Safety & hazards

Hawaii Reef-Safe Sunscreen: Oxybenzone and Octinoxate Ban Under Act 104

Hawaii’s Act 104 bans oxybenzone and octinoxate in over-the-counter sunscreens, and Act 117 expanded the list to include avobenzone and octocrylene.

17 min read · Updated October 3, 2026

The 2021 Expansion Under Act 117

Governor Ige signed Act 117 in July 2021, expanding the prohibited list to include avobenzone and octocrylene. Both additional UV filters became illegal to sell without prescription starting January 1, 2023. Avobenzone was the most common UVA filter in mainland chemical sunscreens, and octocrylene was widely used to stabilize avobenzone against sunlight-driven degradation. Removing both effectively eliminated the chemical-sunscreen category from Hawaii retail.

Adding avobenzone closed the compromise loophole where formulations had marketed themselves as “reef friendlier” by dropping oxybenzone but retaining other UV-filter chemistry. Retailers had roughly 18 months from Act 117’s signing to reformulate product lines or exit the Hawaii market. Coverage in the Honolulu Civil Beat tracked industry pushback and lobbying against the second-wave ban.

The Four Banned Chemicals at a Glance

Chemical name	Common name	Statute	Prohibition date
Benzophenone-3	Oxybenzone	Act 104 (2018)	January 1, 2021
Octyl methoxycinnamate	Octinoxate	Act 104 (2018)	January 1, 2021
Butyl methoxydibenzoylmethane	Avobenzone	Act 117 (2021)	January 1, 2023
Octocrylene	Octocrylene	Act 117 (2021)	January 1, 2023

How the Department of Health Enforces the Ban

The Hawaii Department of Health holds primary enforcement authority through its Environmental Management Division. DOH inspectors work alongside county code enforcement teams, and complaints from residents drive many investigations. The agency confirmed that most enforcement during 2021 and 2022 was educational, giving retailers written notice before assessing fines. That grace period ended once retailers had reasonable opportunity to clear existing stock.

Once a retailer has been formally notified and continues to sell banned product, statutory penalties apply. First-time violations carry a fine of up to $500. Repeat violations escalate to $1,000 per subsequent offense, and each individual sale of a banned product can be counted as a separate violation. Large chains have generally complied administratively rather than litigate, and no case has produced a published appellate decision to date.

Reporting Suspected Violations

Residents and visitors who see banned sunscreens for sale can file a complaint through the DOH consumer protection portal or by calling the environmental health office on their island. Complaints require the store name, product name, ingredient-list photograph, and date observed. DOH reviews within 30 to 60 days on average, and the reporting resident receives a status update if the complaint form requested one.

The Prescription Exception

Neither Act 104 nor Act 117 imposed a total prohibition. A licensed Hawaii physician can write a prescription for a chemical sunscreen when mineral alternatives are medically contraindicated. Patients with certain photosensitivity conditions, post-procedure skin recovery, or documented allergies to zinc oxide may qualify. The prescription must be presented at a licensed Hawaii pharmacy, and the pharmacy documents the transaction the way it would any prescription-only product.

Chain pharmacies including Longs Drugs and Times Pharmacy stock a small back-counter inventory of prescription-only chemical sunscreens for exactly this purpose. Insurance coverage varies widely because most private plans classify sunscreen as a cosmetic rather than a therapeutic product, and Medicaid does not cover it. Most patients pay cash for prescription sunscreen, generally $30 to $60 per tube.

Common Medical Indications

• Polymorphous light eruption where mineral filters trigger secondary breakouts
• Rosacea flares triggered by zinc oxide occlusion
• Post-laser resurfacing during the 90-day sensitivity window
• Documented contact dermatitis to titanium dioxide nanoparticles
• Pediatric xeroderma pigmentosum requiring maximum UVA blocking
• Adjunct treatment for lupus-related photosensitivity flares

Reef Safe Marketing vs. the Actual Chemical List

The phrase “reef safe” is not a regulated term anywhere in the United States. No federal agency defines it, and Hawaii’s statute never uses those words. That regulatory gap allowed manufacturers to place “reef safe” or “reef friendly” on packaging while including octocrylene, avobenzone, or other chemistry that Hawaii now prohibits. The label alone tells a relocating buyer almost nothing about legal compliance.

