California Restricts “Reef Safe” Sunscreen Claims from January 2027

What California's Reef-Safe Sunscreen Claims Restrictions Cover

AB 1744 makes it unlawful to use the following claims in advertising or on the label or container of a sunscreen product sold in California unless the product contains no chemical UV filters:

• "Reef safe"

• "Reef friendly"

• "Ocean safe"

• "Marine safe"

• "Ocean friendly"

• "Marine conscious"

• "Reef conscious"

The restriction also covers similar terms or phrases likely to cause a reasonable consumer to believe that the product does not harm marine ecosystems. Businesses must therefore assess the meaning conveyed by alternative wording, rather than checking only for the expressly listed phrases.

The law restricts environmental marketing claims; it does not itself ban the sale or use of sunscreens containing chemical UV filters.

Affected Products, Ingredients and Enforcement

For this provision, "sunscreen product" includes any over-the-counter drug regulated by the U.S. Food and Drug Administration (FDA) that is intended to protect users from UV radiation. Covered formats include lotions, sprays, sticks, gels and solids.

AB 1744 expressly identifies the following chemical UV filters:

These six ingredients are examples, not an exhaustive list. The statutory language covers any chemical UV filters. A product's absence of oxybenzone and octinoxate alone therefore does not establish eligibility to carry the restricted claims.

Products without chemical UV filters remain subject to the environmental marketing requirements in Business and Professions Code Sections 17580 and 17580.5. Such products must still have appropriate support for their environmental claims and must not make untruthful, deceptive or misleading representations. A mineral-only formulation does not automatically substantiate a claim that the finished product is harmless to marine ecosystems.

Violations are subject to the misdemeanor provisions in Section 17581, which provides for imprisonment in county jail for up to six months, a fine of up to $2,500, or both. The California Senate Judiciary Committee's analysis explains the existing substantiation and penalty provisions.

Impact and Recommended Actions for Businesses

The restrictions apply to covered sunscreen products sold in California, making them relevant to both domestic suppliers and overseas businesses serving the state. Companies using common packaging or promotional materials across the U.S. market should assess whether those materials require revision for California sales.

To prepare for the requirements, REACH24H recommends that businesses:

• Identify affected products and claims. Review California-market sunscreen products for the listed terms and other wording that conveys marine-ecosystem safety.

• Check the complete formulation. Identify all chemical UV filters rather than limiting the review to the six expressly named ingredients.

• Review marketing across channels. Assess labels, containers, websites, e-commerce listings and advertising associated with California sales.

• Coordinate updates before the effective date. Align revised wording and implementation schedules with packaging suppliers, distributors and retailers.

• Review supporting evidence. For products without chemical UV filters, evaluate whether the evidence supports each environmental claim about the finished product.

These steps are practical recommendations for implementing the statutory restrictions. Businesses should also assess other applicable FDA and state requirements separately. As FDA explains, sunscreens are regulated as drugs in the United States, so changes to environmental claims do not resolve all U.S. sunscreen compliance obligations. For further context, see REACH24H's guide to U.S. FDA OTC and cosmetic regulations.

How REACH24H Can Help

REACH24H supports personal-care businesses with product classification, formula and labeling review, claims assessment and state-level regulatory evaluation. Through our U.S. cosmetics compliance services, we help businesses identify applicable requirements, including potential drug-classification issues, and prioritize compliance actions for the U.S. market.