These days, there seems to be a serum or cream to make any given body part more perfect. Globally valued at $1 billion in 2025, the eyelash serum market is no exception.[1] Eyelash serums often promise prescription-grade results without a doctor’s visit, making them attractive to consumers seeking to better themselves without high medical bills. However, ‘cosmeceuticals’ like eyelash serums often straddle the line between what is legally safe for everyday beauty consumers and what carries prescription-strength health risks without the accompanying warnings.
The Origin of Eyelash Serums: From Glaucoma to Glam
Eyelash growth serums were discovered by accident in the early 2000s.[2] The drug “bimatoprost” was being used to treat glaucoma, a disease of the eye, when patients treated with bimatoprost eye drops noticed longer and fuller eyelashes following treatment.[3] Bimatoprost contains a prostaglandin analogue (PGA), which was discovered to be the active ingredient increasing eyelash length and quantity as a side effect of glaucoma treatment.[4] PGA and its analogs work by biologically keeping the eyelash in its anagen, or growth, phase longer than normal.[5] The pharmaceutical company Allergan monetized this side effect of bimatoprost by obtaining FDA approval for Latisse, the only prescription eyelash serum that claims to medically grow eyelashes. [6] Latisse lists adverse side effects to include itchy eyes, eye redness, eye irritation, skin darkening, and darkening of the irises, which is likely to be permanent.[7] One particular side effect of PGA and its analogs is fat loss around the eyes, which makes eyes appear sunken and tired.[8]
Given the cosmetic implications, over-the-counter cosmetic manufacturers started producing eyelash serums with a synthetic analog to the drug in Latisse, known as Isopropyl Cloprostenate (ICP). Lifetech Resources LLC began manufacturing eyelash serums containing ICP without going through the FDA’s “New Drug Approval” process, and instead sold the serum as a cosmetic, which does not require FDA approval.[9] Lifetech marketed these lash serums with claims of growing thicker and fuller eyelashes but did not mention possible side effects of its main ingredient, ICP. ICP has the same risks as the drugs Latisse and bimatoprost, including eye irritation, fat loss around the eye, and permanent eye discoloration.[10] In 2011, the FDA issued a warning letter to Lifetech Resources LLC for violating the “Federal Food, Drug and Cosmetic Act” based on the manufacture and promotion of the following three eyelash serums: RapidLash Eyelash Renewal Serum; NeuLash Active Eyelash Technology; and NeuveauBrow Active Eyebrow Technology. [11]
According to the warning letter, these products were considered drugs based on the use of ICP and what they claimed the serums could do.[12] These products claimed to significantly increase the length of eyelashes, lengthen and thicken lashes in 30 days, help promote cell regeneration, and help accelerate the length of the hair shaft.[13] Because these promotional claims stated that the products are intended to affect the structure or function of the body (by inducing eyelash/eyebrow growth), the FDA found that they should be classified as drugs per 21 U.S.C. § 321.[14] Further, the FDA noted that the use of ICP, the synthetic version of the FDA-approved drug to treat eyelash growth, was to alter the structure and function of the body, so these products should be classified as drugs.[15] The misclassification of these products (by failing to disclose them as drugs) meant that side effects and use guidelines that should accompany this active ingredient were missing and presented risks of harm to the public.[16]
The Marketing Makeover
After the FDA issued this warning in 2011, companies making and marketing eyelash serums started to change their tune. Instead of stating that the serums grew eyelashes, stimulated lash growth, or lengthened eyelashes, marketing for eyelash serums containing ICP, PGA, or other drug analogs started to use terms like ‘appear thicker’, ‘visibly fuller’, 'conditions’, and ‘lash enhancing’.[17] This was done to avoid the dreaded FDA warning letter and potential classification as a drug by the FDA, which involves a long and costly process.[18]
The Multi-Million Dollar Reckoning
These changes in marketing, while financially successful, were not without their downsides. The use of ICP and vague marketing language caught up to two major players in lash serums, Rodan + Fields and Grande Cosmetics, costing them together more than $44 million in settlement payouts from consumer protection class-action lawsuits.[19]
Rodan + Fields was sued by a class of plaintiffs in 2018, who claimed that Rodan + Fields’ “Lash Boost” product was a misbranded drug that could cause serious side effects because of its use of ICP as a key ingredient in its formula.[20] The federal class action lawsuit, brought under California consumer protection laws, accused Rodan + Fields of engaging in unfair and fraudulent marketing.[21] Rodan + Fields marketed its $150 Lash Boost eye serum by claiming it gave users “the appearance of lush, longer-looking lashes”, and stated that it was not a drug product, contained only cosmetic ingredients, and was not associated with any significant side effects. [22] The class of plaintiffs claimed that the FDA should have regulated Lash Boost and that its status as an unregulated cosmetic did not warn consumers about the risks associated with ICP.[23] Lash Boost accounted for $200 million in retail sales for Rodan + Fields in 2017 alone.[24]In 2022, Rodan + Fields agreed to pay $38 million to resolve the class action lawsuits without admitting any wrongdoing.[25]
