How the SAFE Sunscreen Act Could Change FDA Compliance

How the SAFE Sunscreen Act Could Change FDA Compliance
Andrew Parshad
President & Founder of Quality Smart Solutions

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FDA compliance for OTC sunscreen ingredients under SAFE Sunscreen Standards Act

Sunscreen compliance in the U.S. may be on the edge of its most significant update in over two decades. On June 3, 2025, lawmakers introduced the SAFE Sunscreen Standards Act (H.R.3686), a bipartisan bill that aims to modernize how the FDA reviews and approves sunscreen active ingredients. 

This matters because no new sunscreen ingredients have been approved by the FDA since 1999. If you manufacture, import, or label sunscreen products, this could shift how quickly and effectively your products enter the U.S. market. Keep reading to find out what this means for your business and how you can prepare. 

What is the SAFE Sunscreen Standards Act? 

The SAFE Sunscreen Standards Act, short for Supporting Accessible, Flexible, and Effective Sunscreen Standards, was introduced in the House of Representatives by Representatives Dr. John Joyce, Debbie Dingell, Dave Joyce, and Deborah Ross. The bill proposes amendments to the Federal Food, Drug, and Cosmetic Act to improve how sunscreen active ingredients are reviewed and approved. 

This legislation was introduced in response to mounting concerns that current FDA regulations are outdated and restrictive. Because sunscreens are classified as over-the-counter (OTC) drugs in the U.S., any new UV filter must undergo a lengthy New Drug Application (NDA) process, which often takes years. This has prevented innovative and globally recognized ingredients from entering the market. 

As a result, many promising ingredients remain stuck in regulatory limbo, while some ingredients currently in use have not been fully assessed for safety. The bill aims to fix this by creating a faster, more transparent review process that still prioritizes public health and safety. 

Key provisions of the SAFE Sunscreen Standards Act 

The U.S. currently allows only 16 active sunscreen ingredients, while regions like the EU permit more than 30. Many globally accepted ingredients remain stuck in FDA limbo, leaving companies with limited options and longer timelines. So, here’s what the bill proposes: 

  • A streamlined pathway for reviewing and approving sunscreen active ingredients. 
  • An emphasis on non-animal testing methods, supporting alternative evidence models. 
  • A requirement for the FDA to deliver a formal report to Congress on its progress implementing new testing standards. 

If passed, this legislation would remove long-standing regulatory bottlenecks and improve sunscreen ingredient compliance in the U.S. market. 

Why this matters for sunscreen compliance 

For businesses looking to enter or expand in the U.S. OTC market, sunscreen compliance is a critical barrier. Products containing active ingredients not currently approved by the FDA are classified as unapproved new drugs, making them subject to warning letters, import refusals, or recalls. 

The new bill could bring several important changes. It may lead to faster ingredient approvals, particularly for companies using internationally recognized sunscreen actives.  

Additionally, if the FDA begins accepting more alternative testing methods, businesses could benefit from reduced costs and quicker product registration timelines.  

The requirement for a formal Congressional report may also encourage greater transparency and predictability in the approval process, supporting more confident planning for product launches. 

What sunscreen brands and manufacturers should do next 

Although the SAFE Sunscreen Standards Act is not yet law, it’s a strong signal that regulatory change is on the horizon. Companies operating in the OTC space should start evaluating how these changes could impact their portfolio. Some actions you can take now include: 

  • Reviewing your current ingredients and formulations for FDA alignment. 
  • Assessing your product claims and labels to ensure full FDA and OTC drug monograph compliance. 
  • Consulting regulatory experts to help you navigate pre-market pathways if your ingredients are not currently monograph-listed. Our team at QSS can guide you through these steps and keep you updated as the legislation progresses. 

FAQ: SAFE Sunscreen Standards Act

Is the SAFE Sunscreen Standards Act in effect now?

No. As of July 2025, the bill has only been introduced and is not yet law. 

Not immediately. However, if passed, it may affect how new ingredients are added or approved moving forward.

Yes. If enacted, it could allow for more flexibility and faster approvals for products that already meet standards in other regions.

No immediate action is required, but it’s smart to start evaluating your product pipeline and testing strategies now, especially if you plan to introduce non-monograph ingredients in the near future.

Stay compliant and ahead of regulatory change 

At Quality Smart Solutions, we specialize in helping OTC and cosmetic companies navigate FDA compliance, labelling regulations, and ingredient approvals. Whether you’re planning to launch a new sunscreen product or reformulate to meet new standards, our regulatory experts can help. 

Visit our Contact Us page to schedule a free consultation and learn how we can support your compliance journey.  

You can also explore our OTC Drug Compliance services to learn more about how we help businesses like yours meet FDA requirements and streamline your regulatory process. 

 

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Andrew Parshad
Andrew Parshad is President, CEO and founder of Quality Smart Solutions, a North American compliance solutions provider offering regulatory and quality assurance services to comply with FDA & Health Canada brands and ingredients regulations in the categories of dietary supplements, foods, cosmetics, OTC drugs and medical devices. Andrew started Quality Smart Solutions in 2007. Since that time he and his firm has served thousands of clients worldwide . Andrew's affiliate company, Quality IMPORT Solutions that offers import agent services into the Canadian market as a government licensed importer for foods, dietary supplements and medical devices.
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