‘Reef safe’ sunscreen, decoded: what Hawaii’s law covers, what the FDA says, and four labels graded

The short version

• “Reef safe” has no legal definition in the US. It’s a marketing phrase. What is law: Hawaii bans the sale of sunscreen containing oxybenzone or octinoxate without a prescription, since January 1, 2021. That’s the whole statewide list. [1]
• “Hawaii Act 104 compliant” only means those two filters are absent. A 2021 bill to add avobenzone and octocrylene passed the state Senate but did not become law; the current statute still names only the original two. [1][2]
• The FDA, for human safety, calls only zinc oxide and titanium dioxide GRASE (generally recognised as safe and effective) under its 2021 proposed order. It says twelve other filters, including avobenzone, homosalate, octisalate and octocrylene, need more data, and stresses that this “does not represent a conclusion … that [they] are unsafe.” [3]
• Mineral isn’t automatically coral-proof. In a lab study, uncoated zinc oxide nanoparticles caused “severe and fast coral bleaching” in Acropora corals; two coated titanium dioxide forms did not. [4]
• The reef science is still young. The US National Academies’ 2022 review asked the EPA to run an ecological risk assessment of UV filters, focused on heavily used beaches and wastewater outfalls. [5]

Product	Scope Grade	Why	Buy
Badger Reef Safe Mineral Sunscreen SPF 50Buy on Amazon: Badger Reef Safe Mineral Sunscreen SPF 50 (opens in a new tab)	B	25% non-nano uncoated zinc oxide, three inactives; “reef safe” still undefined	Buy on Amazon: Badger Reef Safe Mineral Sunscreen SPF 50 (opens in a new tab)
Thinksport Mineral Sunscreen SPF 50+Buy on Amazon: Thinksport Mineral Sunscreen SPF 50+ (opens in a new tab)	C	23.4% zinc oxide; particle form undisclosed; grapefruit peel oil and “natural fragrance oil”	Buy on Amazon: Thinksport Mineral Sunscreen SPF 50+ (opens in a new tab)
Thrive Natural Care Reef Safe Sunscreen SPF 50Buy on Amazon: Thrive Natural Care Reef Safe Sunscreen SPF 50 (opens in a new tab)	C	23.5% non-nano zinc oxide; adds an unsupported “restore sun-damaged skin” claim	Buy on Amazon: Thrive Natural Care Reef Safe Sunscreen SPF 50 (opens in a new tab)
Sun Bum Original SPF 50 Sunscreen LotionBuy on Amazon: Sun Bum Original SPF 50 Sunscreen Lotion (opens in a new tab)	C	“Hawaii 104 compliant” is true; four organic filters FDA wants more data on, plus fragrance and MI	Buy on Amazon: Sun Bum Original SPF 50 Sunscreen Lotion (opens in a new tab)

Products we read

As an Amazon Associate, FORMUSCOPE earns from qualifying purchases. Prices live on Amazon and change often, so we don’t show them. Links never change a grade.

Our pick if reefs are why you’re shopping: Badger. It’s the shortest, most transparent formula here, and it names the zinc oxide form. If you’re simply buying a good SPF 50: all four are broad-spectrum SPF 50 products sold under FDA’s OTC monograph, and the best sunscreen is the one you’ll reapply.

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What the law and the regulators actually say

Hawaii (statute). “Beginning January 1, 2021, it shall be unlawful to sell, offer for sale, or distribute for sale in the State any sunscreen that contains oxybenzone or octinoxate, or both, without a prescription issued by a licensed healthcare provider.” The definition of sunscreen excludes products marketed as cosmetics for the face. [1]

Hawaii (bill that didn’t pass). SB132 SD2 (2021) would have added: “Beginning January 1, 2023, it shall be unlawful to sell … any sunscreen that contains avobenzone or octocrylene.” [2] The current statute text contains no such clause. [1]

US FDA (human safety). The 2021 proposed order “proposes GRASE status for sunscreens containing zinc oxide and/or titanium dioxide” (up to 25%), removes PABA and trolamine salicylate (finalised September 2026), and lists cinoxate, dioxybenzone, ensulizole, homosalate, meradimate, octinoxate, octisalate, octocrylene, padimate O, sulisobenzone, oxybenzone and avobenzone as needing more data. In June 2026 FDA also added bemotrizinol as a new monograph filter. [3] The underlying 2019 proposed rule is on the Federal Register. [6]

Coral studies. Downs et al. (2016) found oxybenzone deformed coral larvae, caused bleaching and DNA damage in a concentration-dependent way, and worsened in light. [7] Corinaldesi et al. (2018) found uncoated nano zinc oxide bleached Acropora corals quickly, while two modified titanium dioxide forms caused minimal change. [4] These are lab exposures; real-world dose at a reef is the open question the National Academies flagged. [5]

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The labels

1. Badger Reef Safe Mineral Sunscreen SPF 50: Scope Grade B (Supported, with caveats)

The claim (Amazon listing, sold by BadgerBalm, captured Nov 13, 2026): “Broad Spectrum SPF 50 protection using non-nano uncoated Zinc Oxide“; “REEF SAFE … fully compliant with Hawaii and Mexico reef-safe sunscreen laws, containing no oxybenzone or octinoxate”; “the first formula to achieve Protect Land + Sea Certification”.

