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cleangirlusa.com

No American government body defines the word clean in cosmetics. The last time a federal regulator tried to define a beauty marketing word was 1975, and a court struck the rule down in 1977. Nobody has tried since. In the vacuum, six American retailers wrote seven published definitions of their own, and those definitions disagree with each other ingredient by ingredient. Two federal courts have now ruled on the word seven months apart and reached opposite results. The one defense that worked was publishing your own definition.
00:00:00:00 Trailer  ·  :26  ·  Looping
The argument

The word has no definition. It has seven.

Start by separating two things that sound alike and are not alike. A clean girl is an aesthetic: minimal makeup, glossy skin, hair pulled back, muted neutral clothes. Clean beauty is a formulation claim about what is in a bottle. One names a look and one names an assertion a seller makes about a product, and nothing in the public record connects them.1 Conflating them is the first mistake anyone makes in this subject and it is the reason most writing about it is useless. This page is about the second word, because that is the one with money and liability attached to it.

Now the finding. We searched the code of federal regulations and the Federal Register for both phrases and got zero and zero. The government publishing office returns sixteen records for one of them and not one is a regulation, a statute or a piece of agency guidance; four are court records and one is a hearing where the phrase appears three times, all three inside a single witness's prepared testimony.2 That is not an oversight. The last time an American regulator tried to define a cosmetic marketing word, it published a rule in 1975 requiring comparative testing before a product could be called hypoallergenic, two companies sued, and in December 1977 a court of appeals held the action arbitrary and capricious and the rule never took effect.3 The agency's own page on that word today says it means whatever a particular company wants it to mean, and says the same thing in different words about natural, about organic and about cruelty-free.4 Forty-nine years later nobody has tried again. Meanwhile the register shows the exact phrase in this domain is a live registered trademark, for surface cleaners, with the word clean disclaimed, which is the kind of thing a buyer should learn from the seller rather than from counsel.5 And on demand: on one shared scale the aesthetic passed the claim in January 2022 and has risen every year since, while the claim has been flat for four years, spiked once in spring 2026 and reverted below its own 2022 baseline.6

Into that vacuum, six retailers wrote seven definitions. Each is a document anyone can download, and each sets out which ingredients a product must be formulated without before that retailer will call it clean.7 The longest runs to twenty-three pages; its publisher says over 1,200 ingredients and our parse of the file finds 1,164 unique names and 1,210 registry numbers, which tells you the headline figure counts identifiers rather than ingredients.8 The shortest is forty-seven names, and it is the only one of the seven that version-stamps its own definition, so you can read which nine entries arrived in April 2024.9 One publishes its exclusions in three sections where only the first is a prohibition, and states in writing that its list does not guarantee a product is free of anything.10 The published totals run from twenty-three to over three thousand and look like a ranking. They are not: some count individual substances, some count chemical classes, and one program's single line for a class of compounds is the same chemistry another describes as more than three thousand ingredients.11 This page publishes no ranking of them, and card 10 is the long version of why that would be dishonest.

Then take six ordinary ingredients and check each against each of the six published lists. The documents disagree. One chelating agent is prohibited on three and absent from three. Mineral oil and petrolatum are prohibited on two and permitted on a third, but only at pharmacopeial grade, with the program stating its reason is contamination rather than the ingredient class.12 That second position is not a weaker rule, it is a different theory of what the risk is, and a brand selling into both has to satisfy two incompatible definitions of one word.13 A familiar preservative family is excluded as a whole class by three programs, while a fourth names eight specific members, all of one chemical type, leaving the two most commonly used ones unnamed beside a bare class row with no identifier attached. We report both and refuse to resolve the ambiguity, because reading an intention into somebody else's standard is how this subject gets reported wrongly.14 Four programs describe how compliance is established and each uses a different verb: brands guarantee, brands certify, products have been verified, and one states no mechanism at all.15 And the most misread thing here is an empty cell, because three of these documents say in their own words that what they publish is partial.16

Finally, what happens when the word is tested. In March 2024 a federal court dismissed a complaint over a clean seal, and the reason is the most practical fact in this entire subject: the retailer had published a specific list of what the seal meant, so the published definition is what a reasonable consumer was taken to have read.17 Six months later a second federal court denied a motion to dismiss outright against a different retailer on the same theory, reasoning that a retailer applying its own program between manufacturer and shopper may be taken to have assessed something.18 Two federal courts, seven months apart, opposite outcomes. Most challenges never reach a court at all; they go to an industry self-regulatory panel that cannot fine anyone, cannot enjoin anyone, issues recommendations and whose only real lever is a referral to the agency, and which has upheld one of these words as readily as it has questioned another.19 And if any American body had settled this, it would be in the national standards catalog. We searched it and the phrase returns no results.20

Domain
cleangirlusa.com
Length
12 characters + .com
TLD
.com, the default
Category
Beauty claims and standards
Hyphens or numerals
None
Federal definition of the word
None, and none since 1977
Published private definitions
Seven
Price
$3,500 buy it now
What nobody defined
0

Federal rules naming it

Both phrases, in the regulations and the Federal Register. Queries printed.2

1977

The last attempt

A rule defining a beauty word, struck down. Nothing since.3

0

Dictionary entries

In three of the four reference works. The fourth is a slang entry.1

1

Live registration of the phrase

For surface cleaner, with the word clean disclaimed.5

What was written instead
7

Published definitions

Six retailers. Seven documents. No two the same.7

23 to 3,000

The published range

And the counts do not measure the same thing.11

2

Federal courts, opposite results

Seven months apart, on the same theory.17

0

Accredited standards defining it

Our search of the national standards catalog.20

Find your fit

Six businesses
that live at this address.