Relocating households cannot rely on the front label. The only reliable check is scanning the “active ingredients” panel on the back of the tube and rejecting any product listing the four banned compounds. Products labeled “mineral,” “physical,” or “non-chemical” almost always pass, but the ingredient panel remains the definitive test. Screenshots of the panel help when comparing purchases across multiple stores.

Common Marketing Terms and What They Actually Mean

Label term	Regulated?	What to actually check
Reef safe	No	Read the active ingredients panel
Reef friendly	No	Read the active ingredients panel
Hawaii compliant	No formal certification exists	Verify no oxybenzone, octinoxate, avobenzone, or octocrylene
Mineral sunscreen	Loosely — implies zinc or titanium	Confirm non-nano particle size
Broad spectrum	Yes — FDA regulated	Covers UVA and UVB but does not indicate reef safety
Non-nano	No, but widely disclosed	Verify particle size 100 nm or larger

Mineral Sunscreens That Qualify

Two active ingredients pass Hawaii’s chemical screen: non-nano zinc oxide and non-nano titanium dioxide. Both are inorganic mineral compounds that sit on top of the skin and reflect UV radiation rather than absorbing it. Zinc oxide covers UVA and UVB across the full spectrum. Titanium dioxide covers UVB and short-wave UVA effectively but leaves a gap in longer UVA wavelengths, which is why most premium mineral formulations lead with zinc.

The “non-nano” specification matters because particles smaller than 100 nanometers can be ingested by coral polyps and small marine organisms. Reputable brands publish particle size data on their websites or on the tube itself. Products meeting the non-nano threshold typically list particles between 150 and 350 nanometers, which sit on the skin surface and wash off in visible flakes rather than dissolving invisibly into the water column.

Recommended Zinc Oxide Concentrations

Effective mineral sunscreens contain zinc oxide at 15 to 25 percent by weight. Concentrations below 10 percent generally fail to deliver the SPF value printed on the label under real-world application densities. Dermatologist-formulated brands including EltaMD, Blue Lizard, and Kokua Sun Care disclose their zinc percentages directly on the tube, which allows shoppers to comparison-shop by SPF chemistry rather than only by claimed SPF number.

The White Cast Problem

The classic complaint against mineral sunscreens is the ghostly white cast they leave on skin, particularly on darker complexions. Newer formulations use tinted iron oxides and micronized (but still non-nano) zinc to reduce visible residue while remaining reef-compliant. Kokua Sun Care, formulated on Maui, blends zinc with kukui nut oil and honey to improve spreadability without adding banned filters, and the tinted line reduces white cast on medium-to-dark skin.

Cost and Availability Compared to the Mainland

Compliant mineral sunscreens cost meaningfully more than the chemical sunscreens that dominate mainland shelves. The Honolulu Consumer Price Index tracks personal-care goods separately from cosmetics, and the personal-care line has run 15 to 20 percent above the national average since 2021. Sunscreen specifically runs closer to 30 percent above mainland pricing at single-tube retail.

A relocating family of four applying sunscreen daily consumes roughly one 3-ounce tube per person per month during summer months when the Hawaii UV index regularly hits 11. That translates to $80 to $140 per month in sunscreen alone during peak season for a four-person household, before accounting for reapplication rates during snorkeling and beach days.

