Does Hawaii's reef sunscreen ban apply to SPF lip balm?

Almost certainly, if it holds oxybenzone or octinoxate. The statute's words, the face cosmetic gap, the INCI names to look for, and Maui, the USVI and Key West.

Very likely yes, if the balm contains oxybenzone or octinoxate. Since 1 January 2021, Hawaii law has made it unlawful to sell sunscreen with either filter without a prescription. The law defines "sunscreen" as any product "marketed or intended for topical use to prevent sunburn". An SPF lip balm is sold for exactly that. There is one gap. The definition leaves out products marketed as a cosmetic "for the face". Nobody has ruled on whether lips fall inside that. So do not rely on the gap. Turn the tube over and read the filters. If you see oxybenzone, octinoxate, benzophenone-3 or ethylhexyl methoxycinnamate, it cannot be sold in Hawaii. In Maui County and the US Virgin Islands the rules go further. They reach the balm in your pocket too.

• Hawaii: oxybenzone, octinoxate
• In force from 1 Jan 2021
• CAS 131-57-7 and 5466-77-3
• Maui County: mineral only
• USVI: octocrylene too
• Key West: never in force

What the law means by "sunscreen"

The law is section 342D-21 of the Hawaii Revised Statutes. It was added by Act 104 of 2018, approved on 3 July 2018. The core rule is one sentence. From 1 January 2021, it is 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."

Everything turns on the word sunscreen, so here is the law's own definition, in full:

"Sunscreen" means a product marketed or intended for topical use to prevent sunburn. Sunscreen does not include products marketed or intended for use as a cosmetic, as defined in section 328-1, for the face.

That definition has two parts. The first part is wide. "Topical" means put on the skin. It says nothing about the product's form, size or name. A lotion, a spray, a stick and a lip balm are all caught. What matters is that the product is sold or meant to prevent sunburn.

The second part is the exclusion. It refers to the Hawaii food and drug law for the meaning of cosmetic. Section 328-1 defines a cosmetic as an article applied to the body "for cleansing, beautifying, promoting attractiveness, or altering the appearance". So the exclusion is for face products sold to make you look a certain way. The plain reading is foundation, tinted moisturiser or make-up that happens to carry an SPF.

The ban is about sale, not about you. The words are "sell, offer for sale, or distribute for sale". Nothing in section 342D-21 makes it unlawful to bring your own tube to Hawaii or to use it on the beach. The prescription route is real but narrow. It needs a physician, an osteopathic physician or an advanced practice registered nurse licensed in the state.

The law sits in Hawaii's water pollution chapter, and Act 104 explains why. Its findings say both filters "cause mortality in developing coral" and add to coral bleaching. They name reef sites where the chemicals were found. These include Hanauma Bay and Waikiki on Oahu, and Honolua Bay on Maui. This page does not weigh that science. It reads the rule the science produced.

Is an SPF lip balm "sunscreen" under Hawaii law?

Two answers circulate, and that is why this question gets asked. One says lip balm is a cosmetic for the face, so it is exempt. The other says any product with an SPF is sunscreen, so it is covered. The second is the safer reading by a wide margin, and here is why.

An SPF number is a claim to prevent sunburn. SPF stands for sun protection factor. It is measured as protection against sunburn redness, as choosing an SPF lip balm explains. A balm that prints SPF 15 on the front is "marketed ... to prevent sunburn" in the plainest sense. In the United States, that claim also makes it an over-the-counter drug rather than a cosmetic. That is covered at SPF in lip balm.

The exclusion is harder to reach. It covers products marketed "as a cosmetic" for the face. A plain SPF lip balm is sold to protect and soothe lips, not to beautify them. That is not the cosmetic purpose section 328-1 describes. A tinted lipstick with SPF is a better candidate for the exclusion, because it is sold for colour. But even there, nothing settles it.

