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FDA Issues Final Order Removing PABA and Trolamine Salicylate as Sunscreen Active Ingredients

FDA Removes PABA & Trolamine Salicylate from Sunscreen Active Ingredients
FDA Removes PABA & Trolamine Salicylate from Sunscreen Active Ingredients


  • Following its evaluation of the available safety and benefit-risk information, FDA has removed PABA from the permitted active ingredients under the OTC sunscreen monograph.

Manufacturers, formulators, marketers, and other stakeholders should review their products and regulatory strategies to ensure alignment with the updated requirements.

Key considerations may include:

  • Reviewing existing and proposed sunscreen formulations for PABA and Trolamine Salicylate.
  • Assessing regulatory compliance of products intended for the U.S. market.
  • Reviewing product labeling, claims, specifications, and supporting documentation where applicable.
  • Ensuring appropriate quality and analytical testing throughout product development and manufacturing.
  • Monitoring further FDA updates to the OTC sunscreen monograph.

For organizations developing new sunscreen products for the U.S. market, early regulatory assessment can help identify potential compliance issues before commercialization.


This process is being carried out under the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020, which introduced a new administrative order process for establishing and updating OTC drug monographs. FDA issued a proposed sunscreen order in September 2021, which received more than 15,000 public comments.

The agency continues to evaluate other important aspects of sunscreen regulation, including matters related to:

  • SPF levels
  • Labeling requirements
  • Permitted dosage forms
  • Other provisions of the OTC sunscreen monograph

Regular monitoring of regulatory developments can therefore help manufacturers:

  • Identify potential compliance gaps early.
  • Evaluate formulations against current requirements.
  • Maintain appropriate product quality and safety standards.
  • Prepare for changes in regulatory expectations.
  • Support smoother product development and market-entry decisions.

By combining reliable analytical testing with technical and regulatory expertise, we help organizations make informed decisions and maintain confidence in the quality, safety, and compliance of their products.

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