EWG’S LICENSING CRITERIAPERSONAL CARE PRODUCTS
EWG’s science team has developed a set of strict criteria for all products that bear the EWG VERIFIED™ mark,which demonstrates that a product meets our highest standards for health, as outlined below.

PERSONAL CARE
PRODUCT CRITERIA
Products bearing the EWG VERIFIED™ licensed markmeet all the following criteria.

1) 	Products must fall into one of 		the EWG personal care productcategories approved for licensing.
EWG will license only those personal care productsthat fall into one of the following categories.
I. 	B aby products: baby bubble bath, diaper cream,
lotion, oil, shampoo, soap, toothpaste, wipes
II. 	H air products: conditioner, detangler, gel,hair color, hair spray, hair removal wax, 		mousse, shampoo
III. 	Makeup: BB/CC cream, blush, bronzer/
highlighter, body art, brow liner, concealer,eyeliner, eye shadow, facial powder, foundation,
glitter, lip balm, lip balm with SPF, lip gloss,
lip liner, lip plumper, lipstick, mascara, makeup
remover, makeup remover wipes
IV. 	Nail products: cuticle products, nail polish, nailpolish remover, nail products
V. 	S kin products: aftershave, after-sun products,
antiperspirants and deodorants, anti-aging
products, around-eye creams, bath oils/salts/
soaks, body-cleansing wipes, body-firming
lotion, body powder, body oil, body wash/
cleanser, bubble bath, callus products, exfoliant/scrub, facial cleanser, facial-cleansing wipes,
facial moisturizer, foot cleanser, hand cream,
hand sanitizer, liquid and bar soaps, lotion,
masks, moisturizer, moisturizer with SPF, oilcontroller, redness products, scar products,
shaving cream, toner/astringent

VII. 	Other: body spray, foot odor control, fragrance,
muscle/joint soreness, vapor rub
VIII. 	Sunscreens: baby and kid sunscreens,recreational sunscreens.
NOTE: Concentrated and mix-in products are eligible
for the EWG VERIFIED program, but they must meet thecriteria as sold.

Personal care product categories that are noteligible for EWG licensing include:
I. 	Medical and semi-medical products, including
any product making claims of a medical nature:acne treatment, wound treatment, hormonalcream, pain relief, anti-fungal treatment,anti-itch/rash cream, athlete’s foot treatment,eczema/damaged skin treatment, hemorrhoids,
denture care, contact lens all-in-one clean andrinse, contact lens cleaners, contact lens saline
solution, eye drops/artificial tears, eye drops/
artificial tears for contacts, eye wash, hair loss
treatment, lice treatment shampoo, ear wax
removal, oral pain relief, wart removal, 		
cradle cap treatment, nipple cream, “personal
cleansing,” genital moisturizer, genital powder/deodorant, lubricant/spermicide, hair growth
inhibitor, hair growth treatment/stimulant,
varicose/spider vein treatment, bandages, dental
floss, pore strips
II. 	C ategories of products that tend to be caustic
or harsh, such as skin fading/lightener, chemical
depilatory, hair straighteners (hair relaxer, hairperm), baby powder, facial hair bleach, chemical
peel, sunless tanning products, tanning oils
III. 	S ome categories of products with healthconcerns, such as eyelash glue and nail glue

VI. 	O ral care products: breath freshener, 		mouthwash, toothpaste

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IV. 	A erosols of any kind, because of respiratory
concerns. For purposes of this program, aerosol
products are those that are pressurized, throughthe use of a propellent or mechanical force,to dispense product. This definition of aerosol
does not include pump spray products
V. 	P roduct types not eligible for inclusion
in Skin Deep® (for more details, see
ewg.org/skindeep/learn_more/about ).