Retail Price Comparison

Product	Active ingredient	Size	Approximate Hawaii retail
Blue Lizard Sensitive SPF 30+	Non-nano zinc	5 oz	$21.99
EltaMD UV Clear SPF 46	Zinc + niacinamide	1.7 oz	$41.00
Thinksport SPF 50	Non-nano zinc	3 oz	$16.49
Kokua Sun Care SPF 50	Non-nano zinc	3.4 oz	$32.00
Little Hands Hawaii Baby SPF 35	Non-nano zinc	3 oz	$24.00
Badger Reef Safe SPF 40	Non-nano zinc	2.9 oz	$17.99

Sam’s Club and Costco carry warehouse-sized twin packs of Blue Lizard and Thinksport at 25 to 35 percent below single-tube retail, and both chains stock only compliant formulations after 2023. Buying at warehouse pricing brings the monthly sunscreen budget for a four-person household closer to $50 during shoulder seasons, though summer consumption still runs higher regardless of unit price.

Practical Guide for Relocating Households

Households arriving from Los Angeles, Seattle, or Chicago benefit from auditing every SPF product in their bathroom before packing. Matson and Pasha Hawaii shipping containers regularly arrive at Sand Island with cardboard boxes of expired or noncompliant sunscreen that relocating families end up trashing rather than using, which wastes both freight cost and shelf space in the container.

The Matson container shipping schedule allows roughly 14 to 21 days between mainland loading and Honolulu unloading, so any sunscreen shipped west should still be at least 12 months from expiration when it arrives. Heat during Pacific transit accelerates degradation of any remaining zinc formulations, and containers can reach interior temperatures above 130°F crossing the equator-adjacent shipping lane.

What to Do With Noncompliant Stockpiles

1. Use up mainland chemical sunscreen before the move where possible
2. Do not ship banned formulations across the Pacific — freight cost exceeds replacement cost
3. Donate unopened bottles to mainland shelters or free clinics before departure
4. Bring compliant mineral sunscreen for the first 60 days after arrival
5. Establish a Costco or Sam’s Club membership within the first month for bulk resupply
6. Set a monthly sunscreen calendar reminder during the first Hawaii summer

Sunscreen Application Math for Hawaii Sun

Full-body application for an average adult requires approximately 1 ounce, or about a shot glass, per application. Effective protection at Hawaii’s latitude requires reapplication every 2 hours during peak sun and immediately after swimming or heavy sweating. A day at Hanauma Bay or Waimea Bay easily consumes 3 to 4 ounces per person, meaning a single 3-ounce tube covers roughly one adult for a full beach day.

Why the Ban Was Passed: Reef Damage Research

Hawaii sits astride roughly 410,000 acres of coral reef, the largest concentration in United States waters. Reefs support commercial fisheries, coastal storm protection, and a diving-and-snorkeling tourism economy that the Hawaii Tourism Authority values at nearly $1.2 billion annually. Even modest reef bleaching translates into measurable economic damage across resort communities from Poipu on Kauai to Ka’anapali on Maui to Hapuna on Hawaii Island.

The peer-reviewed 2015 study by Downs et al., published in the Archives of Environmental Contamination and Toxicology, demonstrated that oxybenzone at 62 parts per trillion triggered coral larval deformity. Concentrations found in Hawaiian bays exceeded 3,500 parts per trillion during heavy visitation weekends. Warmer summer ocean temperatures above 84°F compound the chemical stress, and the 2015 and 2019 mass-bleaching events drew regulatory attention.

Vog and Other Environmental Stressors

Hawaii reefs face additional pressure from ocean acidification, sedimentation from cesspool leachate, and volcanic vog on the Big Island’s leeward coast. Households researching relocation to Kona or Ka’u should read the DOH vog and SO2 advisory framework, since air and water quality issues both trace back to the same regulatory division that enforces the sunscreen statute.

The state’s broader environmental push connects sunscreen chemistry to sewage handling, coral survival, and drinking-water safety. The Act 125 cesspool conversion mandate targets the roughly 88,000 remaining cesspools statewide, and the Act 326 tax credit subsidizes homeowner conversions up to $10,000. These programs sit alongside the sunscreen statute in DOH’s reef-protection portfolio.