We found no court ruling, Department of Health rule or published guidance that says whether lip products fall inside the face exclusion. So the honest position is that the gap exists but is untested. For a buyer that makes the question easy: you do not need the gap. You can simply choose a balm without those two filters. For a seller it is a different matter. Under section 342D-30, fines under the same chapter run to $60,000 for each separate offence. Each day counts as a new offence. A shop that stocks an oxybenzone lip balm in Hawaii is betting on an argument nobody has won.

The other places on this page use the same definition, almost word for word. The US Virgin Islands law also excludes cosmetics "for use on the face". But it then names "balms" in its list of banned products. That is as close to a ruling on lip balm as any of these laws comes.

The two banned filters: CAS numbers and the names on the pack

A filter, in this context, is the ingredient that absorbs or blocks ultraviolet light. It is what gives a sunscreen its SPF. Hawaii's law names two filters. It pins each one down three ways: a chemical name, a CAS number and a list of synonyms. A CAS number is a unique ID that the Chemical Abstracts Service gives each chemical. It cannot be confused with a similar one.

On a US pack, the filters appear under "Active ingredients" in the Drug Facts box. Each has a percentage beside it. There they usually carry the names oxybenzone and octinoxate. On a pack made for Europe or the UK, they sit in the ordinary ingredient list under their INCI names. INCI is the international naming system for cosmetic ingredients, and INCI names explained sets out how it works. That means benzophenone-3 and ethylhexyl methoxycinnamate. Octyl methoxycinnamate, also listed in the statute, is another name for the same molecule.

The trade names in the last column, such as Parsol MCX or Eusolex 4360, are supplier names for the raw material. They matter if you make balm, or if you are reading a supplier's specification sheet.

One detail is worth knowing if you read the statute closely. Hawaii's text says each filter protects against light from "370 nanometers to 220 nanometers". The US Virgin Islands text gives 400 to 280 nanometers for the same two molecules. Both texts give the same CAS numbers, though, so they point at the same two chemicals.

Watch for a different filter with a similar name. Benzophenone-4 is a different chemical from benzophenone-3, and the Hawaii law does not name it. Neither are octisalate, homosalate or octocrylene. They are separate chemicals with separate CAS numbers.

Avobenzone and octocrylene: the bills that died

You will still read that Hawaii bans avobenzone and octocrylene. It does not. Bills to add them were filed in 2021 and never passed.

Senate Bill 132 would have amended section 342D-21. Its SD1 draft adds a new rule. From 1 January 2023, it bars the sale of "any sunscreen that contains avobenzone or octocrylene without a prescription". It defines avobenzone by CAS number 70356-09-1, with butyl methoxydibenzoylmethane, its INCI name, among the synonyms. It defines octocrylene by CAS number 6197-30-4. The House filed a matching bill, HB 102, with the same 2023 date.

SB 132 crossed to the House in March 2021 and was carried over to the 2022 session. Bill tracking records show it as dead on 5 May 2022. The 2023 date came and went with nothing in force. So under Hawaii state law today, a lip balm with avobenzone and octocrylene is lawful to sell. Maui County and Hawaii County are a different matter, covered below.

The failed bill also shows how the county rule worked. Section 342D-21(b) barred counties from passing their own sunscreen rules, but only "prior to January 1, 2021". SB 132 would have extended that bar to 2023 for the new filters. Because it died, the counties were free to go further. Two of them did.

A worked case: three lip balms on one trip

Take three lip balms a traveller might pack, and walk each one through the rules on this page. The labels are made up for the example. The rules are quoted from the sources at the foot of the page.

• Balm A, SPF 15. Drug Facts actives: octinoxate and oxybenzone.
• Balm B, SPF 30. Drug Facts actives: avobenzone, homosalate, octisalate and octocrylene.
• Balm C, SPF 30. Drug Facts active: zinc oxide only.

Now suppose the trip goes to Honolulu, then Maui, then St John in the US Virgin Islands, then home through Key West.

