'Dermatologist Tested' Means Almost Nothing. Here Are the Label Claims That Do.

Before writing this we counted our own labels. Fifty-four products, 206 separate claim phrases attached to them — paraben-free, fragrance-free, silicone-free, vegan, allergen-free, EWG-Green. Not one of those 206 was reviewed by a regulator in any country before we published it.

That is not a confession of wrongdoing. It is how the entire category works, in the US and in Korea, and the reason a shelf of bottles can all sound equally reassuring while meaning wildly different things. Some label phrases are checked by a government agency against a numeric test. Some are industry conventions with a shared meaning and no enforcement. And some are just words a marketing team liked.

"Dermatologist tested" is in the third group. It has no protocol, no minimum number of subjects, and no regulator anywhere has defined it.

Tier 3: the phrases nobody ever defined

The FDA maintains a page listing the cosmetic claims it has felt obliged to comment on. Alcohol free. Aromatherapy. Cosmeceutical. Cruelty free. Hypoallergenic. Organic. Wrinkle treatments. "Dermatologist tested" is not on the list, and the same page explains why the list is so short: the law does not require cosmetic labeling to have FDA approval before a product goes on the market, and the agency "does not have a list of approved or accepted claims for cosmetics." Claims have to be truthful and not misleading. That is the whole standard.

Hypoallergenic is the more interesting case, because somebody did try. The FDA proposed a rule in February 1974 that would have required manufacturers to substantiate the term, and finalized it on 6 June 1975. Almay and Clinique took it to court. The US Court of Appeals for the DC Circuit struck the rule down as unreasonable, and the FDA's own page now says the term means "whatever a particular company wants it to mean."

Fifty-one years later, that is still where it sits.

Hiranput and colleagues put a number on the consequence in Clinical and Experimental Dermatology in 2024. They pulled 208 personal care products marketed as hypoallergenic from two large UK retailers and screened the ingredient lists against the British Society for Cutaneous Allergy baseline series. 73.6% contained at least one of those allergens. 10.1% contained two, 1.9% contained three, and fragrance turned up in 40.1% of them. Cetearyl alcohol was the most common offender in leave-on products; parabens led in rinse-offs.

The word had done its work on the shelf and nowhere else.

"Clean" is worse still, in the sense that there is less to argue with. No agency defines it. Each retailer writes its own exclusion list, the lists disagree, and a product can be clean at one chain and not at another without changing a single ingredient.

Tier 2: real conventions, zero enforcement

Fragrance-free is the clearest example of a term that does mean something without meaning it legally. The FDA's own guidance says plainly that it "doesn't have regulations governing the use of these terms," then describes the convention anyway: "unscented" may contain masking fragrance ingredients added to cover an unpleasant base odor, while "fragrance free" should contain no added fragrance ingredients, though the product may still smell of its raw materials.

That distinction is useful to anyone who reacts to linalool or limonene, and the better Korean brands observe it carefully.

It is also entirely voluntary.

Vegan sits in the same tier for a different reason. It describes where ingredients came from, and it is silent on whether any of them are safe or effective. A vegan formula can be loaded with limonene and linalool. Cruelty-free describes a testing policy rather than the product. EWG Verified and EWG-Green are scores from a private US non-profit, not a government finding — a distinction we should probably make more clearly on our own listings than we currently do, since exactly one of our products carries that badge.

Tier 1: the small set somebody actually checked

Korea is the interesting jurisdiction here, because it has the pre-market review the US does not. The Cosmetics Act defines a "functional cosmetic" as five statutory benefit classes, and Article 4 requires anyone selling one to undergo an examination by the Minister of Food and Drug Safety or file a report on that product's safety and effectiveness. The Enforcement Rule then breaks those five classes into 11 named categories: melanin-prevention whitening, melanin-fading whitening, wrinkle improvement, gentle tanning, UV interception and scattering, hair colour change excluding temporary, hair removal excluding physical methods, alopecia alleviation excluding physical thickening, acne relief in cleansing products only, atopic dryness alleviation, and reduction of red striae distensae.

Note the exclusions. Acne relief only counts as a reviewed claim in a cleansing product. Alopecia alleviation excludes anything that merely thickens the hair shaft. Those carve-outs are the whole point of a defined claim: they tell you the exact boundary of what was checked.

In the US the equivalent list is almost entirely sunscreen. 21 CFR 201.327 says a product may print "Broad Spectrum" only if its mean critical wavelength measures 370 nm or greater, and may state water resistance only as 40 or 80 minutes, matched to the immersion test it passed. A sunscreen that is SPF 2 to 14, or that fails broad-spectrum, must carry a Skin Cancer/Skin Aging Alert saying the product has been shown only to help prevent sunburn. That is a claim with a number and a consequence behind it, which puts it in a very small club. We went into why Korean filters behave differently from American ones in a separate piece.

The EU takes a third approach: no pre-approval, but Commission Regulation 655/2013 sets six common criteria every cosmetic claim must satisfy — legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. Evidential support requires "adequate and verifiable evidence." It is not a review board. It is a rule that says the file has to exist and has to survive being asked for.

What our screening found

The number we would rather you use instead is the screening score, which is at least reproducible: we read every INCI entry, grade it low, mid or high risk, and publish the count. Across the catalog that came to 1,696 entries, of which 153 graded mid and 8 graded high. Our Celleanser Derma Barrier P Cream scores 9.8 not because it says clean on the front but because we could not find anything in it to flag. The method is written up in full, including the parts of it we think are weak.

The practical takeaway

Read a label back to front. The INCI list is the only part of the packaging that a regulator dictates the contents of, and it is the part brands have the least freedom to shape.

If a claim has a number in it, somebody probably had to defend that number. SPF 50, 80 minutes, 370 nanometres, an MFDS review file. If it has an adjective in it, assume nobody did. And a specific negative claim beats a vague positive one every time, which is why "contains no fragrance ingredients" is worth more than "gentle" even though gentle sounds kinder.

We are keeping our free-of list, because a fragrance-allergic reader still wants to know. But we are going to say which tier each one belongs to, and we would rather you audited us than took the badge at face value. The products that got through our grading are on the awards page, with the flags we found still attached to them.