Pick the one closest to yours and the twenty snapshots below will mark the ones built for it. Nothing is hidden; the grid only marks and scrolls.

Twenty use cases

What a business
looks like here.

Each panel below is a working miniature of a site that could run at this address: navigation, hero, product screen and proof numbers, followed by a plain note on how that business would position the name. All twenty stay on screen at all times; a lane simply marks its own. The domain sits in the browser bar of every one of them, whole and unbroken, because the name is the thing being sold.

01

Two Words That Share A Syllable

The look and the claim are not the same thing
🔒 cleangirlusa.com
LookClaimSplit See the split

One names a look.
One names what
is in the bottle.

A clean girl is an aesthetic: minimal makeup, glossy skin, hair pulled back. Clean beauty is a formulation claim about ingredients. Nothing in the public record connects them. Treating them as one word is the first mistake anyone makes here.

THE TWO SENSES OF ONE ADJECTIVESEPARATED FIRST
CLEAN GIRLAn aestheticA look. Minimal or no-makeup makeup, glossy skin, hair in a bun or slicked back, gold jewelry, muted neutral clothes.POPULARIZED ON SHORT-FORM VIDEO, EARLY 2022
CLEAN BEAUTYA formulation claimAn assertion about what a product is made of, or not made of. It is a claim a seller makes and a buyer is asked to believe.NO AGREED DEFINITION, NO GOVERNING BODY
The term clean girl aesthetic refers to a beauty, fashion, and lifestyle trend based around a look that’s intended to appear elegantly casual but also minimalist and effortless.DICTIONARY.COM SLANG DICTIONARY, FEBRUARY 1, 2023
QUOTED WITH ITS OWN CAVEAT ATTACHED, BECAUSE THAT IS WHAT THE SOURCE SAYSThat entry sits in a slang dictionary, not the main dictionary, and it carries the publisher’s own note that it is not meant to be a formal definition. We print the caveat because leaving it off would make the entry look like something it is not.
THREE OTHER DICTIONARIES CARRY NO ENTRY FOR EITHER PHRASE, AND NEITHER HAS EVER BEEN A WORD OF THE YEARWE CHECKED
2different kinds of word
0sources linking them
2023-02-01the slang entry
How they position itOwning the address where the two senses of the word get told apart is worth more than owning a page that confuses them like everyone else.
02

Zero In The Federal Record

What the government has written about either phrase
🔒 cleangirlusa.com
eCFRFRgovinfo Run the search

Neither phrase
appears in any
federal rule.

We searched the code of federal regulations, the Federal Register and the government publishing office for both phrases on the day this page went up. The queries are printed so anyone can run them again and get the same answer.

FULL-TEXT SEARCH OF THE FEDERAL CORPUS · QUERIES PRINTEDOUR SEARCH
eCFR, exact phrase“clean girl”0
eCFR, exact phrase“clean beauty”0
Federal Register, 1994 to date“clean girl”0
Federal Register, 1994 to date“clean beauty”0
Control, proving the query form works“clean air” in eCFR8,844
Control“cosmetic ingredient” in eCFR5
AND THE SIXTEEN HITS THAT DO EXIST, READ ONE BY ONE RATHER THAN COUNTEDThe government publishing office returns sixteen records for “clean beauty” and not one is a regulation, a statute or a piece of agency guidance. Four are federal court records. One is a 2019 congressional hearing, where the phrase appears three times and all three are inside a single witness’s prepared testimony. The remaining eleven are decades-old prose where the two words happen to sit together.
A WITNESS SAYING A PHRASE AT A HEARING IS THAT WITNESS’S VOCABULARY, NOT THE GOVERNMENT’SREAD CAREFULLY
0in the regulations
0in the Federal Register
2026-10-01date we ran it
How they position itPublishing the query alongside the result is what separates a page a buyer trusts from a page a buyer checks and abandons.
03

The Last Time Anyone Tried

A regulator defined a marketing word and lost
🔒 cleangirlusa.com
19751977Never Read the case

One agency tried
to define a beauty
word. In 1975.

The most important fact in this whole subject is almost fifty years old. A federal regulator wrote a rule defining a cosmetic marketing term, two companies sued, the rule was struck down, and nobody has tried again since.

