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Expensive to get wrongUnited StatesSuncare

The SPF page skips the label the law defines

Of 8 beauty product pages selling into the United States that advertise an SPF value, 1 publishes a Drug Facts panel and 2 name an active ingredient, the two elements that distinguish an over-the-counter drug label from marketing copy, while 0 carry any warning text at all.

A sunscreen is a drug in this market and the page selling it is written as though it were a moisturiser, so the compliance work either happens on the carton alone or has not happened, and only one of those is survivable at a retail buyer’s legal review.

61

61 of a possible 90Tier B, systematic first-party observation. Nothing at this tier is allowed past 90, however good it looks.

Verified September 9, 2026Rechecked every 120 days, next by January 7, 2027.

Constraint

Held since August 5, 2026A rule, law or policy that limits what you may do or say. The earliest date we are willing to say this held. It may well have been true before that; we do not backdate a record past the evidence we have read. Supported, version 2.

This entry is wrong if

A repeat run finds more than half of SPF-advertising product pages publishing a Drug Facts panel.

Written before the record was published, not after. If you can show this, send it to hello@tryorbt.com and the correction goes on the record with the entry.

Evidence

  1. Tier Bobserved-webn = 8

    orbt: Market Register commerce collector, run commerce-20260805140548

    Visible text of one product page per storefront, scripts stripped before matching so a theme’s embedded JSON payload cannot supply a phrase no shopper sees. “Drug Facts” is matched as the defined US label heading rather than as a phrase a marketer would choose, which is what makes its absence meaningful. Two limits: this is the page and not the carton, and a product whose physical label carries a compliant panel is not in breach of anything because its web page does not; and it is one product per shop, so a brand with SPF across a range is described by whichever item its feed returned first. Read it as what a shopper and a buyer’s lawyer see on the site, which is the only thing it measures. Retailers are excluded from both origin groups: OLIVE YOUNG Global, Peach & Lily, Soko Glam, Stylevana. Their catalogues are other companies’ product copy, so counting them by the storefront’s own origin would put Korean listings inside the US-origin group. Run commerce-20260805140548.

    Read 2026-08-05 · CC BY · page hash 9a6ccfd5ea85

History

  1. v2corrected

    Re-derived from collector run commerce-20260805140548 after a change to the instrument: corrected subject-verb agreement in the SPF drug-label sentence. The figures moved for that reason. Any part of the change attributable to the market moving cannot be separated from it in this revision, and the previous statement is recorded below rather than replaced.

    What it said before

    Of 8 beauty product pages selling into the United States that advertise an SPF value, 1 publish a Drug Facts panel and 2 name an active ingredient, the two elements that distinguish an over-the-counter drug label from marketing copy, while 0 carry any warnings text at all.

  2. v1created

    Derived from collector run commerce-20260805140548.

Append-only. Nothing in this list is edited or removed once written, including the entries that record our own mistakes. Every change to every record is on the corrections page, and the same log is in entries.json under revisions.

  • suncare
  • spf
  • labelling
  • otc-drug
  • compliance
  • product-page
  • beauty

Cite this entry

“The SPF page skips the label the law defines”, The Orbt Market Index 0.1.0, entry omr:us:spf-products-ship-without-the-drug-label, retrieved September 9, 2026, https://tryorbt.com/markets/entry/us--spf-products-ship-without-the-drug-label. Dataset: https://doi.org/10.5281/zenodo.22679129

For a deck, a brief or a chat.

Free to quote, cite and act on. Not to resell or redistribute — the sources ask that of us, and each one’s terms are named. Machine-readable: entries.json carries this record under the id omr:us:spf-products-ship-without-the-drug-label, with the same evidence and falsifier.

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