Is non-comedogenic regulated by the FDA?

No. The FDA has no legal definition for non-comedogenic, so a brand can use the word without doing any clinical testing at all. It sits in the same drawer as fragrance-free and unscented: descriptive marketing language rather than a claim anyone has to substantiate.

Are comedogenic ratings reliable?

Not reliably enough to shop by. A 2025 review in JAAD Reviews found the ratings unstandardised and inconsistent when applied to human skin, and identified the core methodological problem: the tests measure isolated ingredients at high concentration, which is not how anyone uses a finished product. Coconut oil rated 4 tells you almost nothing about a moisturiser that contains a little of it.

What Does Non-Comedogenic Mean? Legally, Nothing (2026)

Q: What does non-comedogenic mean?

Legally, nothing. There is no regulated definition, no required test, and no authority checking. Any brand can print it on any product.

Q: Where do comedogenic ratings come from?

A rabbit. After Kligman and Mills described acne cosmetica in 1972, researchers needed a fast screen for pore-clogging potential, and the rabbit ear assay became the standard. A substance is applied to the inner ear of an albino rabbit, often under occlusion, once or several times a week for two to four weeks, and the skin is then examined for comedones. The 0 to 5 scale circulating on the internet descends from that method.

The word has no definition

Start here, because everything else follows from it. The FDA has no legal definition for "non-comedogenic". A brand can put it on a jar without running a single test, and no rule is broken.

It sits in the same drawer as "fragrance-free", "unscented", "dermatologist tested" and "clinically proven". Those are descriptive phrases, not substantiated claims. Some brands behind them have done real work. Some have done none. The word on the front is identical either way, which is precisely why it is on the front.

The ratings came from a rabbit

The 0 to 5 comedogenic scale that circulates in every acne forum has an origin, and it is not a human study.

After Kligman and Mills described acne cosmetica in 1972, researchers needed a fast way to screen ingredients for pore-clogging potential. The rabbit ear assay became the standard. A substance is applied to the inner ear of an albino rabbit, often under occlusion to push it into the follicle, once or several times a week for two to four weeks. The skin is then examined visually and under a microscope for comedones.

As a screening tool in 1972 that was a sensible piece of science. As the basis for deciding whether a moisturiser will break out your face in 2026, it is being asked to carry weight it was never built for.

Why it does not transfer

A 2025 review in JAAD Reviews went through the literature and found the ratings unstandardised and inconsistent when applied to human skin. Rabbit ear results, it notes, repeatedly failed to reproduce on people.

The methodological problem underneath is the one that matters at the shelf: the tests measure isolated ingredients at high concentration, and nobody uses skincare that way. You use a finished formula in which that ingredient might be 2 percent, buffered by everything else in the jar.

"Coconut oil is a 4" tells you almost nothing about a moisturiser that contains a little coconut oil. The number was measured on a different thing.

Which is why the ingredient blacklists built on those ratings are worse than the assay they came from. They inherit every flaw and add false precision on top, and they will happily tell you to avoid a product over an ingredient sitting below the preservative.

What to read instead

None of this means pore-clogging is imaginary. It means the shortcut does not work, and the longer route is not that long.

Read the formula, not the front. Heavy occlusives and rich butters high on the list behave differently from the same ingredients in trace amounts near the bottom. Position is the part of the label that is legally required to be honest.
Trust your own history over a chart. If a product has reliably caused you problems, that single data point is about you, which is more than any rating can say. Comedogenicity varies enormously between people.
Change one thing at a time. Four new products at once and a breakout tells you nothing. It is slower and it is the only version that produces an answer.
Separate the claims. "Non-comedogenic" is unregulated. Fragrance allergens, by contrast, now have to be named on EU labels above a set threshold. One of those claims has law behind it and one does not.
Take real acne to a dermatologist. Persistent or painful breakouts are a medical question with medical answers. No label reading, and no app, replaces that.

Sus grades the formula, not the buzzword

Sus does not read "non-comedogenic" off the front of the box and pass it on to you, because that word has not earned it. It reads the actual ingredient list, checks it against a bank of around 51,000 ingredients, shows you what is in there and in what order, and grades the product against your Skin ID rather than against skin in general. Set your profile to acne-prone and the same bottle gets a different verdict than it gives someone with dry skin, because it should.

What it will never do is promise you a product will not break you out. Nobody can promise that, and any app that does is selling you the same kind of word this page is about.

Download Sus on the App Store

Free for iPhone. Your first 3 scans are on us, no sign-up. Sus is a cosmetics tool for informational purposes. It does not diagnose or treat anything.