ALMAY, INC. v. CALIFANO · 569 F.2d 674 (D.C. CIR. 1977) · NO. 76-1718REPORTED
JUN 6, 1975A final rule is published at 21 C.F.R. 700.100. To call a cosmetic hypoallergenic, a company would have to show by comparative testing that it caused fewer adverse reactions than competing products.
THE CHALLENGETwo cosmetics companies sue. The district court upholds the rule.
DEC 21, 1977The court of appeals reverses. The regulation never takes effect.
SINCENo federal agency has issued a definition of a cosmetic marketing word. That is forty-nine years.
Under such circumstances we are compelled to find that the action of the Commissioner was arbitrary and capricious.THE COURT OF APPEALS, QUOTED FROM THE OPINION
WHAT THE COURT ACTUALLY FAULTED, STATED PRECISELYThe opinion turned on the adequacy of the administrative record, not on any holding that the agency lacked power to regulate the word. It described the bases in the record as conclusions drawn from a dictionary that did not employ the chosen definition, a medical report recommending against any use of the term, and a survey whose unreliability it called apparent. Read it as a record case, because that is what it is.
THE AGENCY’S OWN CURRENT PAGE SAYS THE WORD “MEANS WHATEVER A PARTICULAR COMPANY WANTS IT TO MEAN”ITS WORDS
1975the rule
1977it was struck down
0attempts since
How they position itA forty-nine year old precedent that explains why the whole category is undefined is the kind of thing a buyer cannot find anywhere else, and it is the reason this address reads as authority.
04

The Words Already On File

What the trademark register says about this phrase
🔒 cleangirlusa.com
USPTORegDisclaimed Read the record

It is registered.
For floor cleaner.
With CLEAN given up.

A buyer should know what the public register says before spending anything, and here it says something. The exact phrase carries a live registration, in a class nobody would expect, and the registrant disclaimed half of it.

USPTO RECORD · SEARCHED OCTOBER 1, 2026 · REPORTED, NOT INTERPRETEDRECORD ONLY
THE EXACT WORDING, AS A MARKTWO RECORDS
REGISTEREDReg. 8336251, registered July 7, 2026, Principal Register. International Class 3. The goods, in full: “Cleaning preparations for cleaning surfaces.” A household surface cleaner, not a cosmetic. The word CLEAN is disclaimed.
PENDINGFiled September 23, 2025 across four classes covering hair care, styling irons, dryers and brushes. Status as read: an office action suspending further action has been issued.
ONE WORDNo record at all for the phrase closed up as a single word, in any index we searched.
1,655CLASS 3 RECORDS DISCLAIMING “CLEAN”
308CLASS 3 RECORDS DISCLAIMING “GIRL”
0RECORDS DISCLAIMING THE PHRASE ITSELF
WHAT WE ARE NOT SAYING, AND WILL NOT SAYThose three counts are our counts of search results on one day and they will drift. A registration for surface cleaners is not a right in cosmetics, and we draw no conclusion either way. Presence in this index is not an obstacle and absence from it is not clearance; common-law rights need no registration and are not in this record. We did not search phonetic variants, design marks, state registrations or foreign rights. A clearance search and any opinion on registrability is counsel’s work.
NO PARTY IS CHARACTERIZED AS INFRINGING OR AS LACKING RIGHTS, AND NO ABANDONED APPLICATION IS TREATED AS A FAILURENEUTRAL REPORT
1live registration of the phrase
1pending application
2026-10-01date searched
How they position itPutting the register on the page, including the registration that does not flatter the name, is what a serious buyer needs and what nobody selling a domain ever does.
05

Which Word Is Actually Winning

Relative demand, on one shared scale
🔒 cleangirlusa.com
IndexSharedShape Read the curves

The aesthetic
passed the claim
in January 2022.

Both phrases were put on a single comparison scale for five years. One has risen steadily. The other has been flat, spiked once, and come back down. We print the index, never a search count, because an index is what the tool returns.

RELATIVE SEARCH INTEREST · US · ONE SHARED 0 TO 100 SCALE · 262 WEEKSINDEX, NOT A COUNT
“clean girl” · ANNUAL MEAN INDEX
7.613.214.019.120.130.8
“clean beauty” · ANNUAL MEAN INDEX
9.712.212.911.713.835.2
2021ONE AXIS, ONE QUANTITY: BOTH SERIES DRAWN AGAINST THE SAME MAXIMUM OF 35.22026
“clean girl”, MOST RECENT WEEK19
“clean beauty”, MOST RECENT WEEK10
THE WEEK THE AESTHETIC PASSED THE CLAIMJAN 30, 2022
THE FINDING THAT CUTS AGAINST THE OBVIOUS READ, AND WE PRINT IT ANYWAYThe second series is not a clean read on the ingredient category. Its own top related queries are people asking how to clean a beauty blender, a keyboard, a humidifier, a dishwasher filter. The verb is contaminating the noun. Its 2026 figure rests on one unexplained spring spike that has already reverted to below its 2022 baseline, and we did not guess at a cause.
INDEX VALUES FROM ONE COMPARISON CANNOT BE COMPARED WITH VALUES FROM ANOTHER. THESE ARE ALL FROM ONE.STATED PRECISELY
19the aesthetic, latest week
10the claim, latest week
2022-01-30the week it crossed
How they position itAny buyer can pull a trend line. Pulling it, finding the contamination in it, and printing the contamination is what makes the rest of the page credible.
06

Six Stores, Seven Definitions

What filled the vacuum the government left
🔒 cleangirlusa.com
ProgramsListsCounts See the lists

Nobody defined it.
So six retailers
defined it.

Every one of these is a published document a buyer can download. Each sets out which ingredients a product must be formulated without before that retailer will call it clean. No two of them are the same list.

