DTC Brand Breakdown | How Tower 28 Sensitive Skin Beauty Built a Moat 'Clean Beauty' Brands Cannot Copy
- 14 hours ago
- 8 min read
Walk into any Sephora and you will find dozens of brands describing themselves as 'clean.' The label has become so common it tells customers almost nothing. Most are marketing positions: a green leaf on the box, a 'free-from' list, a softer color palette. There is no third-party body checking the claim.
Tower 28 took the opposite path. The Santa Monica brand, founded in 2019 by Amy Liu, a former L'Oréal, Smashbox, and Kate Somerville executive who has lived with eczema her entire adult life, made one strategic decision early: every product would be tested against the standards of three independent medical associations. The result is the only beauty brand in the United States whose entire skincare line has earned approval from the National Eczema Association, the National Rosacea Society, and the National Psoriasis Foundation, the first beauty brand ever to clear all three across an entire skincare line simultaneously.
That is a moat. Tower 28 doubled its sales at Sephora in 2024 and is now the retailer's 'highest-productivity brand,' jumping 17 ranks in a single year, per founder Amy Liu. Prelude Growth Partners led a USD 28 million Series A in December 2022 at a USD 228 million valuation, and the brand crossed into Sephora U.K. in late 2024. None of this came from celebrity endorsement or virality. It came from being defensibly correct on a single technical claim that competitors cannot match without years of formulation work.
For founders watching the 'clean beauty' category collapse into commodity status, Tower 28 is the most studyable counter-example of the past five years. Below is the WWW.HER breakdown.
WHO | The customer the beauty industry kept telling to manage, not enjoy
Roughly 31 million Americans live with eczema, 16 million with rosacea, and another 7.5 million with psoriasis. For two decades, the beauty industry treated these consumers as a clinical problem to manage. The default products were Cetaphil and CeraVe at the drugstore: medical-adjacent, beige, defensive in their packaging, designed not to react. The implicit message was: get through your skin condition by avoiding everything you might enjoy.
Tower 28's actual customer is the woman who reads that message and refuses it. She wants the same lipgloss, blush, and serum that the makeup-confident woman next to her uses, and she has spent years buying products that triggered her eczema or rosacea anyway because there was no permission-giving alternative. She is on average 18 to 49, Sephora-loyal, willing to pay USD 22 for a multi-stick. She does not want a clinical aesthetic. She wants a beauty aesthetic with clinical safety underneath.
This is the hardest customer for the legacy clean-beauty playbook to win, because the legacy playbook treats sensitivity as a sub-segment to address with one or two SKUs in a broader range. Tower 28 does the inverse: every single product in the line is built to clear the medical-association bar, not just the dedicated sensitive-skin items. That changes the customer's relationship with the brand. The trust is brand-level, not SKU-level, and switching costs become unusually high.
WHAT | An eight-year hero SKU and a small, ruthlessly disciplined catalogue
Tower 28 launched in 2019 with a deliberately narrow assortment: SOS Daily Rescue Facial Spray, a sunscreen, and a small color cosmetics range covering blush, lip, and brow. The breadth was less important than what the spray represented.
SOS Daily Rescue Facial Spray is built around hypochlorous acid, a molecule the human immune system already produces to fight off pathogens. The molecule is highly unstable in solution, which is why no consumer beauty brand had productised it as a daily-use facial spray before. Tower 28's chemists worked for eight years to stabilize hypochlorous acid for facial-skin use, optimizing the pH and concentration. The result is the only hypochlorous acid spray recognized by all three of the major U.S. skin-health organizations. It is now the brand's defining product and the entry point for most new customers.
The discipline that matters strategically is not the spray itself, but what Tower 28 chose not to do after launching it. The brand resisted the temptation to fragment into adjacent products that would have diluted the medical-association compliance. SOS franchise extensions came slowly and stayed inside the moat: SOS Daily Barrier Recovery Cream, SOS Recovery Eye Cream, and a few others, all built to the same testing standard. Color cosmetics expanded with the same constraint: every Swipe Serum Concealer and OneLiner Multi-Liner had to pass the same sensitivity review before launch.
Compare that with the typical clean beauty trajectory: Drunk Elephant scaled by adding new actives faster than its 'Suspicious 6' positioning could absorb, then sold to Shiseido in 2019 and quietly lost cultural relevance. Tower 28 has stayed in a far narrower lane, and as a result has compounding rather than dilutive product launches.
WHY | Third-party certification as moat, Sephora as operating partner
The strategic insight that defines Tower 28 is simple to articulate and very hard to copy: in a category where consumer trust has been corroded by greenwashing, the only credible signal is auditable third-party certification.
National Eczema Association approval, awarded under the Seal of Acceptance program, is not paid endorsement. Each product is reviewed by a panel of dermatologists against ingredient and irritation criteria. The same applies to the National Rosacea Society and National Psoriasis Foundation seals, which Tower 28 holds across its full line. Replicating any one of these for a single product takes 12 to 18 months and material reformulation. Replicating all three across an entire catalogue is a multi-year strategic commitment, not a marketing decision.
