Tower 28 AI Market Strategy Report — Clean Makeup Brands
This report supports CiteWorks Studio's examination of how AI search is recommending Clean Makeup Brands. For more detail, you can also read Clean Makeup Brands: AI Discovery Index.
By Mark HuntleyFounder and CEOOn this report
Key Takeaways
- Tower 28 performs best in comparison prompts, where it is often placed near the top of shortlists.
- Sensitive-skin and acne-safe products are the brand’s clearest strengths across discovery and recommendation moments.
- Clean Beauty Pricing is the main gap, with very low top-3 visibility and no rank-1 support.
- Google AI Overviews drives the strongest visibility, while Google AI Mode shows the weakest results.
This is an independent public analysis by CiteWorks Studio / LLM Authority Index. It is not affiliated with, endorsed by, or sponsored by Tower 28 unless explicitly stated.
Answer Capsule
Tower 28 appears in 164 of 1,173 AI observations and earns 90 valid recommendations. The brand is not the broadest visibility leader, but it converts well when AI systems place it into clean makeup shortlists.
Its clearest strength is Clean Beauty Comparisons, where Tower 28 records its strongest top-3 and rank-1 rates. Its clearest weakness is Clean Beauty Pricing, where visibility and recommendation strength fall sharply.
The biggest opportunity is to extend Tower 28’s sensitive-skin and complexion authority into broader pricing, value, and affordability-stage prompts.
Who This Report Is For
This report is for CMOs, beauty brand leaders, ecommerce teams, retail growth teams, agency partners, and communications teams evaluating whether AI systems simply recognize a clean makeup brand or actually recommend it in buyer-choice moments.
Report Card
Field | Value |
|---|---|
Report type | AI Market Strategy Report |
Target company | Tower 28 |
Category | Clean Makeup Brands |
Reporting month | May 2026 |
AI platforms tracked | 6 |
Public high-intent clusters | 3 |
AI observations analyzed | 1,173 |
Competitors tracked | ILIA Beauty, Beautycounter, e.l.f. Cosmetics, Glossier, Kosas, Milk Makeup, Rare Beauty, Tarte Cosmetics, Thrive Causemetics |
Executive Summary
Tower 28 appears in 164 of 1,173 observations and records 90 valid recommendations. Being named is not the same as being chosen, and Tower 28 performs best when the buyer question requires skin-safety, complexion, or comparison-stage confidence.
Clean Beauty Comparisons is the strongest cluster. Across 449 observations, Tower 28 records a 7.80% top-3 rate, a 6.01% rank-1 rate, and a 10.91% positive visibility rate.
Best Clean Beauty Discovery is also meaningful, with a 5.57% top-3 rate, a 4.52% rank-1 rate, and a 10.09% positive visibility rate across 575 observations. Clean Beauty Pricing is the clearest gap, with a 0.67% top-3 rate, 0.00% rank-1 rate, and 1.34% positive visibility across 149 observations.
Platform performance is led by Google AI Overviews, where Tower 28 reaches a 21.80% positive visibility rate and a 13.16% rank-1 rate. Google AI Mode is the weakest tracked surface, with a 0.93% positive visibility rate and 0.00% rank-1 rate.
Sentiment is mostly favorable where Tower 28 appears: 109 positive mentions, 54 neutral mentions, and 1 negative mention, for a net sentiment score of 0.6585. The brand’s issue is not broad negative framing; it is uneven coverage across pricing and lower-performing platforms.
What Tower 28 Is Winning
Tower 28 is winning sensitive-skin, acne-safe, complexion, and clean beauty comparison contexts. AI systems repeatedly associate the brand with tinted sunscreen foundation, serum concealer, cream blush, cream bronzer, mascara, and gentle formulas.
Its average recommended rank is 1.3529 across rank-eligible recommendations only. That means when Tower 28 receives rank credit, it is usually placed close to the top of the shortlist.
Tower 28 also performs especially well in comparison-stage prompts. That matters because comparison prompts are closer to purchase evaluation than broad discovery prompts.