PUBLISHED RETAILER STANDARDS · EACH DOCUMENT READ OCTOBER 1, 2026PRIMARY DOCUMENTS
WalmartMade Without List“over 1,200”JANUARY 2023
Credo BeautyThe Dirty List“over 3,000”UPDATED JUNE 2026
Whole FoodsPremium Body Care“400+”LIST GENERATED MAY 5, 2014
Whole FoodsCurrent store-wide standard“more than 240”NO DATE PUBLISHED
TargetTarget Priority Chemical List184OUR COUNT · NO NUMBER STATED
Ulta BeautyMade Without List53OUR COUNT · NO NUMBER STATED
SephoraClean at Sephora47OUR COUNT · NO NUMBER STATED
WHOSE NUMBER IS WHOSE, BECAUSE THE DIFFERENCE MATTERSFour of these figures are the retailer’s own, printed in its own document. Three are ours, counted off the published list because that retailer states no total. Every row above says which it is, and so does every other mention on this page.
NONE OF THE SEVEN IS A NATIONAL STANDARD, AND NONE OF THEM CLAIMS TO BEPRIVATE DOCUMENTS
6retailers with a published list
7published lists
0that are national standards
How they position itAssembling seven documents nobody has put side by side, and dating each one, is the work a buyer in this category would otherwise have to do themselves.
07

The Longest List

What the biggest published exclusion list contains
🔒 cleangirlusa.com
MWLCASCount Count it

Over twelve
hundred. We
counted them.

One retailer publishes a twenty-three page list with chemical abstract numbers attached. We parsed the file rather than trusting a summary, and the count tells you something about what the headline number is actually counting.

WALMART · MADE WITHOUT LIST FOR BEAUTY · MAIN LIST, JANUARY 2023OUR PARSE
THE RETAILER’S OWN FIGUREover 1,200AS WRITTEN IN THE ANNOUNCEMENT
OUR COUNT OF ROWS CARRYING A CAS NUMBER1,168PARSED FROM THE PUBLISHED PDF
OUR COUNT OF UNIQUE CHEMICAL NAMES1,164SOME ROWS CARRY SEVERAL CAS NUMBERS
OUR COUNT OF CAS REGISTRY NUMBERS1,210THIS IS THE ONE THAT RECONCILES
WHY THAT RECONCILIATION IS THE WHOLE POINTThe headline figure matches the count of registry numbers, not the count of distinct named ingredients. One named entry can carry three registry numbers. Anyone quoting “over 1,200 ingredients” is quoting a count of identifiers. We use the retailer’s own phrasing when we cite it and we do not convert it into a count of ingredients.
Main ListAluminum and saltsFormaldehyde and releasersMercury compoundsNonylphenolsPFAS
THE DOCUMENT COMMITS TO ANNUAL REVISION; THE MOST RECENT ONE WE COULD LOCATE IS DATED JANUARY 2023STATED AS FOUND
1,164unique names, our count
1,210CAS numbers, our count
2023-01the list we found
How they position itParsing the actual file instead of repeating a press release is the difference between a page that sells a domain and a page that gets cited.
08

The Shortest List, And It Has Versions

The only program that version-stamps its own definition
🔒 cleangirlusa.com
V3V4Added Read the versions

Forty-seven names.
And a version
number on each.

One retailer publishes the shortest list of the six and is the only one that marks which version of its definition each entry arrived in. That makes its definition the only one whose history a buyer can actually read.

CLEAN AT SEPHORA · THE PUBLISHED INGREDIENT TABLEOUR COUNT
CLEAN V339MARCH 31, 2022
→
CLEAN V4+9APRIL 2024
EDTA and derivativesBenzeneOctocryleneOther heavy metalsFragranceNanomaterialsBHTCarbon BlackMineral Oil and derivatives
THE NINE ENTRIES THE TABLE MARKS AS ARRIVING IN V4. A DEFINITION THAT CHANGES IS A DEFINITION YOU CAN DATE.
AND IT IS NOT A LIST OF ABSOLUTE BANS, WHICH IS EASY TO MISREADMany entries carry a numeric ceiling rather than a prohibition. One dioxane limit is ten parts per million for rinse-off and three for leave-on. Lead is under half a part per million for lip products and ten for everything else. One preservative is capped at one percent of the total formula. A ceiling is a different instrument from a ban and the table distinguishes them.
THE SHORT SUMMARY PAGE AND THE DETAILED TABLE DO NOT CARRY IDENTICAL ENTRIES; WE CITE THE DETAILED TABLEOUR NOTE
47distinct names, our count
2versions on the table
9added in the latest
How they position itBeing the page that noticed one program version-stamps its definition and the others do not is exactly the detail a brand person forwards to a colleague.
09

Three Lists Wearing One Name

A program where the headline count is a third of the document
🔒 cleangirlusa.com
231416 Read all three

Twenty-three
prohibited. And
thirty more rows.

One retailer publishes its exclusions in three sections, and only the first is a prohibition. A product can carry the designation and still contain things from the second section, within stated conditions. Quoting the first number alone misstates what the badge covers.

