Selling sunscreen online: SPF, water resistance and the words that are not allowed

In the US, a sunscreen is not a cosmetic. It is an over-the-counter drug, with a Drug Facts label, an SPF that comes from the FDA's test, and a short list of words it may never use. A tinted moisturiser with SPF 30 is a sunscreen too. That surprises many beauty sellers, and it is why sunscreen listings meet more checks than the creams beside them.

This page covers the label, the words required and barred, approvals on Amazon and Walmart, and what changes in Canada and the EU.

What this page covers: sunscreens, SPF moisturisers and makeup with SPF, and tanning products with SPF.

The short version

• A US sunscreen needs a Drug Facts label and an SPF from the FDA test.
• "Broad Spectrum" is allowed only if the product passes that test.
• "Sunblock", "waterproof" and "sweatproof" are never allowed. Water resistance is stated as 40 or 80 minutes.
• Walmart and Amazon treat sunscreen as a restricted category.
• Canada needs a Drug Identification Number or a Natural Product Number; the EU treats sunscreen as a cosmetic.

What must a sunscreen label carry?

A US sunscreen needs a Drug Facts label and an SPF value from the FDA's test method, because US sunscreens are over-the-counter drugs. "Broad Spectrum" may appear only on a product that passes the broad spectrum test.

Which words may a sunscreen listing never use?

"Sunblock", "waterproof" and "sweatproof" are never allowed on a US sunscreen, and water resistance is stated as 40 or 80 minutes:

Your listing should match your label exactly: the same SPF, the same Broad Spectrum claim, the same water resistance minutes.

Do Walmart and Amazon restrict sunscreen?

Yes. Walmart and Amazon treat sunscreen as a restricted category:

• Walmart treats over-the-counter drugs as a restricted category for vetted sellers. It expects a Drug Facts label, FDA registration and listing, and descriptions limited to the use on the Drug Facts label. Its cosmetics policy lists sunscreens sold as cosmetics as unsafe.
• Amazon places sunscreen under its restricted drug and cosmetic rules. Check the category's approval before you list.

What should sunscreen images show?

Sunscreen images should show the Drug Facts panel, the package as printed and scenes that promise no more than the label. The listing's description is limited to the use on the Drug Facts label, and images say things too. The images that hold up:

• A clear photo of the Drug Facts panel, readable at full size.
• The front of the package with the SPF and water resistance as printed.
• Scenes of the product in use that do not promise more than the label, such as a day of sun with no reapplying.

How do Walmart's and Amazon's sunscreen rules compare?

Walmart's and Amazon's sunscreen rules, side by side:

What does sunscreen need in Canada?

A sunscreen sold in Canada needs a Drug Identification Number or a Natural Product Number on the label, depending on its ingredient.

How does the EU treat sunscreen?

In the EU, sunscreens are cosmetics, and their claims follow the common criteria for cosmetic claims.

How Commicorn helps

• Your label, as printed. On the Untouched product route your photo's pixels are never redrawn, so the Drug Facts panel, the SPF and the water resistance minutes stay exactly as printed.
• Your claims, from your label. The listing copy is written from the details you give us. Give us the SPF and minutes as your label states them, and read the copy against the table above before you export.

Questions sellers ask

Is sunscreen a drug or a cosmetic?

In the US, a drug: sunscreen is an over-the-counter drug with a Drug Facts label. In the EU, sunscreens are cosmetics.

Can I call my sunscreen waterproof?

No. "Waterproof", "sweatproof" and "sunblock" are never allowed on a US sunscreen; write "water resistant" with the 40 or 80 minutes from your label.

When can a sunscreen say Broad Spectrum?

Only when the product passes the FDA's broad spectrum test.

Is a moisturiser with SPF a sunscreen?

Yes. In the US, a tinted moisturiser with SPF 30 is a sunscreen too, so it is an over-the-counter drug with a Drug Facts label.

What number does a sunscreen need in Canada?

A Drug Identification Number or a Natural Product Number on the label, depending on its ingredient.

Before you list

Have the Drug Facts panel, the SPF and any Broad Spectrum claim from the FDA's tests, the water resistance minutes as printed, and your FDA registration and listing ready before the listing goes live, along with Amazon's category approval or Walmart's vetting. On an edge case, such as a tinted moisturiser with SPF, the FDA's sunscreen rule at 21 CFR 201.327 decides what the label and the listing may say. In Canada the Drug Identification Number or Natural Product Number decides it, and in the EU the cosmetics regulation and its common criteria for claims.