What makes the moat especially durable is that Amy Liu paired the medical-grade rigor with a brand expression that explicitly refuses to look medical. Tower 28's tagline 'It's okay to be sensitive' reframes sensitivity from clinical condition to character trait. The packaging is candy-bright. The marketing photography uses Asian, Latina, and Black women across age groups. The brand voice is more late-90s teen magazine than dermatology office. This is the precise inversion of how clean beauty sells (aesthetic without auditing) and how clinical skin care sells (auditing without aesthetic).
Distribution is the second pillar. Tower 28 has been Sephora-exclusive in the United States since the 2019 launch, and Sephora has reciprocated by treating the brand as a tier-one growth bet. The 2024 acceleration of branded endcaps across more than 600 U.S. stores, the 'highest productivity at Sephora' designation, and the U.K. launch in late 2024 all came from Sephora's commercial team explicitly choosing Tower 28 as the sensitive-skin lead. The brand entered Sephora U.K. as the retailer's only-at-Sephora launch in late 2024 with nine bestselling products across seven stores, same playbook the brand used in the United States: enter narrow, prove productivity, expand shelf.
The China test has not yet happened. Mainland China's sensitive-skin category is one of the world's largest, dominated by domestic medical-credentialed brands like Winona, Dr. Yu, and the Pien Tze Huang skincare line, and supported by a 'cosmeceutical' regulatory framework that takes clinical claims seriously. Tower 28's three U.S. medical seals do not directly translate to mainland regulatory approval, but the operating logic does: Chinese consumers in this category, more than any other beauty segment, want auditable evidence over aesthetic positioning. A brand entering with a credible testing apparatus, framed in a non-clinical visual language, would face less of an entrenched competitive set than in U.S. clean beauty.
HERSTORY | Twenty years inside the industry, then a brand built for her own daughters
Amy Liu launched Tower 28 at age 40 after a long beauty industry career at L'Oréal, Smashbox, and Kate Somerville. She was the operator who knew exactly how the prestige beauty machine worked: the 25-shade foundation expansion, the trade marketing budget, the seasonal catalogue refresh, the 'clean' rebrand cycle. She also knew exactly what it could not do for her, because she had eczema her entire adult life, and her daughters had inherited the same sensitive, eczematic skin.
The founding insight was generational rather than market research. Liu watched her daughters approach the same Sephora aisles she had spent her career building merchandising plans for, and saw the same gap she had personally lived inside: a brand that did not exist for them. Tower 28 was the brand she would have wanted at 16, and the one her daughters needed at the same age.
The build cadence reflected operator discipline. Tower 28 launched in April 2019 with limited inventory, was on sephora.com by September 2019, and was inside every U.S. Sephora store with a half-shelf by March 2020. The Series A only came in late 2022, four years post-launch, after the brand had already proven retail productivity. That is the inverse of the clean beauty cohort that took venture funding before product-market fit and burned out chasing growth they could not metabolize.
The USD 28 million Series A from Prelude Growth Partners landed at a moment when many clean beauty brands were down-rounding or shutting. Prelude has since gone on to back KilgourMD, Perelel, and other clinically credentialed women's wellness brands, treating Tower 28 as the template. The clinical-credibility-as-moat thesis has now compounded into a fund strategy.
Takeaway: What Tower 28 sensitive skin teaches the next generation of beauty founders
Tower 28's most replicable lesson is not the sensitive-skin niche, the bright packaging, or even the SOS Daily Rescue Facial Spray. It is the architecture of trust: identify a category in which consumer language has been corroded by marketing inflation (clean, natural, hypoallergenic, dermatologist-tested), then replace the corroded language with a third-party-audited certification framework that competitors cannot adopt without years of reformulation.
For Chinese cosmeceutical brands eyeing global expansion, the implication is direct. The U.S. and U.K. sensitive-skin shelves are not won by efficacy claims alone. They are won by independently verifiable seals (NEA, NRS, NPF) plus a brand voice that does not sound like a hospital. A Chinese sensitive-skin brand entering Sephora in 2027 with a Winona-style clinical aesthetic will find shelf space, but not category leadership. The Tower 28 path, audited credibility wrapped in non-clinical language, is the rare playbook that travels in both directions: it works in markets where consumer trust in 'clean beauty' has collapsed, and in markets where consumer skepticism of unfounded efficacy claims is still sharp.
Tower 28 has not finished its arc. The next test is whether the brand can extend the moat into mainland China through a registration-led entry, and whether the company can hold its niche discipline as Sephora's commercial pressure pushes toward category-adjacent expansion. Few sensitive-skin brands have managed both. Tower 28 is the one to watch.
Double V helps international brands navigate the Chinese market and supports Chinese brands looking to expand globally, from market research and brand strategy to social media content and KOL campaigns. Talk to our team.
Double V is a cross-border operating partner and intelligence house for emerging consumer brands, based in Hong Kong and Shenzhen. We help brands connect China and the world through three businesses: Brand Operation (marketing and distribution for brands on retainer), Brand Incubation (sister company Glam Infinite and our own-built brands), and Industry Intelligence (cross-border research and reports).
Comments