ULTA BEAUTY · MADE WITHOUT LIST · THE THREE PUBLISHED SECTIONSOUR COUNT
SECTION ONE · PROHIBITED23The entries a product must not contain.
SECTION TWO · LIMITED USE14Permitted under stated conditions. Mineral oil, petrolatum and paraffin sit here, required to be pharmacopeial grade. So do talc and retinol esters.
SECTION THREE · NOT INTENTIONALLY ADDED16Things brands have represented they do not intentionally add. A preservative sits here, described as considered safe at one percent or below.
The “Made Without List” does not guarantee “100% free from” since trace contaminants are possible. It is not the intention ... to test for trace contaminants or guarantee 100% free-from.THE PROGRAM’S OWN PUBLISHED DISCLAIMER
WE PRINT THE DISCLAIMER BECAUSE IT IS THE MOST USEFUL SENTENCE ON THE PAGEIt is the clearest statement any of these six publishes about the limits of its own badge. Reading “23 ingredients” without the other thirty rows and without this sentence gets the program wrong in both directions.
THE SAME PROGRAM STATES ITS STANDARDS DO NOT APPLY TO PRODUCTS ON CLEARANCEALSO PUBLISHED
23prohibited, our count
14limited use, our count
16not intentionally added
How they position itReading all three sections when every write-up quotes only the first is the kind of care that makes an address worth paying for.
10

The Numbers Do Not Measure The Same Thing

Why three thousand and twenty-three are not comparable
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UnitsClassesScale See the units

One counts
substances. One
counts classes.

The published figures run from twenty-three to over three thousand and look like a ranking. They are not. Some count individual substances, some count chemical classes, and one counts registry identifiers. The same chemistry appears at three different resolutions.

ONE AXIS, ONE QUANTITY · WHICH IS EXACTLY WHAT THESE FIGURES DO NOT SHARENOT COMPARABLE
Counts individual substancesCredo “over 3,000” · Walmart “over 1,200”SUBSTANCE
Counts chemical classes and groupsUlta 23 · Target’s customer page, 9 groupsCLASS
Counts registry identifiersThe figure that reconciles Walmart’s headlineIDENTIFIER
ONE LINE ON ONE LIST“Perfluorinated compounds”1 entry
is the same chemistry as
ONE CATEGORY ON ANOTHERThe PFAS category“more than 3000”
THIS PAGE WILL NOT RANK THESE PROGRAMS, AND HERE IS THE REASON STATED PLAINLYA strictest-to-laxest table would be our editorial construct rather than a finding. The counts use different units, the documents cover different product ranges, one is an allow-list as well as a deny-list, and one program’s standard also reaches packaging, labor and environmental claims. There is no honest way to put them in order, so we do not.
ONE PROGRAM SAYS SO ITSELF: ITS CATEGORY COUNTS EXIST BECAUSE CLASSES CONTAIN HUNDREDS OF INGREDIENTSITS WORDS
3different units in use
1chemistry, three resolutions
0rankings on this page
How they position itRefusing to publish the ranking everyone wants, and explaining why it would be dishonest, is the single most persuasive thing a page in this category can do.
11

The Grid Nobody Has Published

Six ingredients against six published lists
🔒 cleangirlusa.com
GridSixSix Read the grid

Same ingredient.
Six lists. Three
different answers.

This is the finding. Take six ordinary cosmetic ingredients and check each one against each of the six published lists. The documents do not agree with each other, and every cell below was verified by searching the actual source file.

EACH CELL VERIFIED BY TEXT SEARCH OF THE PUBLISHED DOCUMENTOUR CHECK
SEPHORAULTATARGETCREDOWALMARTWHOLE FOODS
EDTAPROHNOT ON ITNOT ON ITPROHNOT ON ITLISTED
Mineral oil, petrolatumPROHLIMITEDNOT ON ITPROHNOT ON ITNOT ON IT
Cyclopentasiloxane (D5)PROHNOT ON ITNOT ON ITPROHNOT ON ITNOT ON IT
PhenoxyethanolMAX 1%NOT ADDEDNOT ON ITRESTRNOT ON ITNOT ON IT
AcetonePROHNOT ON ITNOT ON ITNOT ON ITLISTEDNOT ON IT
Bisphenol APROHNOT ON ITLISTEDNOT ON ITNOT ON ITNOT ON IT
PROHIBITED OR LISTEDPERMITTED WITH A CONDITIONNOT ON THE PUBLISHED LIST
WHAT A GRAY CELL MEANS, AND WHAT IT DOES NOT“Not on the published list” is a statement about a document, not about what a retailer permits. Several of these programs say in their own words that the list they publish is partial. A gray cell means we searched that file and the term is not in it. It is not a finding that the ingredient is allowed, and card 15 is about exactly that distinction.
WHOLE FOODS APPEARS HERE ON ITS CURRENT STORE-WIDE LIST, NOT ITS ARCHIVED ONE. THE TWO DIFFER.WHICH DOCUMENT
36cells, each checked
6ingredients
6published lists
How they position itThis single screen is the reason to own the name. It is the one view of this market that does not exist anywhere else, and it is built entirely from documents anyone can download.
12

One Ingredient, Two Positions

A disagreement that is reasoned, not careless
🔒 cleangirlusa.com
ProhibitPermitGrade See both sides

One prohibits it.
One permits it,
at a grade.

The easy reading of the grid is that somebody is being sloppy. Look at one row closely and that reading falls apart. Two programs took opposite positions on the same ingredient and both published a reason.

