Everything You Need to Know About the FDA's AHA Labeling Guidance for Cosmetics

FDA Guidance graphic for Alpha Hydroxy Acids like glycolic acid or lactic acid.

The U.S. Food and Drug Administration (FDA) issued Guidance for Industry: Labeling for Cosmetics Containing Alpha Hydroxy Acids to help companies and consumers understand a key safety concern with products that contain alpha hydroxy acids (AHAs), such as glycolic acid and lactic acid. AHAs are widely used in cosmetics — from exfoliants and skin creams to toners and facial peels — because they help improve the appearance of skin by loosening dead skin cells. However, clinical evidence and consumer experience have shown that these acids can make the skin more sensitive to ultraviolet (UV) radiation from sunlight. This increased sensitivity can last during use and for up to one week after stopping the product.

What the Guidance Recommends

A “Sunburn Alert” on Labels

The central recommendation of the guidance is that cosmetic products containing AHAs and intended for application to the skin or mucous membranes should include a clear and visible “Sunburn Alert” on the label.

A recommended version of this warning reads:
“Sunburn Alert: This product contains an alpha hydroxy acid (AHA) that may increase your skin’s sensitivity to the sun and particularly the possibility of sunburn. Use a sunscreen, wear protective clothing, and limit sun exposure while using this product and for a week afterwards.”

This statement helps consumers understand that while the product is meant for cosmetic use, it carries a specific risk when exposed to sunlight.

When the Guidance Applies

The FDA recommends the alert for products that:

  • Contain an AHA as a non-incidental ingredient — meaning the acid is present at a level that contributes to the product’s function, not just a trace ingredient.
  • Are intended for application to areas exposed to the sun, such as the face, arms, or body — even if unintentionally (e.g., products like shampoos or deodorants that might contact exposed skin).
  • Do not contain a sunscreen — products that include sun protection are subject to different regulatory rules and aren’t covered by this specific guidance.

However, products that apply AHAs to non-sun-exposed areas (like mouthwash applied inside the mouth) are not covered by this guidance.

Not a Legal Requirement — But Important to Follow

The FDA guidance is not legally binding, meaning it is recommended rather than required by law. However, it reflects the FDA’s current thinking on consumer safety and labeling best practices. The agency notes that cosmetic labeling that fails to disclose material facts — like increased sun sensitivity — could be considered misleading under federal law.

Why This Matters to Brands and Consumers

For Consumers

If you use AHA-containing products, this guidance highlights two key takeaways:

  • Your skin may be more sensitive to the sun while using the product and for up to a week after.
  • Taking proactive sun protection steps — sunscreen, hats, and protective clothing — is crucial to help avoid sunburn.

For Manufacturers and Brands

Clear labeling is an important part of responsible product development. Though not required by law, including the recommended Sunburn Alert helps:

  • Educate customers about product effects
  • Demonstrate transparency and safety commitment
  • Avoid potential issues with the product being considered misbranded

In summary, Alpha hydroxy acids are popular and effective cosmetic ingredients, but they come with a well-documented potential for increased sun sensitivity. The FDA’s guidance empowers both consumers and manufacturers to manage that risk through clear labeling and thoughtful product instruction.

Whether you’re a skincare enthusiast or a brand owner, understanding this guidance helps ensure safe, informed use of AHA-containing products — and encourages confidence in products that are responsibly labeled. (FDA Sources)

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