2) 	P roducts must rate “Green”
in Skin Deep.
EWG will license only products that pose few potential
health hazards and receive a hazard rating in the“Green” range of EWG’s Skin Deep database. Products
in Skin Deep are rated 1 to 10, with 1 being the best and10, the worst. In Skin Deep, products that rate “Green”
are those that receive either a 1 or a 2. A product’s
hazard rating is not an average of the ingredients’hazard ratings. It is calculated using a weight-ofevidence approach that factors in all of the hazards
or health impacts associated with the ingredients.
Although many of the ingredients in Green-rated
products have low hazard ratings and rate in the Greenrange, it is not a criterion that all ingredients within alicensed product rate Green.
EWG also rates sunscreens with hazard ratings but
uses additional sunscreen-specific factors and modeled
product efficacy to evaluate these products. Only
products rated Green in EWG’s Guide to Sunscreens
qualify for licensing.

Sunscreen efficacy is determined through ananalysis of four contributing factors:

EWG has given more weight to factors that raise
particular concerns for sunscreens. EWG VERIFIED
sunscreens may not:I. 	B e in an aerosol or powder form, given thepotential for inhalation
II. Have an SPF value below 15 or higher than 50+
III. 	H ave predicted UV protection much lower thanits SPF value would indicate
IV. 	Include a banned FDA sunscreen marketing claimon the label, such as the word “sunblock.”
Although a cosmetic company pursuing EWG
VERIFIED is not required to make products available
to consumers in the U.S., the company must comply
with all Food and Drug Administration cosmetics
regulations applicable to products sold in the U.S.,
including, but not limited to, the use of U.S.-allowed
active ingredients and appropriate FDA-requiredlabeling language and Drug Facts label for productcategories that are regulated as over-the-counter,or OTC drugs. For any product whose label is ina language other than English, the company shallbe responsible for translation fees through EWG’stranslation service of choice for the ingredient label
and, if applicable, Drug Facts label.
For more information on FDA regulation of cosmetics, see:fda.gov/cosmetics/cosmetics-guidanceregulation/cosmetics-laws-regulations.

For more information on FDA- required Drug Facts label, see:fda.gov/drugs/information-consumers-and-patientsdrugs/otc-drug-facts-label.

I. 	E xpected ultraviolet B, or UVB, protection, orlabeled SPF
II. Modeled ultraviolet A, or UVA, protection
III. 	The balance of modeled UVA protection to labeled
SPF, or UVB protection
IV. Sunscreen stability.

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3) 	P roducts cannot contain any 		ingredients on EWG’s list of
unacceptable ingredients.
EWG’s list of unacceptable ingredients includes:I. 	C ertain ingredients with health, ecotoxicity and/or contamination concerns
II. 	S ubstances falling within any of the following
categories because of scientific safety 		evaluations (with certain limited exceptions):• 	C osmetic ingredients banned by Health
Canada, appearing on the Cosmetics 		
Ingredient Hotlist• 	I ngredients designated as banned in theEuropean Commission’s database of 		
cosmetic substances, CosIng• 	Chemicals on California’s Proposition 65 listof known carcinogens and reproductive toxins• 	S ubstances classified by the International
Agency for Research on Cancer as known,
probable and possible carcinogens(categories 1, 2A and 2B)• 	Substances listed in the National Toxicology
Program’s Report on Carcinogens (reasonably
anticipated and known human carcinogens)• 	Substances classified by the EPA’s IRIS
program as “carcinogenic to humans,”“likely to be carcinogenic to humans,”or having suggestive evidence of
carcinogenic potential• 	I ngredients the FDA does not allow for use
in cosmetics• 	Fragrance chemicals prohibited by the 		International Fragrance Association• 	M ineral pigments not allowed for use as
colorants by the FDA, Health Canada and/or
the EU• EU Category 1–designated endocrine disruptors• 	S ubstances that fall under the EU’s Globally
Harmonized System hazard codes H340-362(hazard codes for genotoxicity, cancer anddevelopmental/ reproductive endpoints)• 	S ubstances designated as sensitizing
asthmagens by the Association of
Occupational and Environmental Clinics(applies only to products that are powders
or sprays).