MINERAL OIL, PARAFFIN AND PETROLATUM · TWO PUBLISHED TREATMENTSBOTH QUOTED
PROHIBITEDListed as prohibited on one program’s table, where it arrived in the April 2024 version, and prohibited on another’s, which states its petrolatum category covers more than fifty individual ingredients.TWO PROGRAMS
PERMITTED, WITH A CONDITIONPlaced in a limited-use section and allowed only at United States Pharmacopeia, National Formulary or European Pharmacopoeia grade. The program’s stated reason: to ensure the highest quality is used, to prevent contaminants.ONE PROGRAM
READ THAT SECOND POSITION AGAIN, BECAUSE IT IS THE INTERESTING ONEIt is not a weaker rule. It is a different theory of what the risk is. One position treats the ingredient class as unwanted. The other treats the refining grade as the thing that matters and writes the grade into the standard. Both are defensible, both are published, and a brand selling into both has to satisfy two incompatible definitions of the same word.
NOTHING HERE SAYS EITHER POSITION IS CORRECT. THIS PAGE REPORTS WHAT THE TWO DOCUMENTS SAY.NO RANKING
2published positions
1ingredient
3pharmacopeial grades named
How they position itShowing that the disagreement is principled rather than sloppy is what turns a gotcha page into a reference, and references are what get linked.
13

A Whole Class, Or Two Of Them

Where one word covers different chemistry
🔒 cleangirlusa.com
ClassNamedGap Compare them

Three say the
class. One names
eight of them.

A single familiar preservative family shows how far these definitions drift. Some programs exclude the whole class in one line. One names eight specific members, all of one type, and leaves the two most common ones unnamed.

PARABENS · HOW FOUR PUBLISHED DOCUMENTS DESCRIBE THE SAME FAMILYAS WRITTEN
Whole class, one lineThree programs list the family as a single prohibited entry. One of the three states its category covers more than twenty-five individual parabens.CLASS
Eight named, all propyl or butyl typeOne program’s customer page names propyl- and butyl-parabens. Its underlying list names eight: butyl, propyl, sodium propyl, sodium butyl, potassium propyl, potassium butyl, isobutyl and isopropyl.NAMED
Not named in that documentMethylparaben and ethylparaben, the two most commonly used members of the family.ABSENT
And one row that makes it genuinely unclearThe same list also carries a bare class row reading “Parabens” with no registry number attached to it.AMBIGUOUS
WE DO NOT RESOLVE THAT AMBIGUITY, AND NOBODY ELSE SHOULD EITHERThe bare class row could mean the whole family is covered and the eight named entries are illustrative, or it could mean something narrower. The document does not say. We report both the named entries and the class row and stop there, because reading an intention into somebody else’s standard is how this subject gets reported wrongly.
A FOURTH PROGRAM’S SHOPPER LIST NAMES ONLY TWO PARABENS, AND SAYS ITSELF IT SHOWS “MANY OF” ITS BANNED INGREDIENTSPARTIAL BY ITS OWN WORDS
3exclude the class
8named individually by one
2common ones unnamed
How they position itThe ability to say exactly where two standards diverge, and to refuse to guess where a document is silent, is the credential this address would carry.
14

Who Actually Checks

Attestation, verification, or nothing stated
🔒 cleangirlusa.com
GuaranteeCertifyVerify Read the verbs

Read the verb.
It is doing all
of the work.

Four programs describe how compliance is established and each uses a different verb. One says brands guarantee. One says brands certify. One says products have been verified. One says nothing at all. The verb is the whole mechanism.

HOW COMPLIANCE IS ESTABLISHED · EACH PROGRAM’S OWN WORDINGQUOTED
“brands guarantee to us that they comply”The same program adds that brands undertake their own internal testing so that they are in a position to confirm compliance to the retailer. Its corporate policy applies third-party testing and audits to its own private label, and states no equivalent for the brands carrying the seal.
“brands ... certify with [the program] that they comply”The program separately names a technology partner that it says verifies ingredients, packaging and product claims.
“have been verified to be free of all chemicals on the [list]”Stated as of January 2023. The same retailer describes a separate animal-testing attribute as designated and validated by each brand.
No mechanism statedNeither the announcement nor the list document describes a verification or an attestation step. We report the absence and do not characterize it in either direction.
WHY WE QUOTE EACH ONE RATHER THAN SUMMARIZING THEM TOGETHERGuarantee, certify and verify are three different allocations of responsibility, and generalizing one program’s mechanism onto another would misdescribe both. A brand choosing where to sell, and a buyer reading a seal, are looking at four different arrangements wearing one word.
NOTHING ON THIS CARD SAYS ANY PROGRAM CHECKS TOO LITTLE. IT SAYS THEY CHECK DIFFERENTLY, IN THEIR OWN WORDS.STATED CAREFULLY
4different verbs
1that states no mechanism
0we characterize for them
How they position itQuoting four verbs instead of flattening them into one sentence is the difference between a page a compliance lead reads and a page they close.
15

Absence Is Not Permission

The sentence three of these documents print about themselves
🔒 cleangirlusa.com
PartialStatedLimits Read the limits

The lists say
they are not
the whole list.

The most misread thing in this subject is an empty cell. Three of these programs state in their own documents that what they publish is partial. An ingredient missing from a published list tells you about the document, not about the product.

