How to market a skincare brand without medical claims

Rewrite skincare copy so it sells on how skin looks and feels, not on treating it: the FDA's intended-use test, UK wording that works, and Meta's beauty ad rules.

What this is for

A cream is a cosmetic or a drug depending on what you say it does, not only on what is in it. Claims about changing how the body works, rather than how skin looks, can turn a moisturiser into an unapproved drug in the eyes of the FDA. The agency lists examples. source, checked 28 September 2026

This guide shows how to find those claims in your store and ads and rewrite them into appearance and feel, which is still persuasive copy. It covers the US, the UK and Meta's ad rules. It is general information, not legal advice; for products such as sunscreens and acne treatments, get specialist regulatory help. The skincare industry page covers buyers and channels for this category.

Time needed and what you need

Time needed: about 3 hours for a first pass. Finding every claim, including product names and blog posts, takes most of it; rewriting goes quickly once you have the patterns.

Every product page, collection page and blog post, plus live ads and email templates
The list of product names and the ingredient callouts on each label
Any test results you hold: consumer panels, dermatologist tests, clinical studies
A spreadsheet with columns for the claim, where it appears, its type and the rewrite

The steps

Work through the claims in this order: the ones that make the product a drug, then the ones that need stronger evidence, then the ad-platform rules.

1. Collect claims from everywhere, product names included

The FDA reads intended use from labels, ads, websites and other promotion, and also from how shoppers see the product. That means a product called "Eczema Rescue Balm" makes a claim before anyone reads the description, and so does a blog post titled "how our serum clears breakouts". source, checked 28 September 2026

2. Flag anything that treats a condition or changes the body

Mark every line that names a skin condition as something the product fixes (acne, eczema, rosacea, psoriasis) or says it changes the skin's biology (repairs the barrier permanently, boosts collagen production, regenerates cells, stops pigment forming). In the US these are drug claims for a product sold as a cosmetic.

3. Rewrite from change to appearance

Most flagged claims can be kept as a claim about how skin looks or feels, and usually as a temporary effect. The UK regulator's line on wrinkle creams is a useful model for any market. source, checked 28 September 2026

"Heals dry, cracked skin" becomes "Leaves dry skin feeling soft and comfortable"
"Clears acne" becomes "A gentle cleanser for oily, blemish-prone skin"
"Fades dark spots" becomes "For a more even-looking skin tone"
"Boosts collagen" becomes "Skin looks plumper and smoother"

4. Sort sensory claims from efficacy claims

"Skin feels smoother" is a sensory claim that a consumer panel can support. "Reduces wrinkle depth" is an objective claim, and the ASA expects testing on people for it; in-vitro results are often not enough. A survey of customers never supports an objective claim. source, checked 28 September 2026

5. Know which products are drugs whatever you say

Some skin products are drugs in the US by what they are for, such as sunscreens, acne treatments and anti-dandruff products. If you sell one, the claim can stay, but the product has to meet the drug rules, including its labelling. A moisturiser with SPF is both. source, checked 28 September 2026

6. Check before-and-after images and retouching

A photo can overstate an effect as easily as words can. The ASA expects evidence behind efficacy claims and warns against exaggeration through images. Use unretouched photos taken in the same light, and do not show a result bigger than your evidence supports. source, checked 28 September 2026

7. Apply Meta's beauty rules to your ads

Meta bans ads that put down how someone looks, which rules out hooks like "Embarrassed by your pores?". It also refuses ads for products that permanently lighten skin. Everyday creams and makeup are not held to its over-18 targeting rule, so you do not need to restrict the audience age for them. source, checked 28 September 2026

Talking about the viewer's skin, rather than the product, also runs into the personal attributes rule; the personal attributes guide has rewrites.

8. Hold reviews and creator content to the same test

A customer writing "this cured my rosacea" is sincere, but once you put it in an ad or on a product page it is your claim. Feature reviews about texture, scent, how skin feels and how long a jar lasts. The guide to turning reviews into ad copy covers choosing lines that stay safe.

A worked example

For a small-batch skincare brand with 9 products
Worked example (an invented brand with invented numbers)
The brand finds 22 claims across its product pages, 5 ads and its welcome emails.
11 are sensory claims such as "skin feels softer" and stay as written. 6 describe a change in the skin and are rewritten to appearance, for example "reduces wrinkles" becomes "reduces the appearance of fine lines". 3 are drug claims ("heals eczema", "regenerates cells" and a product named "Acne Cure Gel") and are removed, with the gel renamed "Clarifying Gel". 2 cite a firmness result the brand has no test for and are held back until it runs a study on people.
That is 11 + 6 + 3 + 2 = 22 claims dealt with, and 2 of the 5 ads, which opened with "Struggling with breakouts?", are rewritten to describe the gel instead.

Common mistakes

Calling a product a cosmeceutical or "clinical" to sound serious. Neither word creates a middle category; they draw attention to the claim and invite the question of what evidence sits behind it. source, checked 28 September 2026

Forgetting cleansers. A face wash sold only to clean is a cosmetic; one sold to treat acne is regulated as a drug. The claim on the bottle decides which. source, checked 28 September 2026

Backing a hard claim with a customer poll. "Wrinkles reduced" cannot be proved by asking customers what they think; that needs measurement on people. Keep panel results for feel-based claims. source, checked 28 September 2026

Fixing the product page and missing the blog. Old posts about treating skin conditions sit on your domain and count as promotion. Include them in the audit and rewrite or retire them.

Doing this with Tilly

Tilly's agents write into the tools you already use: the ads agent publishes to Meta with ads paused, emails go to Klaviyo as drafts and blog posts to your Shopify blog, and nothing publishes without approval. Keep your list of claims to avoid next to you when you approve, and read every draft against it.

Questions people ask

Can I still say "anti-ageing"?

As a description, often yes; as a promised effect, no. The ASA says calling a cream anti-ageing is unlikely to be a problem on its own, especially when the ad makes clear the effect is temporary. source, checked 28 September 2026

Do I need FDA approval to sell a moisturiser?

Not for a cosmetic. Apart from colour additives, cosmetics do not need FDA approval before sale, which is exactly why a drug claim is a problem: it describes a product that has not been through the drug route. source, checked 28 September 2026

Are feel-based claims weak copy?

Only if they are vague. "Sinks in within a minute, no sticky film" is specific, true and easy to support, and it answers a real worry. The ASA treats sensory claims like these as low-risk. source, checked 28 September 2026

See this on your own store

Paste your store URL. The first pass takes about a minute and needs no account. Save a card (nothing is charged) and Tilly reads the whole store and works out who buys from you.