4) 	P roducts with ingredientson EWG’s list of restricted
ingredients must meet the 		
restrictions set by authoritative
bodies, industry institutions
and EWG.
EWG’s list of restricted ingredients includes cosmetics
ingredients that have been restricted by national andinternational governments, authoritative bodies, andcertain cosmetics and fragrance industry institutions.
The restrictions include, but are not limited to,acceptable product-use categories, concentration limits
and contamination restrictions established by thefollowing groups:
I. FDA
II. EU (as listed in the CosIng database);
III. 	H ealth Canada (as listed in the Cosmetic 		
Ingredient Hotlist)
IV. Japan’s Ministry of Health, Labour and Welfare
V. 	Personal Care Products Council’s Cosmetics
Ingredient Review
VI. International Fragrance Association
VII. Research Institute for Fragrance Materials.

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Should the guidance of authoritative bodies conflict,
EWG shall use the most health-protective limit. In lieu
of established restrictions for ingredients that EWG
determines to be of concern, additional restrictions or
prohibitions may be put in place based upon review of
the available science and best professional judgment.

5) 	P roducts must follow standard
ingredient naming guidelines.
I. 	Each ingredient name should be listed using
International Nomenclature for Cosmetics
Ingredients, or INCI, labeling guidelines, as
found in the most recent edition of the 		International Cosmetics Ingredient Dictionary
and Handbook.
II. 	M ixtures must be listed by their component
INCI names. For example, the mixture “Geogard
Ultra” must be listed as “Gluconolactone,
Sodium Benzoate.” No reference to trademark
ingredient mixtures may appear in the 		
ingredient list.
III. 	If INCI names are not available, ingredients mustbe listed using a unique chemical name.
(Note: Trade names and registered trademark
names will not be allowed.)
IV. 	A ll botanicals must include the scientific namefollowed by the chemical modification, such as
extract or oil. A company may decide whether
it will also list the common name. The generalnaming structure should be as follows:6) 	Products must fully disclose all
ingredients, including ingredientsused in fragrance and flavor 		
mixtures and chemicals used tocoat mineral ingredients.
EWG will license only those products that fully
disclose their ingredients. This provision includes,
but is not limited to, complete disclosure of fragrance
and flavor mixtures, as well as chemicals used to coatmineral ingredients and non-chemical materials or
substrates, such as wipes. For the purposes of thisagreement, an ingredient is any substance used in the
preparation of the product that is still present in the
final commercial product.
For fragrance and flavor mixtures, all ingredients aboveand below 100 parts per million, or ppm (or 0.01% of
the final product) must be disclosed to EWG. Only
those ingredients above 100 ppm must be listed on the
product package. If the mixture comprises more than
five ingredients above 100 ppm, the company must
include either of the following on the product’s package:
I. A fully disclosed ingredient list
II. 	T he term “fragrance” or “flavor” followed byan asterisk or equivalent, as well as an asterisk
directly beneath the ingredient list preceding
the first five ingredients in the mixture, basedon concentration, and instructions on where tofind the fully disclosed list of ingredients online.
(See example below for details on placement
and wording.)		[Botanical name] [(Common name), optional][Name of relevant plant part, such as leaf or stem,
if applicable] [Chemical modification]

		
Example of product ingredient list

		 For example, Aloe Barbadensis (Aloe Vera) Leaf Extract		* Fragrance ingredients include: Citrus Paradisi(Grapefruit) Extract, Citrus Limon (Lemon) 		
Extract, Lavandula Angustifolia (Lavender) Extract,
Camellia Sinensis (Green Tea) Extract, Mentha
Piperita (Peppermint) Leaf Extract, and others(See full fragrance ingredient list on company website)		Ingredients: Water, Butyrospermum Parkii (Shea)
Butter, Fragrance,* Tocopherol.

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In either case, the company must include theirdisclosed ingredient list, including at least theirfragrance or flavor ingredients at or above 100 ppm,
in Skin Deep and on the company’s website.
To allow companies to protect confidential businessinformation about the product and fragrance
formulation, EWG does not require disclosure of
the weight or amount of an intentionally added
ingredient outside of certifications necessary to satisfy
concentration restrictions.
NOTE: EWG reserves the right to perform random
product testing, including through qualified third-party
testing services, to ensure that products fully disclose all
ingredients on the label. 		

