Summary: A marketing term used to indicate that a product is unlikely to clog pores, though the term is not legally defined or regulated.
"Non-comedogenic" refers to products or ingredients that are formulated to minimize the likelihood of blocking pores and contributing to comedone formation, which can lead to acne. The claim suggests that the product should have a low tendency to trigger breakouts, but the term itself is not legally defined or regulated. Neither EU Regulation (EC) No 1223/2009 nor US FDA regulations provide a formal definition or standard for "non-comedogenic" claims. Brands are free to use the term based on their own testing, formulation philosophy, or ingredient selection, though advertising laws generally require that claims are not misleading.
Comedogenic Ratings and Origins
The idea of "non-comedogenic" products is historically linked to comedogenic ratings, which are informal scales (typically from 0 to 5) that attempt to indicate the pore-clogging potential of individual ingredients:
| Rating | Interpretation |
|---|---|
| 0 | Will not clog pores |
| 1 | Very low likelihood |
| 2 | Low likelihood |
| 3 | Moderate likelihood |
| 4 | Fairly high likelihood |
| 5 | High likelihood |
These ratings originated in the 1970s and 1980s, when Dr. James E. Fulton and colleagues developed the rabbit ear assay, applying cosmetic ingredients to rabbit ears and grading the degree of comedone formation. Their findings were published in:
Fulton, J.E., Pay, S.R., & Fulton, J.E. (1984). Comedogenicity of current therapeutic products, cosmetics, and ingredients in the rabbit ear. Journal of the American Academy of Dermatology, 10(1), 96–105. https://www.sciencedirect.com/science/article/abs/pii/S019096228480050X
While widely adopted at the time, the rabbit ear model has since been recognized as imperfect and poorly predictive of human skin responses, especially in well-formulated products. Human skin is less sensitive than rabbit skin, and the context of the entire product formula significantly affects whether an ingredient will clog pores. Today, comedogenic ratings are still cited as rough guidance, but they are regarded as approximate and not definitive. Actual comedogenicity depends on the formulation, concentration, skin type, and individual factors.
Regulatory status
"Non-comedogenic" remains a marketing term:
- It is not legally defined or standardized.
- Brands are not required to perform testing or meet specific criteria to use this claim.
- Some brands substantiate the claim using ingredient selection (avoiding ingredients with higher comedogenic ratings), optional in vitro or clinical testing, or by formulating in a way that is commonly used for products intended for acne-prone or sensitive skin.