The "All Mineral" Sunscreen Fraud
If a consumer wants an all-mineral sunscreen, they have a right to actually get one. Whether mineral-only formulas are superior to those containing organic filters (or a hybrid of both) is a debate worth having. But that's not what this post is about.
This is about the fact that achieving SPF 30+ in a truly all-mineral system that is also cosmetically elegant with no white cast is not possible. No white cast, elegance, high SPF - pick one, maybe two. Tinting helps, but only for a subset of products. So how are hundreds of brands delivering SPF 30+ all-mineral formulas? They aren't.
The trick they're using is Butyloctyl Salicylate (BOS). It shares the identical UV-absorbing chromophore as Octisalate (a regulated OTC sunscreen active) and differs only by the length of an attached hydrocarbon chain:
That structural tweak was enough to exclude it from the FDA's sunscreen monograph when it was patented and introduced in the 1990s. It gets listed as an inactive ingredient, typically attributed to its emollient or solubilizing properties.
It does serve those functions. But that's not why it's in there.
It's in there to absorb UVB and push SPF numbers higher so brands can print a higher SPF on the label without disclosing the organic filter partially responsible for it. There are no FDA-mandated concentration limits on it either, meaning it can be used well above the 5% cap that applies to its regulated analog, Octisalate. It can't be listed as an active, but is one and you can use as much as you want without being clear why. What brand truly interested in transparency and consumer choice would do this?
This is currently legal (but it isn't, in my opinion, defensible.) Consumers should not have to cross-reference the inactive ingredients list to find out whether the "all mineral" product claimed on the front of the tube is actually what's inside it.
To be clear, burnd does not necessarily think BOS is a bad chemical, but it has not been studied as a sunscreen in the concentration many brands are using it at. That along with the deceptive behavior is what we think is the problem.
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