The formula (Drug Facts on the listing [8]): Active Ingredient: Zinc Oxide 25%. Inactive Ingredients: Organic Sunflower Seed Oil, Beeswax, Sunflower Vitamin E

Check	Finding	Effect
Filter status	Zinc oxide is the filter FDA proposes as GRASE, at its 25% ceiling [3]	Strong
Coral evidence	The bleaching study used nano uncoated ZnO [4]; this is non-nano, which that study didn’t test	No evidence of harm, no proof of safety
Hawaii compliance	No oxybenzone or octinoxate [1]	True
Claim match	“Reef safe” is undefined; the certification is a third-party label we haven’t audited	Caps at B

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2. Thinksport Mineral Sunscreen SPF 50+: Scope Grade C (Plausible, thin evidence)

The claim (Amazon listing, sold by Thinkbaby & Thinksport, captured Nov 13, 2026): “gentle and reef-safe ingredient based clean sunscreen”; “suitable for sensitive skin”.

The formula (Drug Facts on the listing [9]): Active Ingredient: Zinc Oxide 23.4% with caprylic/capric triglyceride, polyglyceryl-4 isostearate and plant oils, then Citrus Paradisi (Pink Grapefruit) Peel Oil and, last, “Natural Fragrance Oil”.

Check	Finding	Effect
Filter status	Zinc oxide only [3]	Strong
Coral evidence	Particle size and coating aren’t stated, so we can’t say whether the nano-ZnO study applies [4]	Unknown
Formula vs “sensitive skin”	Citrus peel oil and an unnamed fragrance oil are odd choices for a “sensitive skin” claim	Caveat
Claim match	“Reef-safe ingredient based” is hedged wording for an undefined term	C

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3. Thrive Natural Care Reef Safe Sunscreen SPF 50: Scope Grade C (Plausible, thin evidence)

The claim (Amazon listing, sold by Thrive Natural Care, captured Nov 13, 2026): “REEF SAFE SUNSCREEN 23.5% NON-NANO ZINC OXIDE”; “formulated without Oxybenzone or Octinoxate to help protect fragile reef ecosystems”; “helps restore skin damaged by sun using clinically-proven natural ingredients”.

The formula (listing [10]): inactive ingredients include plant esters and extracts, then “Natural fragrance (of orange, grapefruit, lemon, anise, guaiacwood, cedarwood, peppermint, davana, patchouli, vetiver oils)”.

Check	Finding	Effect
Filter status	Non-nano zinc oxide [3]	Strong
Extra claim	“Restore skin damaged by sun” with “clinically-proven natural ingredients”: no study named, and repair isn’t a sunscreen claim	Unsupported
Formula notes	Ten essential oils in a sunscreen	Caution for fragrance-sensitive skin
Claim match	Reef wording is as undefined as everyone else’s	C

If Thrive publishes the study behind the restoration claim, we’ll re-grade.

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4. Sun Bum Original SPF 50 Sunscreen Lotion: Scope Grade C (Plausible, thin evidence)

The claim (Amazon listing, sold by Amazon.com, captured Nov 13, 2026): “Hawaii 104 Reef Act Compliant”; “all of our mineral and non-mineral sunscreen products throughout the U.S. are made without Oxybenzone and Octinoxate.”

The formula (Drug Facts on the listing [11]): Actives: Avobenzone 3%, Homosalate 10%, Octisalate 5%, Octocrylene 10%, with inactives including fragrance and methylisothiazolinone.

Check	Finding	Effect
Hawaii claim	True: neither banned filter is present [1]	Accurate
FDA status	All four actives are in FDA’s “additional data needed” group (not a finding that they’re unsafe) [3]	Noted
Implied reef benefit	Avobenzone and octocrylene were the filters Hawaii’s Senate tried to add in 2021 [2]	The compliance badge says less than it seems
Formula notes	Fragrance plus methylisothiazolinone (MI), named Allergen of the Year in 2013 [13]	Caution for sensitive skin

Fair note: this is a widely liked, broad-spectrum SPF 50. Our C is about how much the “reef” badge implies, not about sun protection.

