The Ugly Truth About Clinically Tested Skin Care & Darker Skin Tones

When you’re shopping for a new skin care product, from cleansers and moisturizers to toners and serums, there are likely a few things that you look for on the label before plunking down your credit card to buy it. Whether that’s organic, clean, or cruelty-free, one of the most highly regarded markers of quality is “clinically tested,” meaning the product is “clinically proven” skin care that (by most metrics) actually does what it claims to do.

The term has become popular as skin care brands continue to compete for authority using scientific innovation and strong effectiveness claims. Seeing the statement on your product is meant to elicit an overall sense of trust that it will more likely deliver on its promises, whatever they may be. However, further inspection of what cosmetic testing actually looks like reveals gaps that may change your perspective on the process, namely, a historical lack of diversity amongst testing subjects that is critical enough to skew results.

As the stakes continue to rise, TZR investigated how to contextualize clinical testing in 2022 in order to avoid putting blind trust in beauty, and to feel more confident in the products you’re buying for your skin, especially for shoppers with darker skin tones.

What Does “Clinically Tested” Mean?

When thinking about clinical testing and skin care claims, it’s important to remember the beauty industry is up against very few regulations (at least in the United States). “As a skin care brand we only have two requirements,” says Joyce de Lemos, chief product officer and co-founder of Dieux Skin. “We have to do the quality testing to make sure our products don’t hurt anyone, and we have to make sure any claims we make are substantiated, but there’s no real protocol for holding companies responsible.”

However, this doesn’t mean skin care brands can weave tall tales about a product’s effectiveness. When a product has a direct claim, like the ability to fade hyperpigmentation, brands are vulnerable to legal action without research-backed receipts. “There are independent organizations that look through all of these brands’ claims to take them down. These are legal companies,” adds Charlotte Palermino, CEO and co-founder of Dieux. Despite large beauty companies recently grappling with class-action lawsuits, some brands still avoid validating their claims altogether and succeed in flying under the radar.

Aside from providing a legal cushion, the ultimate goal of testing is to give product benefits unbiased, scientific testimony. This approach isn’t the only way to create great skin care, but it provides credible legitimacy. “It’s the only objective way to say this [product] does what it says it does,” says Alice Lin Glover, co-founder of EADEM. Validating data is particularly important for skin care brands, like EADEM, that target multicultural consumers and are often forced to defend their stance. EADEM not only creates products specifically formulated for women of color but is also one of few brands that exclusively used ethnic skin types in their clinical trials. “You should know before you go into a clinical study that your product is going to work,” says Lin Glover. “We know our products work, but we did it to prove in the industry that [our product] was needed and it was necessary because some people still think [multiculturalism] is a marketing ploy.”

The Different Types Of Product Testing

In an ideal world, clinical data would be the difference between an impressive beauty product and a dud, but not all clinical testing is similar or equal. The umbrella term includes several different testing levels that are not always made clear to consumers. “There are three different types of testing you can do,” says Blair Lawson, chief marketing and merchandising officer at Beautycounter.

Consumer Perception Studies

“The first [type of clinical testing] is you send [panelists] the product and you have them try it according to your instructions,” says Lawson. “Then you have them fill out a questionnaire at the four and eight-week mark. You’re asking them if the product does what you’re expecting and hoping. We call that consumer perception because that’s what it is. It’s not a scientific clinical trial.”

These studies can be conducted anonymously using the same third-party labs typically hired to perform advanced trials, but many brands opt to complete these surveys themselves due to funding constraints. This method may threaten the objectivity of the study, but can still be marketed as a clinical test. “It’s not the best type of study, but over the last two years it was done a lot more because of COVID,” says board-certified dermatologist Dr. Dhaval G. Bhanusali, who has overseen clinical testing for both pharmaceutical drugs and cosmetics. “For smaller brands, you have to look at what is possible and what isn’t possible. Consumer perception is the bare minimum.”

Instrumentation Tests & Visual Grading

Experts primarily differentiate between additional testing second and third testing groups by the extent of the trials performed. “The second bucket is instrumentation tests and clinical expert visual grading,” says Lawson.

Similar to consumer perception studies, a specific subject group uses a product and change is recorded over time in a lab setting. “You use an instrument in the lab, so you measure with a tool whether the skin is, for example, more hydrated. Clinical expert visual grading assesses images before and after a certain time,” she says. Although these tests follow traditional rules of experimentation with concrete measurements, the lack of industry standards around benchmarks can muddy the results. “The landscape is really opaque and murky and because of that people can get away with a lot,” says de Lemos. “There’s a certain number of panelists that use your product but what’s important to one brand may be 50 people while another brand uses five. There’s a level of specificity that’s required like, what other products were the subjects using during the clinical?”

A Lack Of Diversity In Tester Demographics

The demographics of clinical trial panelists also heavily influence a test’s outcome. A dark spot product may have different results on a panel of older subjects dealing with age spots as opposed to a younger panel of people suffering from acne-related discoloration. “It goes even further than that,” says Marie Kouadio Amouzame, co-founder and CEO of EADEM. “Even irritation testing, RIPT, that basically says the product isn’t going to irritate or burn the skin — those panels are usually not diverse. We know skin of color tends to react or have more irritation and [brands] don’t test if the product won’t have these effects on darker skin.”

Unfortunately, most brands are at the mercy of predetermined panelist databases, which are notoriously not diverse. “Historically, [lighter skin tones] were the ‘preferred’ skin tone in terms of testing, at least in Asia and parts of Europe,” explains de Lemos. “So that bled over into what’s available for [consumer research organizations] and testing models developed in the United States.”

Already high testing costs and tight product launch timelines have encouraged the industry to turn the cheek to this reality, putting smaller and BIPOC-focused brands on the chopping block. For example, while building their all-PoC testing group, EADEM was either turned away from labs or met with panelists recruiting upcharges that extended their timeline by a year. With basic clinical trials averaging around $50,000, EADEM’s trailblazing approach is often out of scope for similar companies.

Like in most cases, the power to create change lies with influential industry players with deeper pockets. “If nobody asks [labs] to go above and beyond or change their ways, why would they even do that?” says Amouzame. “Bigger brands that have the budgets to do so should say something about it. Once these brands have invested money in creating diverse panels, it makes it easier for the labs to recruit [diverse subjects] again and again.”

What Consumers Need To Know When Shopping For Products

As clinical testing becomes something like an industry standard for new and established skin care brands, keep in mind not all products require it to be effective and have trustworthy claims. “There are individual studies on individual ingredients. I know retinol improves wrinkles,” says Dr. Bhanusali. “You don’t want [brands] to waste money [on clinical testing] when you [already] know things are going to work. The science says niacinamide at 6% is great for pigmentation. If [a product] had a .02% I’d be more concerned.” Even formulas featuring more novel ingredients can be dependably vetted without clinical research via structured, community feedback or consumer-specific task forces that help brands gather scientifically significant information.

What the industry understands about skin science and testing is constantly evolving, so it’s important to realize consumers are unlikely to ever have the full picture about their products. By no means should you discredit the value of clinical testing, but seeking out brands that are transparent about their formulation methods, regardless, can help you feel more confident when deciding on your next beauty purchase. “As a consumer it’s about asking the right questions and not being afraid,” says Amouzame. “If a brand claims they are made for skin of color they should be able to tell you what they mean by that.”

A firm grasp on the vulnerabilities of clinical testing and product claims will also help cut through the marketing fluff and get closer to a beauty product that works for you. “If you understand [the differences in testing] as a consumer you can understand a little better how powerful the words are,” says Lawson. “You have insight on what was behind the testing, what was the process, and what those results are actually telling you.”