Skincare claim risk list (second category)
Updated 2026-08-15 · Risk-term list version 2026-08-15c
23 high-risk and needs-review phrasings for skincare and body care, in six families. The key difference from shapewear: beauty risk is not only exaggeration but category — phrases like "anti-inflammatory", "repairs the barrier" and "stimulates collagen" turn a cosmetic into a drug, which is a different registration and labelling regime.
The list is not lawyer-reviewed, and we could not open the regulator’s official pages in this pass. So each entry describes the shape of the risk rather than paraphrasing regulation, the page carries no regulatory links, and there are no per-term pages.
The beachhead is still shapewear and functional intimates — built out, with a page per term. Beauty is the second category: complete here, and explicitly labelled as what it is.
- This list has not been reviewed by a lawyer. Neither has the shapewear list, but beauty differs in kind: the risk is not only exaggeration but category — one sentence can turn a cosmetic into a drug, which is a different registration and labelling regime.
- We could not open the regulator’s official pages from this machine in this pass. So each "why" below describes the shape of the risk rather than paraphrasing regulation, and the page carries no regulatory links — by this site’s citation rule, we do not link pages we have not opened.
- That is why beauty has no per-term pages. Forty-five authoritative-looking regulatory explainers built on unverified sources is exactly what this site criticises elsewhere. Concentrating the caveats on one page is more honest than scattering them across forty-five.
The list in full
23 terms, 19 of them high risk. The levels match the beachhead category: high risk (no reasonable risk-free reading) and needs review (two readings, decided by context).
| Phrase | Level | Family | Why | Say instead |
|---|---|---|---|---|
treats acne | High risk | Drug-style claims (treating and repairing) | "Treats" positions a cosmetic as something aimed at a skin condition, which pulls it into a different regulatory category that ordinary skincare cannot satisfy. | part of a daily cleansing and moisturising routine |
anti-inflammatory | High risk | Drug-style claims (treating and repairing) | Inflammation is a medical concept and "anti-inflammatory" describes a therapeutic action. It is the most common phrasing in skincare copy and among the fastest to get a listing pulled. | (delete the sentence) |
repairs the skin barrier | High risk | Drug-style claims (treating and repairing) | "Repairs" points at restoring a bodily function, which reads as a drug claim. What you usually mean is "it does not feel tight", which is both safer and more specific. | does not leave my skin feeling tight |
eczema | High risk | Drug-style claims (treating and repairing) | Naming a skin disease is itself a claim that the product relates to that disease. Ordinary skincare copy should not carry disease names. | (delete the sentence) |
fades acne scars | Needs review | Drug-style claims (treating and repairing) | Two readings: describing appearance ("looks more even") is lower risk; promising the marks go is a change in skin condition and slides into drug-claim territory. Context decides. | (if describing appearance) looks more even under makeup |
stimulates collagen | High risk | Structure or function claims | Claims an effect on a production mechanism inside the skin — the textbook shape of a structure-or-function claim, which is outside what a cosmetic may say. | (delete the sentence) |
cell renewal | High risk | Structure or function claims | Same family, and more explicitly at the cellular level. | (delete the sentence) |
restores hair growth | High risk | Structure or function claims | Promoting hair growth is an unambiguous functional claim and belongs to an entirely different approval track. | (delete the sentence) |
removes wrinkles | High risk | Structure or function claims | "Removes" is a structural change; a cosmetic works on how something looks. To review these are not different degrees but different categories. | fine lines look smoother under makeup |
reduces cellulite | High risk | Structure or function claims | Changing cellulite is a change in body condition, i.e. a functional claim. It appears constantly in body-care copy and carries constant risk. | (delete the sentence) |
FDA approved | High risk | Regulatory status and grade illusions | Ordinary cosmetics are not an approved product category, so this states a regulatory status that does not exist for them. That is a false regulatory claim, not an exaggeration. | (delete the sentence) |
medical grade | High risk | Regulatory status and grade illusions | "Medical grade" is not a defined tier for cosmetics, but it makes the reader believe this is what clinics use. It manufactures the impression of a credential. | high-concentration formula |
pharmaceutical grade | High risk | Regulatory status and grade illusions | Same shape as above, one step stronger — it borrows the authority of an entire regulated industry. | (delete the sentence) |
dermatologist recommended | High risk | Endorsement and evidence | An endorsement claim: you must be able to produce the dermatologist and the recommendation. Without them it is not a flourish, it is a factual statement you can be held to. | (delete the sentence) |
clinically proven | High risk | Endorsement and evidence | An evidence claim requiring a study and a method you can show. "Lab tested" with no report to produce is riskier than saying nothing. | (with a real report) third-party test report on the listing |
chemical free | High risk | Absolute safety claims | Nothing is chemical free — water is a chemical. It is unsupportable on its face, and it implies a safety guarantee you cannot back. | no added fragrance, no added alcohol |
