Regulatory Standards Guiding Marijuana Skincare Products

In the evolving world of cannabis skincare, marijuana face cleansers are gaining consumer attention — but so are the regulations that govern them. While marketing and formulation flexibility exist, these products fall under a growing web of federal and state oversight designed to ensure product safety and truthful labeling.

At the federal level, cosmetics — including cannabis-infused face cleansers — are regulated under the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). MoCRA expanded the FDA’s authority over cosmetic products, requiring facility registration, product listing, safety substantiation, and adverse event reporting. It also allows for records access and recall authority. For marijuana cleansers, this means meeting the same requirements as other skincare products to ensure that ingredients are safe and products are not adulterated or misbranded.

Currently, the FDA has not issued cannabis-specific ingredient prohibitions for cosmetic formulations. However, the agency draws a firm line between cosmetics and drugs. If a marijuana cleanser claims to treat conditions such as acne, inflammation, or eczema, it may be classified as a drug, triggering much stricter pre-market approval processes. Brands are therefore advised to make purely cosmetic claims — such as cleansing, moisturizing, or enhancing appearance — and ensure that all ingredients used have a demonstrated safety profile.

The FDA’s ongoing review of cannabinoids such as CBD also adds complexity. While CBD is not allowed as an ingredient in foods or dietary supplements, it may appear in cosmetics provided the product complies with general cosmetic laws. Manufacturers are expected to ensure ingredient purity, proper labeling, and truthful marketing while avoiding any medical or therapeutic claims.

The Federal Trade Commission (FTC) plays a complementary role by regulating advertising. It requires that all product claims — including those about effectiveness or benefits — be truthful, non-misleading, and backed by competent scientific evidence. Several enforcement actions have targeted unsubstantiated claims in the CBD sector, emphasizing the need for credible documentation and laboratory validation.

For products that contain THC or are derived from marijuana rather than hemp, state-level regulations apply. These items cannot move across state lines and must be produced and sold within state-licensed cannabis systems. For example, states like California and Colorado have established limits on THC potency in topicals, along with strict testing, labeling, and packaging rules. Each state may also set its own requirements for contaminants, residual solvents, pesticides, and heavy metals — all of which must be verified through certified testing facilities.

In summary, marijuana face cleansers sit at the intersection of cosmetic, cannabis, and advertising law. To remain compliant, brands must follow MoCRA’s safety and registration rules, substantiate any claims to FTC standards, verify ingredient integrity, and, where applicable, adhere to state cannabis testing and labeling laws. These steps not only reduce legal risks but also help build consumer trust in a rapidly expanding category.