1. Honolulu, under state law. A shop cannot sell Balm A. It is marketed to prevent sunburn, it contains both banned filters, and the face exclusion is no safe harbour. Balms B and C can be sold. The traveller's own tube of Balm A is not touched by section 342D-21, which is about sale only.
2. Maui. Balm A and Balm B both use non-mineral actives. Under Ordinance 5306, neither can be sold, distributed or used here. That includes the tube in the traveller's pocket. Only Balm C is allowed.
3. St John, US Virgin Islands. Balm A contains oxybenzone and octinoxate. Balm B contains octocrylene. The Act bans selling, importing, using or possessing a sunscreen with any of the three. It names balms in its list. So both A and B are out, even unopened in a bag. Avobenzone, homosalate and octisalate are not named, so a balm with only those would pass. Balm C passes.
4. Key West. No local rule applies. The city's ban was struck down by Florida law before it started. All three can be sold and used.

Walked through like that, the answer for a traveller is obvious. Balm C, with zinc oxide alone, is the only one that works at every stop. That is the practical rule, and it costs nothing to follow. How zinc oxide behaves in a balm is covered in zinc oxide.

Maui County: mineral only, and use is banned too

Maui County's rule is the strictest one in Hawaii. Council Bill 135 was signed into law as Ordinance 5306 by Mayor Michael Victorino on 6 December 2021. It took effect on 1 October 2022. It covers the whole county, which takes in the islands of Maui, Lanai and Molokai.

The rule is defined by what is allowed rather than what is banned. "Mineral sunscreens" are zinc oxide and titanium dioxide. Every other active ingredient makes a product a "non-mineral sunscreen". The county's own announcements name octinoxate, octocrylene and oxybenzone as examples, but the list is open. Avobenzone, homosalate and octisalate are all non-mineral, so they are caught too.

The ordinance reaches further than the state law in one important way. It covers "the sale, distribution, or use" of non-mineral sunscreens. So a visitor using a chemical-filter lip balm on a Maui beach breaks the county code. It is not just the shop that sold it. The only exception is a prescription from a licensed healthcare provider. Fines go into the county's Environmental Protection and Sustainability Fund. When the rule began, Maui Now reported that enforcement would focus on educating the public rather than on fines.

The county's case for the mineral line rests on the US Food and Drug Administration. US sunscreens use 16 active ingredients as filters. Of those, only zinc oxide and titanium dioxide are deemed "generally recognized as safe and effective". That FDA status is about human use. The county added its own view that the two minerals are safer for marine life.

Hawaii County, the Big Island, passed a similar rule. Maui Now reported that it bans the sale and distribution of non-mineral sunscreens from 1 December 2022. That report does not say the Big Island rule covers use, so we do not claim it does.

The US Virgin Islands: three filters, and use or possession

The US Virgin Islands law is Act No. 8185, from Bill 33-0043. The legislature passed it on 25 June 2019 and the governor approved it in July 2019. It adds section 305h to title 27 of the Virgin Islands Code.

It goes further than Hawaii's state law in three ways.

1. A third filter. It bans octocrylene as well as oxybenzone and octinoxate. Octocrylene is defined by CAS number 6197-30-4, the same number the dead Hawaii bill used.
2. Use and possession. It is unlawful to "use or possess, after March 30, 2020, while in the Virgin Islands" any sunscreen product with one of the three. Import for sale was barred from 30 September 2019.
3. Balms by name. Each rule applies to products "including, but not limited to, lotions, pastes, balms, serums, or ointments".

The Act keeps a face cosmetic exclusion. It uses the federal definition of cosmetic, from the Food, Drug and Cosmetic Act. But with balms named in the operative rule, a reader cannot count on the exclusion for an SPF lip balm. The only way out of the ban is a prescription, filled by a licensed pharmacy or drug store. The Department of Licensing and Consumer Affairs fines $1,000 for a first offence and $2,000 for each later one.

Avobenzone is not in the Act. Nor are homosalate or octisalate. So in the Virgin Islands, unlike Maui, some chemical filters remain lawful. A lip balm built on avobenzone without octocrylene would pass. Read every active on the panel to be sure.