zero irritation | High risk | Absolute safety claims | Any skincare can irritate someone. "Zero" is an absolute nobody can honour, and the moment one person reacts, this sentence becomes the clearest evidence against you. | it did not sting on me (personal experience) |
safe for pregnancy | High risk | Absolute safety claims | A safety endorsement for a specific vulnerable group, far beyond what a seller can judge. The right move is to send them to their own doctor. | ask your own doctor if you are pregnant |
all natural | Needs review | Absolute safety claims | "Natural" has no agreed definition, and natural does not mean gentle. It reads as a safety promise, which makes it the vaguest and most challengeable line in this family. | (name the actual ingredients instead of characterising the whole) |
hypoallergenic | Needs review | Absolute safety claims | Widely used and weakly defined: it suggests a tested allergy profile that in practice often has nothing behind it. Keep it only if you can say what was tested. | (if tested) patch-tested, report on the listing |
non-comedogenic | Needs review | Absolute safety claims | Same shape as hypoallergenic — a technical-sounding safety claim with no shared standard behind it. It is not automatically a problem; be ready to say what supports it. | (delete the sentence) |
overnight results | High risk | Immediacy and absolutes | Immediacy plus outcome — the least arguable line in this family. | (delete the sentence) |
permanently | High risk | Immediacy and absolutes | Cosmetic effects are reversible and fade when you stop. "Permanently" contradicts the nature of the product. | (delete the sentence) |
Six families: beauty’s risk has a different shape
Almost all shapewear risk is "promising what the product cannot do". Beauty adds a layer: certain sentences change what category the product is in. The first two families below are that layer.
| Family | Terms | In one line |
|---|---|---|
| Drug-style claims (treating and repairing) | 5 | Verbs like "treat", "anti-inflammatory" and "repair" point at restoring a bodily function rather than at appearance. |
| Structure or function claims | 5 | "Stimulates collagen", "cell renewal" and "restores hair growth" claim an effect on a mechanism inside the skin. |
| Regulatory status and grade illusions | 3 | "Medical grade", "pharmaceutical grade" and "FDA approved" manufacture the impression of a credential — that the product cleared some approval. |
| Endorsement and evidence | 2 | "Dermatologist recommended" and "clinically proven" require you to produce the dermatologist and the study. |
| Absolute safety claims | 6 | "Zero irritation", "all natural" and "safe for pregnancy" promise safety to an audience you cannot know. |
| Immediacy and absolutes | 2 | "Overnight", "permanently" and "completely" turn a process that varies by skin and fades when you stop into a certain, irreversible outcome. |
What you can do with it today
- Scan skincare copy with the free checker — it already reads this list, because it reads the same data.
- Run a full plan on a skincare link: angles, bilingual scripts, storyboards and the creator brief are all wired up. Sample: the niacinamide serum plan.
- Download the list to diff against your own: Chinese CSV · English CSV (CC BY 4.0, carrying the same three caveats).
- Do not cite it as a regulatory basis to anyone. It is a list of items to check, and an unreviewed one at that.
What unblocks per-term pages
Two things, and neither is optional:
| Condition | Why this one | Who |
|---|---|---|
| A lawyer reviews the list | Beauty rests on regulation rather than platform policy, and reading regulation is not a call we can make ourselves | You (the order in Q3 was: legal review after the first paying users and before the beauty knowledge base — the knowledge base now exists first, so that order needs re-confirming) |
| Being able to open the official pages and verify line by line | This site’s rule is to link only pages we have opened. Without that we can describe risk shapes but not write authoritative interpretation | Agent (any machine with access) |
Until both happen, beauty on this site stays at this page plus one sample plan. It does not expand. The beachhead remains shapewear and functional intimates.
FAQ
If it is unreviewed, why publish it?
Because it is useful and, with the caveats stated, it does not mislead. The alternative is publishing nothing, which helps nobody writing skincare copy today. What we must not do is pretend it was reviewed — hence the caveats at the top rather than in a footnote.
How does it differ from the shapewear list?
Shapewear rests mainly on platform advertising policy pages we opened line by line, with links and verification dates on every page. Beauty rests on regulation, and we could not open the official pages in this pass — so one has per-term pages and sources, and this one has a single status page and zero links.
Does the checker scan skincare copy?
Yes. The checker reads this same data, so it already works on skincare. The same caveats apply: a match does not mean a problem, no match does not mean safe, and this list has not been reviewed.
When does it get built out?
When both conditions hold: a lawyer reviews the list, and the official pages can be opened and verified line by line. Until then beauty is this page plus one sample plan.
Why not wait until after the review?
Because the timing of the review is yours to set, and the knowledge base is finished now. Completing the data, stating the caveats and naming the unblock conditions is more useful than stopping halfway — you can switch the per-term pages on the day the review lands.