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Sunscreen

The words you may not use

Updated

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Three words are named in the regulation itself as false or misleading, and they are exactly the three a marketer reaches for.

The three

  • Sunblock. Nothing blocks; products reduce. The word overstates what any sunscreen does.
  • Sweatproof. There is no such performance and no test that would support it.
  • Waterproof. Replaced entirely by the water resistance statement with a time.

Why they are prohibited rather than discouraged

Each implies a completeness the product does not have, and a user who believes a product blocks the sun or survives swimming indefinitely reapplies less and burns. The words change behavior, which is why they are treated as misleading rather than merely loose.

What to say instead

The tested facts: the SPF, broad spectrum if it qualifies, and Water Resistant with 40 or 80 minutes if it was tested for it. Those are specific and defensible, and they are more informative than the banned words were.

It applies beyond the label

A website, an advertisement and a social post describing a product as waterproof carry the same problem as a label that does. The prohibited word is prohibited because of what it conveys, not because of where it is printed.

Watch inherited copy

Older packaging, a distributor’s listing, a retailer’s product page or a description written years ago can all still carry these words. If you sell through others, what they write about your product is worth auditing.

Similar overstatement without the exact word

All-day protection, total protection and the like make the same claim in other words. The regulation names three terms and the principle behind it reaches further than the three.

Retailers reproduce your copy

Listings on marketplaces and shop websites are often written from your own description, so a prohibited word in your copy propagates to places you do not control. Supplying approved copy is easier than correcting it later.

Replace them with the tested facts

SPF, broad spectrum, and Water Resistant with 40 or 80 minutes say more to an informed buyer than the banned words ever did, and every one of them is defensible because a test produced it.

References

21 CFR 201.327, Over-the-counter sunscreen drug products; required labeling based on effectiveness testing. Paragraph (g) makes “sunblock”, “sweatproof” and “waterproof” false or misleading; paragraph (a)(2) permits only “Water Resistant (40 minutes)” or “(80 minutes)”; paragraph (d)(2) carries the Skin Cancer/Skin Aging Alert. law.cornell.edu
Written from federal regulation, not from a formulation lab. A sunscreen is an OTC drug and an insect repellent is a pesticide, and both carry requirements that a cosmetic does not. Nothing here clears a specific label, and the difference between a cosmetic claim and a drug claim is narrower than it looks.