7) 	P roducts must disclose all 		fragrance allergens required on
personal care product labels in
the EU.
The EU requires companies to indicate the presence of
26 fragrance allergens in the list of ingredients whenconcentrations exceed 0.01% in rinse-off products
and 0.001% in leave-on products, whether or not they
were added directly as an ingredient or are present as acomponent of a fragrance ingredient. The allergens andtheir CAS numbers are attached in Appendix I.
EWG requires that companies list fragrance allergens
meeting the EU criteria above at the end of theiringredient lists on the product package. If fragrance
allergens are dispersed throughout the ingredient
list rather than listed at the end, they must be clearly
identified with an asterisk or similar symbol indicatingthat the allergen is a component of the parent ingredient.
Companies may choose to indicate these allergens on
the product package and/or on the product webpage. If
companies choose to list the allergens solely on theirwebsite, they must also indicate on the product package
the specific ingredients that have the relevant allergenic
components with an asterisk or similar symbol andinclude a phrase at the end of the ingredient list thatpoints to the website for the full list of allergens.

NOTE: if the EU’s requirements for labeling fragrance
allergens change (for instance, if more allergens are added totheir list), EWG’s licensing criteria will change accordingly.

8) 	P roducts must follow EU labelingguidelines for nanomaterials
used in cosmetics.
EWG requires that all licensed cosmetics products
follow the EU 2009 labeling guidelines fornanomaterials in cosmetics, provided that any claims
about nanomaterials are properly substantiatedand comply with any applicable FDA regulations
for cosmetics. For the purposes of this agreement,
we refer to the EU’s 2011 recommended definition:“‘Nanomaterial’ means a natural, incidental or
manufactured material containing particles, in an
unbound state or as an aggregate or as an agglomerate
and where, for 50% or more of the particles in thenumber size distribution, one or more external
dimensions is in the size range 1 nm-100 nm.”
Manufacturers using ingredients that meet the 2011 EU
definition of nanomaterials in their product(s) must
include these ingredients on the product’s ingredientlist. The names of such ingredients should be followedby the word “nano” in parentheses.
For more information on the EU’s guideline fornanomaterials in cosmetics products, see:health.ec.europa.eu/system/files/2020-10/
sccs_o_233_0.pdf

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9) 	P roduct labels must show an 		
expiration date or a “period oftime after opening.”
EWG requires licensed products to address the
product’s shelf stability by including one of thefollowing pieces of information on the label:
I. An expiration date for products
II. 	T he period of time a product may be used after
opening without any harm to the consumer.
This “period of time after opening” must be
indicated on products with a shelf life of 30
months or more.

10) 	P roduct manufacturers must
develop, document andfollow current good
manufacturing practices.
EWG requires that licensed companies develop,
document and follow a program of good manufacturing
practices, in line with FDA Guidance for Industry:
Cosmetic Good Manufacturing Practices.
These practices include but are not limited to:
I. Maintaining documentation and records
II. 	A ssessing the suitability of buildings, facilities
and equipment
III. Maintaining adequate filth and pest controls
IV. Assessing raw materials

For more information on the FDA’s Guidance for Industry:
Cosmetic Good Manufacturing Practices see:fda.gov/cosmetics/cosmetics-guidancedocuments/good-manufacturing-practice-gmpguidelinesinspection-checklist-cosmetics.