Solar Ultraviolet Intensity at Hawaii’s Latitude

Honolulu sits at 21.3 degrees north latitude, closer to the equator than Miami and roughly the same latitude as Havana. The UV index regularly reads 11 or 12 during June and July, and reaches 8 or higher every month of the year. That contrasts with Seattle, where the UV index tops out around 8 in July and drops below 3 from November through February.

Cloud cover reduces surface UV by only 20 to 40 percent, and reflection off sand and water increases effective exposure by 25 percent. Households moving from higher latitudes underestimate sunscreen consumption during their first year. Dermatology clinics on Oahu report a 30 to 40 percent uptick in first-year visits from mainland transplants presenting with photodamage, sunburns, and early actinic keratosis.

Monthly Peak UV Index in Honolulu

Month	Peak UV index	Approximate time to burn (fair skin)
January	8	15 minutes
March	10	12 minutes
May	12	10 minutes
July	12	10 minutes
September	11	11 minutes
November	8	15 minutes

Where to Buy Compliant Sunscreen Across the Islands

Compliant sunscreen availability has caught up with demand since the 2021 rollout. Every major grocery chain — Foodland, Times, Safeway, KTA Super Stores — carries at least six compliant mineral brands. Whole Foods Kahala and Down to Earth stock premium organic mineral formulations at 10 to 15 percent higher prices than mainstream chains. Availability tightens on smaller islands where inventory turnover is slower.

Island-Specific Sourcing Notes

• Oahu: Longs, Foodland, and Costco Iwilei and Kapolei carry the deepest inventory
• Maui: Times Kihei, Foodland Lahaina, and Mana Foods in Paia stock local brands
• Hawaii Island: KTA Super Stores in Kona and Hilo carry Kokua Sun Care and Manda
• Kauai: Big Save Koloa and Times Lihue rotate seasonal compliant inventory
• Molokai and Lanai: Small stores stock 2 to 3 brands with limited SPF range

Local Hawaii-Made Brands

Hawaii-based manufacturers include Kokua Sun Care (Maui), Little Hands Hawaii (Maui), Raw Elements (partial Kauai operations), Mama Kuleana (Maui), and Manda Naturals (Hawaii Island). All five publish full ingredient lists online and confirm compliance with both Act 104 and Act 117. Purchases from these brands support local economies and shorter supply chains than mainland imports subject to Matson container schedules.

Free Sunscreen Dispensers at Beaches and Resorts

Free mineral sunscreen dispensers have appeared at several beaches on Oahu, Maui, and the Big Island. Waikiki, Kailua-Kona, and Wailea host solar-powered dispensers stocked by the Raw Elements partnership with hotel associations. The dispensers refill twice weekly and dispense roughly 0.25 ounces per press. Users should still apply a full ounce for adult body coverage across a 30-minute reapplication window.

Compliance Data Since the 2021 Rollout

The Department of Health has published enforcement summaries in each of its annual environmental health reports since 2021. First-year enforcement was largely educational, with over 400 written warnings issued to retailers across the four counties and only 12 fines assessed. Warnings dropped to fewer than 90 in year two as retailers rebuilt inventory around compliant formulations.

The second wave, tied to Act 117’s January 2023 deadline, produced roughly 150 warnings during the first six months of 2023, concentrated at gift shops and small resort stores that had missed the avobenzone and octocrylene extension. Larger chains had substantially reformulated inventory ahead of the deadline based on manufacturer schedules communicated during 2022 supply-chain planning.

Where Violations Concentrate

• Small resort gift shops with slow inventory turnover
• Independent surf shops carrying legacy brand loyalty
• Airport concession stands stocked by mainland distributors
• Online-only retailers shipping into Hawaii commercial addresses
• Pop-up beach vendors serving cruise ship day-trippers

How the Ban Connects to Other Hawaii Environmental Laws

The sunscreen statute is one thread in a larger regulatory push. Cesspool conversion under the Oahu cesspool conversion timeline targets nutrient loading into reef waters. Renewable energy expansion under the state net metering successor tariffs reduces vessel-fuel imports through cleaner electricity generation. Reef restoration funds draw on hotel-tax proceeds from the visitor industry.

