture supplier documentation at the point of sourcing. Collect safety data sheets, certificates of analysis, and allergen and toxicology data as ingredients come in, so safety substantiation already exists before launch rather than being assembled under pressure after a retailer or the FDA asks for it.
Track which standards each SKU is claiming against, and re-screen when any of them change. Retailer lists and state laws update on their own schedules, so a product that passed last year may not pass today. Tie each SKU to the specific standards it needs to meet, and re-run the screen whenever one of those standards moves.
Govern product and ingredient attribute data centrally. Keep one verified source of ingredient data that feeds everything downstream: label copy, retailer submissions, FDA product listings, and state compliance checks. When the same data drives all of them, a single correction propagates everywhere instead of being fixed in one place and missed in another.
Clean Compliance Starts With Clean Product Data
Every standard in this article asks the same underlying question: what is in this product, and can you prove it to whoever is asking.
That is a product-data problem before it is a compliance problem, and it is exactly what SPS Commerce Assortment is built to solve. Assortment lets you keep your product and ingredient data in one place, standardize it to each trading partner's required format and attributes, and validate it against their business rules to catch and correct errors before the data goes out.
That is the discipline a multi-standard world demands. Instead of rebuilding a spreadsheet for every retailer and re-checking it by hand, you maintain one accurate source of product data and deliver it to each partner in the format they require. When a retailer updates its list or you expand into a new channel, the data is already structured to be screened and sent again. Talk to a specialist to see how to manage your product data so "clean" becomes something you can document, not just claim.