11) 	Products must pass basic 		
microbial challenge tests andrepeat these tests as appropriate.
EWG will license only products that have:I. 	S pecified to EWG which ingredients, if any, areintended as preservatives
II. 	Passed microbial challenge tests for the finishedproduct (current formulation). (Refer to U.S.
Pharmacopoeia Antimicrobial Effectiveness
Testing, or USP 51, for relevant challenge test).
Companies must also have protocols in place
to repeat microbial challenge tests if/when the
product formulation, manufacturing process
or packaging change. Companies must provide
evidence of anhydrous formulations,when applicable.
In keeping with ISO 29621, products with thefollowing characteristics are considered low-risk for
microbial contamination and are therefore exempt
from this criterion:
Physico-chemical characteristics
or product components
pH

V. Establishing standard operating procedures,		 or SOPs
VI. Evaluation laboratory controls
VII. 	R eviewing and documenting product complaints,
adverse event reports and voluntary recalls.
Products that offer UV protection must also follow the
FDA good manufacturing practices for SPF products.

Ethanol or other alcohol

Limits
< 3.0 or > 10.0
> 20%

Filling temperature> 65.0 °C

Water activity (aw)

< 0.75 a

Solvent-based products
Oxidizing products
Aluminium chlorohydrate

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> 25%

ADDITIONAL
CRITERIA FOR EWGLICENSED COMPANIESe. a congenital anomaly or birth defectCompanies with products licensed by EWG must
agree to all of the following:

For more details on serious adverse events, see:f. 	d isfigurement, including serious or persistentrashes, papules, desquamation, erythema,
and infections.

fda.gov/safety/medwatch-fda-safety-informationand-adverse-event-reporting-program.

i. 	Companies must commit to 		
submitting all reports of productproblems or serious adverse
events to the FDA and to EWG,
with all personally identifiable
information, such as names andaddresses, redacted fromsuch reports.
EWG requires companies with licensed products tosubmit all reports of product problems or serious adverse
events resulting from the use of any of the company’s
products to the FDA through the MedWatch site
(fda.gov/Safety/MedWatch/). Companies should also
submit those reports, with all personally identifiable
information redacted from such reports, to EWG.
Product problems include but are not limited to:a. product contaminationb. questionable stabilityc. labeling concerns.
For the FDA definition of product problems and relevant
examples, see: fda.gov/safety/reporting-seriousproblems-fda/product-problems

Serious adverse events include:
a. deathb. a life-threatening eventc. hospitalizationd. a disability or permanent damageii. 	C ompanies must acknowledge
that EWG’s lists of unacceptable
and restricted ingredients will be
reviewed annually and updated
as needed. A phase-in period will
be provided to allow companies
to comply with any updates.
EWG will review and update EWG’s lists of
unacceptable and restricted ingredients once annually
to reflect the latest in science, regulations and otherrelevant considerations. If EWG makes changes,
companies will be alerted that a new list is pending atleast one (1) month before the changes go into effect.
Any companies with currently licensed products thatare affected will be notified six (6) months before theircontract expires. Companies will then get eighteen(18) months to make the necessary changes to theirformulation and packaging.
At the end of the 18-month period, products with
EWG’s licensed mark that do not comply with the newlists of unacceptable or restricted ingredients may nolonger be manufactured or produced. If companies
continue to distribute non-compliant products with
EWG’s licensed mark, this will be treated as a breachof EWG’s licensing agreement. In the rare event thatscientific evidence emerges showing that a personalcare product ingredient will pose significant harm
to human health, EWG reserves the right to ask
companies either to remove the ingredient or stop
distributing the relevant products with EWG’s licensed
mark within a shorter period than specified above.

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iii. 	Companies must acknowledge
that as a condition of their 		
participation in the licensing
program, EWG will add all of
their licensed products to EWG’s
Skin Deep database, if they are
not already included.
iv. 	Companies must acknowledge
that EWG’s Skin Deep databaseis dynamic and the scoring 		algorithm may change over time.
EWG strives to make all of its consumer databases
as robust as possible. For this reason, Skin Deep isa dynamic database and product and/or ingredient
ratings are subject to change because of both emerging
science and scoring algorithm improvements. In mostcases, EWG will give companies notice of such changes
to the scoring system; unforeseen circumstances
may deem such notice impossible in rare situations.
If changes to the Skin Deep scoring system rendera company’s product out of compliance with EWG’slicensing criteria, the company will have 18 months
either to regain compliance or to remove the EWG
licensed mark from their product packaging andassociated materials.