Households handling multiple relocation decisions — septic system replacement, solar array installation, sunscreen supply — benefit from treating these as related compliance items rather than isolated errands. The DOH wastewater branch permit process and the sunscreen enforcement office share reporting infrastructure. A single portal complaint can trigger inspection under multiple statutes when a business is out of compliance across several regulatory dimensions.

Signage on State Parks and Beaches

Beach signage across Oahu, Maui, and Kauai now includes compliance reminders next to the standard shark, tsunami, and jellyfish notices. Signs use both English and Japanese to reach visitor populations. Directions to nearby stores selling compliant sunscreen appear on signage at Hanauma Bay, Molokini boat launches, and several North Shore surf breaks. Understanding the mauka-makai wayfinding convention helps readers parse the direction blocks.

Frequently asked questions

Is oxybenzone completely illegal in Hawaii?

Oxybenzone is illegal to sell in over-the-counter SPF sunscreen products throughout Hawaii, but it is not illegal to possess or use. Visitors can bring existing chemical sunscreen for personal use, and licensed physicians can prescribe oxybenzone formulations for patients who cannot tolerate mineral alternatives. Retailers face fines up to $500 per first violation and $1,000 for repeat offenses.

Does the ban apply to sunscreen bought online and shipped to Hawaii?

Enforcement targets in-state retail sales rather than personal imports. Individuals ordering chemical sunscreen from Amazon or mainland pharmacies for personal use have not been pursued by the Department of Health. Businesses shipping banned products into Hawaii for commercial resale, however, fall within the statute and can face the same $500 to $1,000 penalties as physical retailers operating storefronts.

What about avobenzone and octocrylene — are those definitely banned now?

Yes. Act 117 added both compounds to the prohibited list effective January 1, 2023. Retailers had 18 months to reformulate or clear inventory. Any sunscreen sold at Hawaii retail today should list only non-nano zinc oxide or non-nano titanium dioxide as active ingredients. Check the ingredient panel on the back of the tube rather than trusting front-label reef-safe marketing.

Are spray sunscreens allowed under Hawaii law?

Spray sunscreens are legal in Hawaii if they use only non-nano zinc oxide or titanium dioxide as the SPF-delivering active ingredient. Most mainland spray sunscreens rely on avobenzone and octocrylene, so those formulations cannot be sold statewide. Mineral spray formulations exist but are less common and typically cost 30 to 50 percent more per ounce than the equivalent lotion.

Do vacationers need a prescription to bring chemical sunscreen on vacation?

No prescription is required for personal-use quantities carried in luggage. The prescription requirement applies only to in-state purchases at Hawaii pharmacies. Travelers with medically necessary chemical sunscreen should keep it in original packaging with the pharmacy label visible if crossing TSA or agricultural inspection, though sunscreen is generally not screened by Hawaii Department of Agriculture inspectors at arrival.

How does Hawaii’s law compare to bans in other jurisdictions?

The U.S. Virgin Islands, Aruba, Bonaire, Palau, and Key West have all enacted similar restrictions, though the exact chemical lists vary. Palau’s 2020 law is the broadest, banning ten UV filters. Key West repealed its ordinance in 2021 after state preemption by Florida. Hawaii remains the only U.S. state with a statewide four-chemical ban enforced through Department of Health inspections at physical retailers.

What happens if a store sells banned sunscreen after the compliance date?

The Department of Health typically issues a written warning on first observation, giving the retailer 30 days to pull inventory. Continued sales trigger fines starting at $500 per incident, escalating to $1,000 for repeat offenders. Each individual sale may count separately. DOH publishes an enforcement log annually, and repeat violators face additional business licensing review with county authorities and possible suspension.