Grande Cosmetics was faced with a similar class action lawsuit regarding its “GrandeLASH-MD”, “GrandeBROW”, and “GrandeHAIR” products, which contained ICP.[26] The lawsuit similarly contended that the serums were misbranded, unapproved new drugs, because they were intended to affect the structure and function of the body by growing hair, and that the packaging and marketing of these products left out important information, such as possible side effects, contraindications, the name and quantity of active ingredients, warnings about unsafe dosage, and directions on how to apply the serums.[27] Grande Cosmetics marketed its products with phrases like “naturally longer, thicker lashes;” “bolder looking brows in just 6-8 weeks;” and “fuller & healthier-looking hair.” [28] In 2023, Grande Cosmetics reached a $6.25 million settlement with the class of plaintiffs, and agreed to pay claimants up to $150, expand cautionary instructions for use, and change how the products are advertised.[29]
MoCRA: Closing the Cosmeceutical Loophole
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA), which went into effect at the end of 2023, has introduced new measures that prevent the kind of harm caused by the sale and marketing of ICP-containing eyelash.[30]MoCRA now requires mandatory adverse event reporting, wherein the manufacturer, packer, or distributor must report serious or adverse events involving cosmetic products to the FDA within 15 days of receiving the report and must retain records of these reports.[31] Before MoCRA, companies were not required to report any adverse events related to the serum to the FDA, because cosmetics like eyelash serums were not classified as drugs.[32] MoCRA now also requires manufacturers to have evidence that a cosmetic is safe for its intended use under labeled conditions, which ensures manufacturers have a scientific basis for claiming their products are safe.[33] MoCRA has stricter requirements when it comes to labeling, wherein each cosmetic marketed in the US must be submitted to the FDA with product name, ingredients, contact information, and facility information, which must be updated annually.[34] Additionally, MoCRA gives the FDA mandatory recall authority for cosmetic products. [35]
MoCRA has made it more difficult for cosmetic companies to sell medical-adjacent products with medical side effects, such as ICP and PGA-containing eyelash serums. MoCRA discouraged the business of selling drug-like results with cosmetic convenience by requiring extensive reporting to the FDA for adverse events, creating publicly searchable paper trails of adverse events for class action litigators to take advantage of, requiring safety dossiers on cosmetic products that must disclose side effects, and giving the FDA the authority to recall a cosmetic product.[36] Cosmetic companies these days are producing eyelash serums that operate differently than those containing ICP, namely through peptides, which serve to condition the lash, rather than biologically alter it.[37] Peptides are considered more gentle and have lower risks of side effects but are also seen as less effective.[38] Grande Cosmetics now makes a peptide-centered lash serum that specifically highlights its lack of ICP.[39] Additionally, cosmetic brands such as The Ordinary and Olaplex have begun selling peptide-based lash serums. [40]
Conclusion
Ultimately, cosmetic lash serums have proved that active, pharmaceutically developed ingredients cannot hide behind a cosmetic label and creative marketing. ‘Cosmeceuticals’ like eyelash serums represent an opportunity for brands to provide consumers with real results without the need for FDA approval, but also present costly legal, regulatory, and health risks. MoCRA has completely changed the environment that allowed eyelash serums to borrow ingredients from medicine but ignore the medical risks, and now has created a robust system of accountability that cosmetic brands cannot hide behind. In a market reshaped by courtroom payouts and regulatory oversight, cosmetic brands are finding that potentially less effective alternatives to ICP and PGA are far cheaper than the legal fallout of selling an unapproved drug.
[1] Eyelash Serum Market Size, Share & Trends Analysis Report by Product (Lash Enhancing, Lash Building), by Application (Home Care, Salons), by Sales Channel (Hypermarkets & Supermarkets, Online), by Region, and Segment Forecasts, 2025–2030, Grand View Rsch., https://www.grandviewresearch.com/industry-analysis/eyelash-serum-market-report (last visited Oct. 7, 2026).
[5] Monica Baiyasi et al., Eyelash Serums: A Comprehensive Review, 23 J. Cosmetic Dermatology 2328, 2328–44 (2024).
[6] Latisse for Eyelash Growth, supra note 2.
[8] Tomoya Higashiyama et al., Decreased Orbital Fat and Enophthalmos Due to Bimatoprost: Quantitative Analysis Using Magnetic Resonance Imaging, 14 PLoS ONE, no. 3, 2019, at e0214065.
[20] Grabenhofer, supra note 19.
[22] Grabenhofer, supra note 19; Berr, supra note 21.
[23] Grabenhofer, supra note 19.
[24] Berr, supra note 21.
[35] Cosmetic FDA Regulations, supra note 30.
[36] Cosmetic FDA Regulations, supra note 30.
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