v. 	Companies must acknowledge
and agree that EWG has theright to perform random producttesting, including through 		
qualified third-party testing
services, to ensure that products
meet the provisions outlined in
EWG’s licensing criteria.
EWG requires companies with licensed products
to acknowledge that EWG has the right to perform
random product testing, which may include the use ofqualified third-party services, to ensure that products
bearing the EWG licensed mark meet the provisions
highlighted in this document.

vi. 	C ompanies must acknowledge
that EWG has the right toapprove, in advance, any useof the EWG VERIFIED mark inadvertising, marketing,artwork, packaging, point-ofsale materials, website content,
promotions and other materials.
Before public use or distribution, companies must
submit to EWG samples of the final licensed product,
including all packaging, product inserts and othermaterials accompanying such licensed product orotherwise bearing the trademarks.

vii. 	C ompanies must acknowledge
that, although product claims are
not addressed in EWG’s licensing
criteria, EWG reserves the 		right to forbid use of the EWG
VERIFIED mark on any productmarketed with claims that would
harm or discredit EWG or the
EWG VERIFIED program.

DOCUMENTINGCOMPLIANCE WITH
EWG’S LICENSINGCRITERIA FORPERSONAL CARE
PRODUCTS
To verify a product meets EWG’s standards for healthand transparency, a company must submit the following
documentation for each EWG VERIFIED criterion.
CRITERION 1: The product must fit into one of theapproved licensing product categories.
CRITERION 2: The product must rate “Green”
in Skin Deep.

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CRITERION 3: The product must be freefrom any ingredients on the EWG list of
unacceptable ingredients.
CRITERION 4: The product must follow standard
ingredient naming and labeling guidelines.
DOCUMENTATION: Companies must submit acompleted Product Submission Form with productname, ingredients and all package text. For verification
purposes, companies must also submit legible images
or pictures of their package as it appears on actual
products for sale. In cases where the package text and/or artwork has yet to be finalized, EWG will review
proof images during the application process. However,companies must submit final package images for EWG
approval before the mark will be approved for use.
(Product Submission Forms can be downloaded fromthe application page.)
To show that their product provides proportional UVA
and UVB protection, companies must also provide oneof the following when submitting sunscreen products:i. 	A n in vivo PPD test using the ISO 24442 protocolthat shows a PPD value that is greater than orequal to one-third the labeled SPF
ii. 	A modified in vitro UVA test using the ISO
24443:2012 or Colipa 2012 methodology, where
the product results indicate that the UVAPF isgreater than or equal to one-third the labeled
SPF; and the coefficient of adjustment, “C,” used
to adjust the in vitro transmission measurement
to the in vivo SPF, must be within the rangeof 0.8-1.2, as recommended by Colipa 2012.
EWG will upload product information to an internal
platform that will highlight whether the product to belicensed meets the EWG criteria specified above.
CRITERION 5: Be free from any of EWG’srestricted ingredients that do not meet therelevant restrictions.

DOCUMENTATION: EWG will require companies
to acknowledge our Safety Substantiation Notice andconfirm that any restricted ingredients in the productmeet the relevant restrictions set by authoritative
bodies and industry institutions.
If the maximum concentration of an ingredient
allowed in the formulation is restricted, we ask thatyou provide a signed statement from a formulator,
regulatory specialist or other authorized company
representative with knowledge of formulation details
certifying that the percentage used is less than the
restricted amount. The signed statement should
address the specific restricted ingredient, productname, and associated percentage. For example, ProductA contains less than x% of Ingredient Y. The statement
should be dated and written on letterhead.
If an ingredient is restricted because of a component
or because of impurity or contamination concerns,
we require more than a signed statement only. We
require test reports or a certificate of analysis or similar
documentation addressing the restricted limit specifically.
Please make sure the substantiation documents
provided clearly show the name of the ingredient being
substantiated on the document, as well as in the name of
the file name being sent to us. All documentation should
be dated within the past two years.
CRITERION 6: Fully disclose all ingredients on thelabel, including those in fragrance and flavor mixturesand chemicals used to coat mineral ingredients.
DOCUMENTATION: Companies must submit asigned affidavit that they have fully disclosed all theintentionally added ingredients on the company’s
public-facing website (including fragrance or flavor
ingredients at or above 0.01%) and product label(including at least the first five fragrance or flavor
ingredients when the mixture exceeds five ingredients).
EWG will supply companies with the necessary form,
the Master Personal Care Products Affidavit, which canbe downloaded from the application page.

