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Ep 33: How to REALLY Find Acne-Safe Skincare


We already covered where the term "non-comedogenic" came from (which was a 1972 rabbit ear study with some pretty significant limitations). But here's the part that might actually make you put down a product: there are no legal requirements to use it. Literally none!


What the regulations actually say


In the US, the FDA and FTC don't require any pre-market testing or approval for cosmetics. The rules are that labels must be "truthful and not misleading," and that's about as specific as it gets. There's no definition of non-comedogenic, no required study, and no minimum number of test subjects. In December 2022, an act called MoCRA expanded the FDA's access to brand safety files, but it doesn't mention comedone counts, rabbit ear assays, or anything close to a non-comedogenic testing standard.


The EU is slightly more rigorous in that brands are required to have "adequate and verifiable evidence" for every performance claim, and regulators can ask to see the file. But even there, the law doesn't define what kind of study, how many subjects, or what results would actually qualify a product as non-comedogenic.


So in practice, in both the US and EU, a brand can put "non-comedogenic" on a label and face essentially no legal consequence for it, as long as they can make a loose argument that they did something to substantiate it.


Why brands keep using it anyway


Because it works. Studies on online shopping show that unregulated buzzwords like "non-comedogenic," "clean," "oil-free," and "silicone-free" drive more sales than regulated terms like SPF claims. As of 2022, products meeting one major retailer's "clean" definition grew 14.7%, and paraben-free products made up over 60% of total beauty and personal care sales.


Non-comedogenic is a low-cost, high-reward label claim. It doesn't require any regulatory approval, it taps directly into consumer ingredient anxiety, and tells people the product is "Safe" without having to prove it. Most companies either formulate to the standards of online acne-checking software (more on that in a minute) or just apply the term and move on.

It's not necessarily malicious, it's just how marketing works.


What good testing actually looks like (versus what usually happens)


A well-executed comedogenicity study applies a product to 30-50 volunteers using a randomized, double-blind protocol, runs for 3-4 weeks with daily application (mimicking real-world use), and has multiple dermatologists recording follicular counts before and throughout the study. Both comedones and any emerging inflammatory lesions are tracked, and results are reported quantitatively with actual lesion counts and meaningful statistics.


A poorly executed study looks like this: 5-10 subjects, 48-hour patch applications that overload follicles by applying the product in a way no normal person would, no control product for comparison, a single observer counting results (which introduces significant bias, especially since spotting comedones under a microscope is quite difficult), and a one-time inspection at the end with qualitative notes like "no visible blockage."


Some brands skip internal testing entirely and just rely on the 1970s rabbit ear data or run their formula through an online ingredient checker. If a brand can't point to an actual study done on their specific finished product, the claim is purely marketing.


One more distinction worth knowing: non-comedogenic and non-acnegenic are not the same thing. Non-comedogenic only addresses whether a product causes new comedones (blackheads and whiteheads). Non-acnegenic addresses the full acne process, including papules, pustules, and nodules. A product can technically pass a pore-clogging test and still inflame follicles and trigger breakouts. Non-acnegenic testing is generally more robust and more relevant for acne-prone skin.


About those pore-clogging ingredient checkers


You've probably seen these ingredient checkers online. You paste in an ingredient list and the app flags anything "comedogenic." They're everywhere and people treat them like gospel.


Here's the issue: most of them are pulling from James Fulton's 1989 ingredient list and/or the original 1972 Acne Cosmetica study. Both of those are based on rabbit ear data. And as we've established, rabbit skin is way more sensitive than human skin, meaning ingredients that score a 2-3 on those scales may be completely harmless on your face.


There's also no standardization across checkers. Some flag anything above a 1, some only flag 4s and 5s. An ingredient at 5% concentration and the same ingredient at 0.05% would get the same flag, even though they'd behave very differently in an actual formula. These tools have no concept of how ingredients interact with each other or how they're distributed throughout a finished product.


They can sometimes be helpful, but they're frequently wrong, and the confidence with which they present their results is not matched by the science behind them.


What to actually do with this information


If you're acne-prone and trying to navigate products, here's a more grounded approach than trusting a label claim - thanks to Lab Muffin Beauty Science for this list:


  1. If you're having a breakout and can't identify the cause, use the comedogenicity scale to rule out high-rated ingredients (think 4-5), not to identify definitive culprits. It's a starting point, not a diagnosis.

  2. Pay attention to where an ingredient falls on the ingredient list. Something comedogenic near the top of the list is present at a higher concentration than something buried near the bottom. If a flagged ingredient is past the fifth or sixth position, it's usually diluted enough to be a non-issue.

  3. Avoid applying highly concentrated individual ingredients (oils, butters) directly to your face if they score high on the scale and you're prone to acne. Coconut oil at 100% concentration on oily skin is very different from a small percentage of coconut oil in a well-formulated moisturizer.

  4. Patch test everything. On your arm first, then on a small area of your face, before going all in. There's no substitute for seeing how your specific skin responds.


The non-comedogenic label can be a useful first filter if you treat it as exactly that: a filter, not a promise.


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