The FDA Just Changed Hormone Therapy Labels. Here's What You Need to Know.
- Dr. Meghan Tierney, DABOM MSCP

- Nov 13, 2025
- 5 min read
Last Monday, the FDA announced it's removing the black box warning from low-dose vaginal estrogen and updating warnings on oral and transdermal hormone therapies. If you're navigating perimenopause or menopause, you've probably seen the headlines. Some are celebrating this as a victory for women's health. Others are concerned about what it means for safety.

The truth? This announcement is a bit of a mixed bag – some genuinely good news, some claims that need some scrutiny, and some statements that are, frankly, not supported by the evidence.
Let's break it down.
First, What is a Black Box Warning?
A black box warning is the FDA's most serious medication warning. It appears prominently on drug packaging to alert prescribers, pharmacists, and patients to significant risks. These warnings exist because there is evidence of serious or life-threatening adverse events. Most of the time.
But when it comes to hormone therapy it got a little weird. These products have carried these warnings for years based largely on a study called the Women's Health Initiative. The data from this study was not interpreted in the best way initially, and this caused the warnings and a generation of women to go through perimenopause and menopause without support. That data has now been reanalyzed and reinterpreted many times in the past two decades and that is why the black box warnings have been reconsidered.
The Good News: Low Dose Vaginal Estrogen For Everyone!
Okay not quite!
But the FDA got it right on this one. The black box warning should never have been put on low dose vaginal estrogen in the first place.

This should have happened years ago.
Low-dose vaginal estrogen has minimal systemic absorption. It stays local, doing it's job where it's applied. It improves the health of the vaginal and vulvar tissue, treating vaginal dryness, painful sex, reducing urinary symptoms, and even preventing urinary tract infections. And by reducing urinary tract infections in older women, vaginal estrogen can save lives. UTI's aren't just uncomfortable. In older women especially, they can lead to serious illness, hospitalization, and even death.
This medication saves lives, and it has been carrying an outsized warning that scared many women and providers away from using it. If you have been hesitant about vaginal estrogen because of the black box warning, this is your sign to talk to your doctor.
The Caution: This is Not a Blanket Endorsement
Here's where I need to pump the brakes on the celebration.
The removal of the balck box warning should not be interpreted as the FDA saying all women should take hormone therapy, or that these medications are risk free.
They still care risks and those risks vary depending on the formulation. Transdermal estrogen (patches, gels, sprays) appears to have a lower risk of blood clots than oral estrogen because it bypasses first-pass metabolism in the liver. It doesn't seem to affect the clotting factors that are made in the liver in the same way that oral estrogen does. And depending on the reason you had a blood clot in the past, transdermal estrogen may still be reasonable to take.
The decision to use hormone therapy is individual, based on your symptoms, health history, risk factors, and goals. This has not changed.
The Concerning Part: The FDA Announcement Made Some Wild Claims
I wish we could have just stuck to the facts here.
In their announcement, the FDA made some statements about the benefits of hormone therapy. Some were based in fact. For instance, estrogen does reduce fracture risk and is FDA approved for the prevention of postmenopausal bone loss. But then things got a little weird.
They made some statements about the benefits of hormone therapy that significantly overreach.
The cardiovascular claim: The FDA stated that when initiated within 10 years of menopause, hormone therapy can reduce cardiovascular disease by 25-50%. This is based on old observational studies. There are no randomized controlled trials that show this benefit.
The cognitive function claim: They stated hormone therapy can reduce Alzheimer's disease risk by 35 % and 64% reduction in cognitive decline. These are also based on older observational studies. These findings have not been supported in randomized controlled trials.
Wait, What Is the Difference Between an Observation Study and a Randomized Controlled Trial? And Why Does It Matter?
Good question!
Observational studies are designed to indentify patterns and generate hypotheses for future research. Or, "gosh it looks like these two things are related, I wonder if one causes the other. Let's find out!" They are not designed to prove anything, just observing and seeing if we should look further.
A randomized controlled trial takes a group of similar people, splits them up, assigns one group to receive the intervention, in this case hormone therapy, and the other group a control, so no hormone therapy. You try to eliminate confounders, or things that could also cause the effect you are measuring. Then you see if the outcome you thought might be caused by the thing (hormone therapy!) is actually doing what you thought it was doing. A randomized control trial can tell us causation, an obesrvational study cannot.
So observational studies can mislead us. In the case of hormone therapy and reduced disease risk, there's a major confounding factor: women who have access to hormone therapy tend to have more financial resources, better healthcare access, higher education levels, and healthier baseline lifestyles than women who don't.These same factors – wealth, high education, good healthcare access – are strongly associated with lower risks of disease including Alzheimer's disease. And now you see that it might not have been the hormones causing the better outcomes in those observational studies.
This is why we need more funding for research in women's health. Randomized controlled trials are expensive!
The Wildest Part: Testing Hormone Levels Before Starting Hormone Therapy
Perhaps the most baffling part of the FDA announcement was the suggestion to test hormone levels before initiating hormone therapy.
This directly contradicts guidance from The Menopause Society, which specifically recommends against routine hormone testing before starting therapy. There is no lab test that defines perimenopause and your labs can be "normal" and you can be in perimenopause. Your hormone levels fluctuate wildly during the menopause transition so your symptoms guide treatment, not lab numbers.
What concerns me is that this statement could lead to women being denied treatment because their levels appear "normal" on a single blood draw, even though they are suffering with hot flashes, night sweats, mood changes, and sleep disruption.
This is already a problem and this statement may make it worse.
The Bottom Line
As with any medication, hormone therapy involves weighing risks and benefits. That calculus is personal and should be made with a knowledgeable provider who understands both the research and your individual situation.
Vaginal estrogen? It probably could be sold over the counter, honestly. The safety profile is excellent, and access barriers cause real harm.
Systemic hormone therapy? I am happy that this may improve access. And it requires a thoughtful conversation about your symptoms, your goals, your health history, and the current evidence – not overblown claims in either direction.
You deserve accurate information so you can make informed decisions about your body.
If you're in Washington State and looking for a doctor to help you navigate perimenopause and menopause with evidence-based, personalized care, book a complimentary discovery call today.



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