WHAT THE DOCUMENTS SAY ABOUT THEIR OWN COMPLETENESSTHEIR WORDS
Note to product suppliers: This list is intended for our shoppers. It’s not for use in formulating products as it doesn’t include all ... requirements and ingredient restrictions. Creating a product with no unacceptable ingredients does not guarantee that we will sell it.ONE RETAILER’S PUBLISHED NOTE, ON ITS OWN LIST
“not an exhaustive list of all prohibited or restricted substances”A second program, which adds that brands are responsible for working with their chemists, contract manufacturers and suppliers to ensure compliance.
“Below are many of the ingredients we’ve banned”A third, whose published list runs to 192 entries against a stated total of more than 240.
SO EVERY GRAY CELL ON CARD 11 CARRIES THIS CAVEAT, AND WE SAY SO THERE TOOWhen this page reports that an ingredient is not on a list, that is a statement about the published document on the date we read it. It is not a statement that the retailer permits the ingredient, and it is not a criticism of anyone. The alternative, which is to stay silent about what the documents contain, would be less useful and no more accurate.
ONE PROGRAM PUBLISHES 192 ENTRIES AGAINST ITS OWN STATED TOTAL OF MORE THAN 240. BOTH NUMBERS ARE ITS OWN.AS PUBLISHED
3that say so in writing
1aimed at formulators
0complete lists
How they position itA page that states the limits of its own evidence is the only kind a regulated industry will cite, and citation is what an exact-match name is actually for.
16

The Case The Published Definition Won

What saved a retailer in federal court
🔒 cleangirlusa.com
Finster901Dismissed Read the ruling

It survived
because the
list was public.

A federal court was asked whether a clean seal misled a reasonable consumer. The complaint was dismissed, and the reason is the most practical thing in this entire subject: the retailer had published a specific list of what the seal meant.

FINSTER v. SEPHORA USA, INC. · NO. 6:22-CV-1187 · N.D.N.Y.REPORTED DECISION
MOTION TO DISMISSGRANTED, WITH LEAVE TO AMEND BY MARCH 29, 2024
The allegationThat the seal implied the products were free of synthetic or harmful ingredients.
The court“Plaintiff’s complaint leaves the Court guessing as to how a reasonable consumer could mistake the ‘Clean at Sephora’ labeling and/or marketing to reasonably believe that the cosmetics contain no synthetic or harmful ingredients whatsoever.”
What it leaned onThat the retailer’s own marketing said products were formulated without specific named ingredients, and claimed nothing broader than that.
THE LESSON, AND IT IS THE REASON CARD 06 EXISTSThe defense was not that the word is meaningless. The defense was that the seller had published its own definition, so the published definition is what a reasonable consumer was taken to have read. An undefined claim would have had nothing to point at.
DISMISSED WITH LEAVE TO AMEND IS NOT A FINAL JUDGMENT. WE DID NOT VERIFY HOW THE CASE FINALLY TERMINATED AND DO NOT ASSERT ONE.STATED PRECISELY
2024-03-15the decision
1reason it turned on
0rulings about the word itself
How they position itThe one fact a brand lawyer in this category needs, read out of the primary document and dated, is what makes an exact-match name into an asset.
17

And The One That Went The Other Way

Six months later, the opposite result
🔒 cleangirlusa.com
BoydDeniedCuration Read the order

Same word.
Different court.
Opposite ruling.

Six months after the first decision, a second federal court faced the same theory against a different retailer and denied the motion to dismiss outright. The distinguishing idea was not the ingredient list. It was what a shopper assumes a retailer has done for them.

BOYD v. TARGET CORP. · NO. 23-CV-02668 (KMM/DJF) · D. MINN.REPORTED DECISION
MOTION TO DISMISS AND MOTION TO STRIKEBOTH DENIED
The court“only Target’s representation that a product is ‘Target Clean’ suggests that Target has done some work on their behalf.”
What proceedsFraud-based claims, breach of warranty, unjust enrichment, and consumer protection claims under the laws of a dozen states.
The idea doing the workCuration. A retailer that applies its own program between the manufacturer and the shopper may be taken to have assessed something.
WHAT A DENIED MOTION TO DISMISS IS, AND WHAT IT ABSOLUTELY IS NOTIt is a ruling that the allegations are legally sufficient to proceed. It is not a finding that anything alleged is true, and it is not a finding that any product was mislabeled or that any company did anything wrong. Nothing on this page should be read as saying otherwise about any party in either case.
TWO FEDERAL COURTS, SEVEN MONTHS APART, OPPOSITE OUTCOMES ON THE SAME THEORY. THAT IS THE STATE OF THE LAW.THE FINDING
2024-09-25the order
2motions denied
0findings of wrongdoing
How they position itHolding two opposite decisions side by side, with the postures stated exactly, is the kind of accuracy that makes a domain look like a publication.
18

The Referee With No Whistle

Who actually hears these complaints, and what they can do
🔒 cleangirlusa.com
VoluntaryRecommendRefer See the powers

It is not a court.
It is not an agency.
Taking part is optional.

Most challenges to these words are not heard by a government body at all. They go to an industry self-regulatory panel that cannot fine anyone, cannot enjoin anyone, and issues recommendations. Its only real lever is a referral.

