Sunscreens fall under the Food and Drug Administration’s (FDA) jurisdiction as over-the-counter (OTC) drugs. This means that any SPF product, even those enhanced with botanical or cannabis-derived ingredients like CBD or hemp extract, must adhere to the FDA’s sunscreen monograph framework, now part of the “Deemed Final Order” (DFO). Under this framework, products must undergo validated SPF testing, include standardized Drug Facts labeling, and qualify for the “Broad Spectrum” designation through critical wavelength testing. Products that are not broad spectrum or have an SPF value below 15 are required to display a specific skin cancer and aging warning. Water-resistance claims are limited to “40 minutes” or “80 minutes” only if proven through FDA-recognized testing, while terms such as “waterproof,” “sweatproof,” and “sunblock” are expressly prohibited.

Currently, the FDA continues to modernize the sunscreen framework. The agency’s proposed order affirms only zinc oxide and titanium dioxide as “Generally Recognized as Safe and Effective” (GRASE) while calling for additional safety data on twelve other organic UV filters. Cannabinoids are not recognized as active sunscreen ingredients under either existing or proposed regulations. Therefore, any product suggesting that CBD or cannabis compounds serve as UV filters would require an approved New Drug Application before such claims could be legally made.

Regarding the cannabis component, the FDA clarifies that cannabis-derived ingredients in regulated products are subject to the same laws as any other ingredient. In cosmetic products such as after-sun lotions, CBD may be included if the product is not adulterated or misbranded and avoids unapproved drug claims. However, once the product is classified as an OTC drug—like sunscreen—it must meet all OTC regulatory requirements. Claims stating that CBD “repairs DNA,” “heals sun damage,” or “treats skin conditions” qualify as unapproved drug claims and are prohibited without FDA authorization.

Advertising oversight falls under the Federal Trade Commission (FTC). The FTC requires all health-related claims to be truthful, non-misleading, and supported by competent and reliable scientific evidence. The agency has repeatedly taken enforcement actions against CBD companies making unsupported therapeutic claims, highlighting that cannabis-related marketing requires strong substantiation. For SPF products, advertisers must ensure that all claims align with FDA-approved labeling and that they possess verifiable test results for SPF level, broad-spectrum protection, and water resistance.

Acceptable claims for cannabis-enhanced sunscreens generally include accurate SPF values, verified broad-spectrum designations, tested water-resistance durations, sensory descriptions (such as texture or scent), and cosmetic-level benefits like “with hemp seed oil for moisturization.” These claims must remain within the cosmetic boundary, avoiding therapeutic or medical assertions. The FDA also mandates that required warnings and Drug Facts formatting appear exactly as outlined in its regulations.

Claims that brands should avoid include “waterproof,” “sweatproof,” “sunblock,” unverified “reef-safe” language, and any statements suggesting that CBD itself provides SPF protection or cures skin ailments. Such claims either violate FDA labeling rules or constitute unsubstantiated health claims under FTC standards.