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CRITERION 7: Disclose all fragrance allergens
required on personal care product labels in the EU.
DOCUMENTATION: EWG will require companies
to sign an affidavit stating that they will disclose
all fragrance allergens that are required on labels in
the EU. EWG will review the product’s ingredientsand determine whether fragrance allergens are likely
present, whether as directly added ingredients or as acomponent of a fragrance ingredient. If EWG decides
fragrance allergens may be present, companies must
either label them accordingly or submit a signed
affidavit from their ingredient supplier stating thatno allergen is present or, if present, all fragrance
allergens meet EU concentration restrictions – 0.01%
in rinse-off products and 0.001% in leave-on products.
EWG will supply companies with the necessary form,
the Master Personal Care Products Affidavit can be
downloaded from the application page.
CRITERION 8: Follow the EU’s labeling guidelines
for nanomaterials used in cosmetics.
DOCUMENTATION: Companies must sign an affidavit
stating that they will follow EU labeling guidelines fornanomaterials in cosmetics within 1 year of signing
the contract. At the end of the year, companies must
either label nanoscaled ingredients or submit affidavits
from ingredient suppliers stating that none of theingredients in the licensed product is considered ananomaterial, as defined by the EU in 2011: “a natural,
incidental or manufactured material containing
particles, in an unbound state or as an aggregate oras an agglomerate and where, for 50% or more of theparticles in the number size distribution, one or more
external dimensions is in the size range 1 nm-100 nm”.
EWG will supply companies with the necessary form,
the Master Personal Care Products Affidavit, which canbe downloaded from the application page.

CRITERION 9: Indicate expiration date or theamount of time after opening within which the
product must be used
DOCUMENTATION: EWG requires companies to sign
an affidavit stating that product labels will indicate an
expiration date or the period within which the productmust be used after opening. The necessary form,
the Master Personal Care Products Affidavit, can be
downloaded from the application page.)
CRITERION 10: Develop, document and follow
current good manufacturing practices.
DOCUMENTATION: EWG will require companies tosign an affidavit stating they have developed and will
document and follow good manufacturing practices
or develop them if they have not yet done so. EWG
will supply companies with the necessary form, theMaster Personal Care Products Affidavit, which canbe downloaded from the application page. EWG may
request a copy of a company’s good manufacturing
practices documentation at any time.
CRITERION 11: Pass basic microbial challenge
tests and repeat them as necessary.
DOCUMENTATION: Companies must sign an affidavit
stating their product either satisfies the requirements
for exemption from this criterion or has passed basic
microbial challenge tests. EWG also reserves theright to request either proof that the product meetsthe requirements for exemption or documentationof the challenge test results. The Master Personal
Care Products Affidavit can be downloaded from theapplication page.

Additional criteria for EWG-licensed companies:i. 	C ommit to reporting all product problems or
serious adverse events to FDA.
ii. 	A cknowledge that EWG’s lists of unacceptable
and restricted ingredients will be updated oncea year, with a phase-in period for companies tocomply with updates;