INDUSTRY SELF-REGULATION · WHAT IT IS AND WHAT IT CAN DONOT A REGULATOR
CANNOTFine
CANNOTEnjoin
CANNOTFind a violation of law
CANRecommend
CANRefer to the agency
ANDParticipation is voluntary
A CLEAN CLAIM, 2024A panel reviewed a claim that a brand bans over two thousand ingredients known to be toxic. It recommended the claim be modified to better reflect ingredients typically used in cosmetics products. The advertiser said it would comply while disagreeing in part.
A NATURAL CLAIM, 2023, UPHELDIn a different matter the panel and its appeal board found a reasonable basis for a natural claim, and the appeal board stated that an analysis of consumer expectation is the proper standard for what is or is not natural. These words are not automatically indefensible.
THE TWO MOST-CITED “NON-TOXIC” DECISIONS IN THIS AREA ARE ABOUT HOUSEHOLD CLEANERS, NOT COSMETICS. WE DO NOT CITE THEM AS COSMETICS PRECEDENT.OUR NOTE
1971founded by the industry
0fines it can impose
1lever it actually has
How they position itKnowing which body hears these disputes, and that it cannot fine anyone, is the first thing a brand entering this category gets wrong.
19

No Accredited Standard Exists

We searched the standards catalog for it
🔒 cleangirlusa.com
ANSINSFZero Run the search

The national
standards catalog
returns nothing.

If any American body had written a real standard for this word it would be in the national standards catalog. We searched it. The two American standards that do exist for personal care cover organic content and claim verification, and neither defines clean.

AMERICAN NATIONAL STANDARDS CATALOG · SEARCHED OCTOBER 1, 2026OUR SEARCH
“clean beauty”“Sorry, your search returned no results.”0
“clean”Cleanrooms, medical device cleaning, vacuum cleaners81
“cosmetic”No American national standard defining any of these words115
“personal care products”Two American national standards, named below19
ORGANIC CONTENTNSF/ANSI 305Sets a minimum organic content and the claim that goes with it. Explicitly does not cover products labeled under the federal organic program.
SAFETY, PURITY AND CLAIMSNSF/ANSI 527Verifies specific ingredient-based claims. Does not define clean or natural.
AND THE INTERNATIONAL DOCUMENT EVERYONE CITES, READ AS FAR AS ITS PAYWALL ALLOWSThere is an international guideline on natural and organic cosmetic ingredients. Its own scope clause states that it does not address product communication, including claims and labeling. We could not read past the free preview, so we quote the scope exclusion and nothing else, and we do not state what its thresholds are because we have not read them.
EVERYTHING ELSE SOLD AS A CLEAN STANDARD IN THIS COUNTRY IS A PRIVATE PROGRAM. THAT IS A DESCRIPTION, NOT A CRITICISM.STATED PLAINLY
0results for the phrase
2American standards that exist
0that define the word
How they position itSearching the catalog that would settle the question, and publishing the empty result with the query attached, is the most defensible thing a page can do.
20

What This Page Will Not Say

The claims we refused, published so they can be checked
🔒 cleangirlusa.com
MethodRefusalsSources See the list

Eight things
we would not
put in print.

Every figure here names its source and its date. These are the statements that could not be made that way, so they are not made at all, and the list is published so a buyer can hold us to it.

DELIBERATE OMISSIONS · PUBLISHED SO THEY CAN BE CHECKEDNOT STATED
01Any ranking of these programs from strictest to laxest. The counts use different units, the documents cover different product ranges, and one is an allow-list as well as a deny-list. A ranking would be our construct, not a finding. Card 10 is the long version of this refusal.
02Any statement that a named retailer, brand, certifier or person is non-compliant, deceptive or greenwashing. Nothing in our research supports it, and the two court cards describe postures rather than conduct.
03Any market size for clean beauty. No federal series isolates it, because the category has no official definition to isolate. Every figure in circulation is a private model. One widely repeated projection circulates as though it were government data because it appears in a hearing transcript; it is one witness’s prepared testimony from 2019, projecting to a year now in the past.
04Any absolute search volume for either phrase. The tool returns an index, not a count, and vendor volume estimates are modeled. Card 05 prints index values from one shared comparison and never mixes scales.
05That the words are interchangeable in legal risk. They are not. One has no definition anywhere. One has a real enforcement record and a consumer-expectation test advertisers have won under. One has federal and state hooks. Flattening them would be the most useful-sounding error available.
06That cosmetics are unregulated in the United States. The premise behind that line is sound and the inference is false. What is absent is a definition of this marketing word, not a regulator.
07Any conclusion about whether this name is registrable or available as a trademark. We report the public record on card 04 and stop. Clearance is counsel’s work.
08Any consumer-perception percentage. Every figure we found traces to a brand-commissioned or panel survey. The legal test in this area genuinely is consumer expectation, which makes dressing a marketing survey up as a legal standard tempting and wrong.
EVERY NUMBER ON THIS SITE CARRIES ITS SOURCE AND ITS DATETHE STANDARD
8refused claims
0rankings published
100%sourced
How they position itThe omissions list is the strongest sales asset on the page. It tells a buyer exactly what kind of operator built this and what standard the address already carries.
Own it

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2

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