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• Claimed / hero active
• Fragrance & allergens
• Preservatives
• Everything else

Badger SPF 50 4 ingredients

• #1 Zinc Oxide

Thinksport SPF 50+ 23 ingredients

• #1 Zinc Oxide
• #16 Citrus Paradisi (Pink Grapefruit) Peel Oil
• #20 Caprylhydroxamic Acid
• #23 Natural Fragrance Oil

Thrive SPF 50 27 ingredients

• #1 Zinc Oxide
• #26 Caprylhydroxamic Acid
• #27 Natural fragrance (essential oils)

Sun Bum SPF 50 28 ingredients

• #1 Avobenzone
• #2 Homosalate
• #3 Octisalate
• #4 Octocrylene
• #17 Fragrance
• #24 Polyaminopropyl Biguanide
• #28 Methylisothiazolinone

Each square is one ingredient, in label order. Original FORMUSCOPE graphic. Hover or tap a square for its name.

Actives are shown first (Drug Facts lists them separately), then inactives in label order.

The 20-second “reef” label check

1. Read the Drug Facts “Active ingredients” box, not the front. Zinc oxide and/or titanium dioxide only = mineral.
2. “Hawaii 104 compliant” = no oxybenzone, no octinoxate. Nothing more.
3. For mineral formulas, look for “non-nano” and “coated/uncoated”. The one coral study against zinc oxide used uncoated nanoparticles. [4]
4. Sensitive skin? Fragrance and citrus or mint oils are common in “natural” sunscreens. Check the tail of the list.

When to see a professional

Sunscreen is one part of sun protection, alongside shade and clothing. See a dermatologist about any new, changing or bleeding spot. If a sunscreen stings or causes a rash, stop using it; a dermatologist can patch-test you to find which filter or fragrance is responsible. FORMUSCOPE grades label claims; we don’t give medical advice.

Sources

1. Hawaii Revised Statutes §342D-21, Sale and distribution of sunscreen containing oxybenzone or octinoxate, or both; prohibition [L 2018, c 104, §2]. https://www.capitol.hawaii.gov/hrscurrent/Vol06_Ch0321-0344/HRS0342D/HRS_0342D-0021.htm (accessed Nov 13, 2026)
2. Hawaii State Legislature. SB132 SD2 (2021 session): proposed avobenzone/octocrylene ban. https://www.capitol.hawaii.gov/sessions/session2021/bills/SB132_SD2_.HTM (accessed Nov 13, 2026)
3. US FDA. Questions and Answers: FDA’s regulatory actions on over-the-counter sunscreen (2021 proposed order OTC000008; 2026 final orders). https://www.fda.gov/drugs/understanding-over-counter-medicines/questions-and-answers-fda-posts-deemed-final-order-and-proposed-order-over-counter-sunscreen (accessed Nov 13, 2026)
4. Corinaldesi C, et al. Impact of inorganic UV filters contained in sunscreen products on tropical stony corals (Acropora spp.). Sci Total Environ. 2018;637-638:1279-1285. [Lab exposure · corals · academic] https://pubmed.ncbi.nlm.nih.gov/29801220/
5. National Academies of Sciences, Engineering, and Medicine. Review of Fate, Exposure, and Effects of Sunscreens in Aquatic Environments and Implications for Sunscreen Usage and Human Health (2022). https://nap.nationalacademies.org/catalog/26381/review-of-fate-exposure-and-effects-of-sunscreens-in-aquatic-environments-and-implications-for-sunscreen-usage-and-human-health
6. US FDA. Sunscreen Drug Products for Over-the-Counter Human Use, proposed rule. Federal Register, Feb 26, 2019 (2019-03019). https://www.federalregister.gov/documents/2019/02/26/2019-03019/sunscreen-drug-products-for-over-the-counter-human-use
7. Downs CA, et al. Toxicopathological effects of the sunscreen UV filter, oxybenzone (benzophenone-3), on coral planulae and cultured primary cells and its environmental contamination in Hawaii and the U.S. Virgin Islands. Arch Environ Contam Toxicol. 2016;70(2):265-88. [Lab exposure · coral larvae and cells] https://pubmed.ncbi.nlm.nih.gov/26487337/
8. Badger Reef Safe Mineral Sunscreen SPF 50, 2.9 fl oz: Amazon listing (claims, Drug Facts). https://www.amazon.com/dp/B0CPN28L8N (accessed Nov 13, 2026)
9. Thinksport Mineral Sunscreen SPF 50+, 6 fl oz: Amazon listing (claims, Drug Facts). https://www.amazon.com/dp/B00K3JQO9Y (accessed Nov 13, 2026)
10. Thrive Natural Care Reef Safe Sunscreen SPF 50: Amazon listing (claims, ingredients). https://www.amazon.com/dp/B0B4342J6V (accessed Nov 13, 2026)
11. Sun Bum Original SPF 50 Sheer Sunscreen Body Lotion, 8 oz: Amazon listing (claims, Drug Facts). https://www.amazon.com/dp/B004XGPM32 (accessed Nov 13, 2026)
12. Scope Grade rubric v1.0. https://formuscope.com/methodology/
13. Castanedo-Tardana MP, Zug KA. Methylisothiazolinone. Dermatitis. 2013;24(1):2-6. [ACDS Allergen of the Year 2013] https://pubmed.ncbi.nlm.nih.gov/23340392/