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iii. 	A cknowledge that as a condition of participatingin the licensing program, EWG will add all of its
licensed products to EWG’s Skin Deep database
if they aren’t already.
iv. A cknowledge that Skin Deep is dynamic, and thescoring algorithm may change;v. 	A cknowledge that EWG has the right to perform
or commission random product tests, including
through qualified third-party testing services, toensure products meet the provisions outlined in
EWG’s licensing criteria.
vi. A cknowledge that EWG has the right to 		approve any use of the EWG VERIFIED mark inadvertising, marketing, artwork, packaging,point-of-sale materials, website content, 		
promotions and other materials.
vii. 	A cknowledge that EWG reserves the right toprohibit use of the EWG VERIFIED mark on
any product making claims that would harm or
discredit EWG or the EWG VERIFIED program.
DOCUMENTATION: Companies must sign an affidavit
stating that they acknowledge and agree to thesecriteria. EWG will supply companies with the necessaryform, the Master Personal Care Products Affidavit,
which can be downloaded from the application page.

APPENDICES

Common name

CAS number

Benzyl salicylate

118-58-1

Cinnamyl alcohol

104-54-1

Cinnamal

104-55-2

Citral5392-40-5

Coumarin

91-64-5

Eugenol

97-53-0

Geraniol

106-24-1

Hydroxycitronella

107-75-5

Hydroxymethylpentyl
cyclohexenecarboxaldehyde
Isoeugenol

97-54-1

Anisyl alcohol

105-13-5

Benzyl benzoate

120-51-4

Benzyl cinnamate

103-41-3

Citronellol

106-22-9

Farnesol4602-84-0

Hexyl cinnamaldehyde

101-86-0

Lilial80-54-6d-limonene

Appendix I: List of allergens required
to be listed on product labels

31906-04-4

5989-27-5

Linalool

78-70-6

Methyl heptine carbonate

111-12-6

3-Methyl-4-(2,6,6-trimethyl-2cyclohexen-1- yl)-3-buten-2-one

127-51-5

Common name

CAS number

Amyl cinnamal

122-40-7

Oak moss

90028-68-5

Amylcinnamyl alcohol

101-85-9

Tree moss

90028-67-4

Benzyl alcohol

100-51-6

EWG’s licensing criteria | Personal care products | 11
Copyright © 2023, Environmental Working Group. All rights reserved.

Appendix II: The International Fragrance Association’s product categories table
These categories are summarized in Table 9 of the guidance for the use of IFRA standards, as follows:
Category

Product type

Sample EWG VERIFIED product categories

1

Products applied to the lips

Lipstick, lip gloss, lip balm

2

Products applied to the axillae

3

Products applied to the face/body using fingertips

4

Products related to fine fragrance

5
5A
5B
5C
5D

Products applied to the face and body using thehands (palms), primarily leave-on:
Body lotion products applied to the body using
the hands (palms), primarily leave-on
Face moisturizer products applied to the face
using the hands (palms), primarily leave-on
Hand cream products applied to the hands using
the hands (palms), primarily leave-on

Antiperspirants and deodorants, bodysprays/mists
Facial makeup, eye makeup, eye cream,
wipes, masks
Fragrance, aftershave

Body creams, moisturizers, foot creams
Facial moisturizer, serums, non-makeup
face products
Hand creams

Baby cream, oil and talc

Baby cream, baby oil, and baby talc

Products with oral and lip exposure

Toothpaste, mouthwash

Products applied to the hair with some handcontact
Rinse-off products applied to the hair with some
hand contact
Leave-on products applied to the hair with some
hand contact

Masks, hair dyes

8

Products with significant anogenital exposure

Baby wipes

9

Products with body and hand exposure, primarily
rinse off

Soaps, facial cleansers, body wash,
shampoo, conditioner, bubble bath, baby
wash, shaving cream

6
7
7A
7B

Hair treatments, styling aides

For more details, see the IFRA Guidance for the Use of IFRA Standards: ifrafragrance.org/docs/default-source/ifracode-of-practice-and-standards/49th-amendment/ifra-49th-amendment-(att-01)---guidance-for-theuse-of-ifra-standardsa7006c445f36499bbb0eb141e8c0d4be.pdf?sfvrsn=7fb244c8_2

EWG’s licensing criteria | Personal care products | 12
Copyright © 2023, Environmental Working Group. All rights reserved.