Key West and Florida: a ban that never started

Key West, Florida, banned the sale of sunscreens containing oxybenzone and octinoxate in February 2019. The city commission approved it by 6 votes to 1. It was modelled on Hawaii's law and set to start at the same time, in January 2021.

It never started. Florida's legislature passed a bill to stop cities regulating cosmetics and over-the-counter drugs. Governor Ron DeSantis signed it at the end of June 2020. It is now section 499.002(7) of the Florida Statutes. It reads: "Notwithstanding any other law or local ordinance or regulation to the contrary, the regulation of over-the-counter proprietary drugs and cosmetics is expressly preempted to the state." Preempted means the state has taken the subject for itself, so a local rule on it has no force. As WLRN reported, Key West's ban "was killed before it ever took effect".

So in Key West, and anywhere else in Florida, no rule restricts which filter your lip balm contains. The state itself has no such ban, and its cities cannot make one.

Where each rule applies, at a glance

Each row restates a rule set out in the sections above, with the source it comes from.

How to pick a lip balm that passes everywhere

The simplest test is the one that settles every row of the table at once. Read the Drug Facts panel, or the ingredient list, before you pack.

1. Find the actives. On a US pack they are in the Drug Facts box. On a European or UK pack they are in the ingredient list, which reading a balm label walks through. Trust the list, not the front of the pack.
2. Look for the two Hawaii names. Oxybenzone or benzophenone-3, and octinoxate, ethylhexyl methoxycinnamate or octyl methoxycinnamate. Any one of them rules the balm out of sale in Hawaii.
3. Look for octocrylene if you are going to the US Virgin Islands.
4. For Maui, accept only zinc oxide or titanium dioxide. If any other active appears, the balm is non-mineral there.
5. Ignore "reef safe" on the front. None of these laws defines it. A product can say it and still hold octocrylene, which matters in the Virgin Islands and in Maui. Marketing words of this kind are discussed in "chemical-free" and clean beauty claims.
6. Pack it so it survives. A firm stick goes through airport security as a solid, as flying with balms explains. Keep it out of a hot car. What heat does to a stick is covered in balm melting in the heat.

Then use it properly. A reef rule does not change how much protection a balm gives. A visible film on both lips, put back on after eating, drinking and swimming, does more than the choice of filter. The amounts are in how much balm to apply. If a filtered balm stings or makes your lips scaly, the filter itself can be the cause. How to patch test a balm sets out how to check, and mineral filters are the usual fallback.

For children, a mineral balm meets the strictest rule on this page. Mineral filters are also the choice our SPF guide suggests for children, and lip balm for children covers the rest.

What this answer does not cover

This page reads each law as written and applies it to a lip balm. It stops at four places.

First, the face exclusion. Our reading, that a plain SPF lip balm is "sunscreen" in Hawaii, follows the words of the statute. It is not a ruling. We found no court decision, Department of Health rule or enforcement case on lip products. A seller should treat the question as open and take advice. A buyer does not need to, because a balm without the two filters avoids the question.

Second, other islands and other places. We checked Hawaii's state law, Maui County and the US Virgin Islands at the source. Hawaii County we checked through a news report. We did not find a matching ordinance for Honolulu or Kauai, but we did not search every county code. Other places have reef rules too, including national parks and some tour operators, and this page does not list them. Check the rules for the exact beach or reserve you are visiting.

Third, change. These rules have moved several times since 2018, and bills come back. A bill that died in 2022 can be filed again. The dates and filter lists here are the ones in the texts we fetched in November 2026.

Fourth, the science and the skin. This page does not judge whether these filters harm reefs. The laws state that they do, and that is what the rules rest on. Nor does it judge whether a mineral balm protects your lips as well as a chemical one. That depends on the SPF tested on the finished product, not on the filter type, as SPF in lip balm explains. Whatever the law allows, your lips still need a tested SPF in strong sun.

Reviewed and updated 4 November 2026. Spotted an error? Tell us and we will fix and log it.