FDA Sunscreen Regulations 2023

Back in 2021, FDA reclassified most of the approved sunscreen ingredients.

In fact, they reclassified every single one of the approved chemical sunscreens removing the GRASE status from these ingredients.

What's GRASE?  It stands for:

  • Generally
  • Recognized
  • As
  • Safe and
  • Effective

In fact, 2 of the 14 chemical sunscreen ingredients lost their status altogether (deemed not safe and effective for use). 


For the other 12 chemical sunscreens, burden is now on manufacturers to prove their products that contain these ingredients are safe before they're sold on the market*.  


*this legislation/regulation still isn't enforced yet... 2 years after the reclassification.


Why would FDA reclassify these ingredients?


Well, for 2 reasons.  Let's talk about the biggest reason first.


There's a safety concern for all 14 of the approved chemical sunscreen ingredients.


At least 4 of these ingredients are endocrine disrupting.


(These 4 endocrine disruptors are in the list of ingredients that's still considered by FDA to be okay for use as long as manufacturers demonstrate the ingredient isn't absorbed "too much" by your skin into your bloodstream.)


Which leads to the second reason (and will answer a question you might already be wondering about)... why the heck did FDA approve these ingredients in the 1st place if they're endocrine disrupting?


Here's the thing... sunscreen ingredients are intended to sit on top of your skin.


And, when they're sitting on top of your skin, the way that the chemical sunscreens protect your body's cells from UV rays is by reacting with the UV ray to form:

  • heat
  • free radicals


And, yes, these are the very same free radicals that do tons of damage to your body's cells and DNA, but when they're generated on the surface of your skin, it's considered no big deal because the surface of your skin is dead skin cells


(technically, it's an acid mantle composed of beneficial bacteria... i.e. your skin microbiome, but hey, let's not pretend we're not killing our beneficial microbiome here with the free radicals and extra heat 🙂)


so, what's dead is dead and it really doesn't matter if you generate a bunch of free radicals on the surface of your skin because it isn't going to hurt those dead skin cells.


One more thing... roughly half of the 14 approved chemical sunscreens were approved by FDA back in 1978 when regulations were much different from today and it was easier to demonstrate safety and efficacy because we didn't know about endocrine disruptors the way we do today, so back then, a lot of attention was paid to things like skin sensitivity and phototoxicity.


But, I digress.  What's happened over the past 20+ years is that there's been a substantial amount of studies conducted evaluating whether sunscreen ingredients really sit on the surface of your skin.


Turn's out?  They don't.  They get absorbed into your skin and into your bloodstream.


A few years ago, FDA found the scientific literature lacking for one specific sunscreen ingredient, avobenzone.


So, FDA took it upon themselves to conduct a study on this ingredient.  They evaluated 4 different products containing avobenzone (an aerosol, a lotion, and 2 other kinds of spray) and for every single formula, the amount of avobenzone found in the bloodstream of the participants in this study was above the threshold set by FDA.


And, this isn't the only study FDA themselves conducted.


In another study conducted by FDA evaluating:

  • avobenzone
  • oxybenzone
  • octocrylene
  • homosalate
  • octisalate
  • octinoxate

it was found all of these ingredients were in the bloodstream at levels higher than allowed by FDA.


One more thing?


The formulation matters on how much of the ingredient gets absorbed, and this may be why there's so much talk right now about whether it's safe to layer sunscreens.


By layering sunscreens, you're increasing:

  • the concentration of these chemical sunscreens on your skin (which increases the amount that's absorbed into your bloodstream) and
  • the likelihood that absorption is increased especially if a lotion or a cream sunscreen is layered with spray sunscreens

Alright, we've arrived at the best question... how are you supposed to protect your skin safely from sun exposure?


  1. Well, the two ingredients still regarded as GRASE by FDA are titanium dioxide and zinc oxide.  These are physical sunscreens aka sun blocks aka mineral sunscreens, which are supposed to act as a mirror, reflecting UV rays back off your skin.

    Zinc oxide and titanium dioxide don't dissolve in water or oil, and this means that in products the particles of zinc oxide and titanium dioxide are suspended in the product and when applied to your skin form a physical barrier on the surface of your skin that reflects sun rays back off your skin.

    There's great debate on whether these 2 sunscreens are absorbed into your skin, so choose non-nano or non-micronized sunscreens that only contain zinc oxide and/or titanium dioxide as the active ingredients (look for the active ingredients box on the back of the bottle just above the ingredients list).

  2. Use clothing and shade as your friend.  You don't need to break the bank buying UPF clothing, any clothing is sun protective.  Wear clothes and a hat when you're in sunlight.

  3. Practice moderation.  The thing people hate most 🙂  If you haven't seen sunlight in 3 months, don't spend 6 hours in the water on day 1.  Okay, I'm going to move on now so I don't sound preachy 😊

What happens when you get too much sun exposure?

Here's how to support your skin after too much sun exposure:


  1. Apply cucumber slices to your skin. 

  2. Blend up a whole cucumber in a blender with 2 cups water and slather that all over your body and leave on 5 to 10 minutes before you shower.
  3. Make a cucumber tea (cucumber spa water) by infusing cool water with cucumber slices packaging in a spray bottle and misting as needed.
  4. For 1, 2, and 3, substitute any of the following:

    1. aloe (find the whole leaf at most grocery stores and be sure to use only the inner pulp avoiding the yellow layer and the outer peel)
    2. roses/rose petals
    3. hibiscus petals

  5. Take cooler showers.

  6. Avoid the sun as much as possible for the day (or 3) after you overdid it.

  7. Up your intake of antioxidant rich foods.  Your skin receives nourishment from your body as well as topically, so up your intake of vitamin C rich foods (mangos and other colorful fruits and berries) and cooling foods (like mint and cucumber 😊)

  8. Drink some tea, especially green or white tea, which offer anti-oxidant benefits without the caffeine (which can prolong recovery times by constricting blood vessels).


And, rest assured with this... your body needs sunlight. 


For extra support for sun weary skin, pick up Rain Organica's Marine Layer Mist, an antioxidant spray with vitamin C, cucumber & rose hydrosols plus 3 skin restorative peptides to promote recovery post-sun exposure.






Brandy Searcy founder Rain Organica

About the Author

Brandy's a formulation scientist and self-proclaimed health geek who loves hiking, gardening, bird-watching, and body boarding. 

Her struggle with acne during her teens and 20s led to a holistic and healthy approach to skincare, embracing skin as an organ to be loved and cared for rather than a canvas to wage war on. 

Since 2008, she's been developing all-in-one products for a simple routine at home, & Rain Organica started when her backpacking friends asked for a portable skincare routine to keep their skin healthy & happy on and off the trails.

You can try Rain Organica for yourself with The Essentials Kit, a complete skincare routine in just 3 steps.

Brandy's LinkedIn Bio

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