Where Tower 28 Has the Clearest AI Visibility Gaps
Clean Beauty Pricing is the sharpest gap. Tower 28 has only a 0.67% top-3 rate and no rank-1 recommendation credit in that cluster.
The second gap is platform consistency. Google AI Overviews is strong, while Google AI Mode barely surfaces Tower 28 and gives it no rank-1 support.
The third gap is category leadership. Ordered by top-3 recommendation rate, Tower 28 trails e.l.f. Cosmetics, Rare Beauty, and Kosas, even though it outperforms Glossier, Milk Makeup, ILIA Beauty, Thrive Causemetics, Tarte Cosmetics, and Beautycounter.
Biggest Opportunity
Tower 28’s biggest opportunity is to turn its sensitive-skin authority into broader decision-stage recommendation power.
The brand already has AI relevance around acne-prone skin, concealer, tinted sunscreen, sensitive eyes, and gentle clean makeup. The next move is to strengthen the answer and citation layer that helps AI systems recommend Tower 28 when buyers ask about price, alternatives, affordability, and whether the product is worth choosing.
Competitive Landscape
Tower 28 is a strong upper-middle recommendation brand in this clean makeup packet. Ordered by top-3 rate, it sits fourth, but its rank-1 rate is stronger than Kosas and several brands below it.
Brand | Top-3 rate | Rank-1 rate | Avg recommended rank | Sentiment |
|---|---|---|---|---|
e.l.f. Cosmetics | 10.74% | 7.84% | 1.3413 | 0.6968 |
Rare Beauty | 8.27% | 5.80% | 1.4227 | 0.6629 |
Kosas | 6.65% | 3.50% | 1.6795 | 0.6630 |
Tower 28 | 5.80% | 4.52% | 1.3529 | 0.6585 |
Glossier | 4.77% | 2.73% | 1.6071 | 0.5444 |
Milk Makeup | 4.09% | 2.73% | 1.5000 | 0.7551 |
ILIA Beauty | 3.84% | 2.98% | 1.4000 | 0.6915 |
Thrive Causemetics | 2.81% | 1.71% | 1.4848 | 0.5059 |
Tarte Cosmetics | 1.11% | 0.34% | 2.3846 | 0.4800 |
Beautycounter | 0.09% | 0.09% | 1.0000 | 1.0000 |
Average recommended rank covers rank-eligible recommendations only.
Prompt Evidence
ChatGPT / Best Clean Beauty Discovery — Which is the best foundation for acne prone skin? The answer names Tower 28 SunnyDays SPF 30 Tinted Sunscreen Foundation and connects it to lightweight, acne-safe coverage.
ChatGPT / Best Clean Beauty Discovery — What is the best concealer for acne? The answer names Tower 28 Swipe Serum Concealer in an acne-concealer context.
ChatGPT / Best Clean Beauty Discovery — What is the best sunscreen with makeup? The answer names Tower 28 SunnyDays SPF 30 Tinted Sunscreen Foundation in a sunscreen-plus-makeup context.
Copilot / Clean Beauty Comparisons — Is Tower 28 lip gloss worth the hype? The answer directly discusses Tower 28 lip gloss in a worth-it comparison context.
Google AI Overviews / Clean Beauty Pricing — clean affordable makeup The answer names Tower 28 Beauty in an affordable clean makeup context.
What CiteWorks Studio Would Do Next
Phase 1: AI Market Strategy Audit
Map the discovery, comparison, and pricing prompts where Tower 28 is present, displaced, promoted, or reduced to factual mention across the six AI platforms.
Phase 2: Recommendation Readiness Plan
Prioritize the clusters where Tower 28 is visible but under-converting, especially Clean Beauty Pricing and weaker platform surfaces.
Phase 3: Owned Answer Layer Buildout
Build answer-ready pages around tinted sunscreen foundation, acne-prone skin, sensitive skin, serum concealer, lip gloss, cream blush, sunscreen makeup, and price justification.
Phase 4: Citation / Authority Layer Development
Strengthen third-party evidence across beauty reviews, retailer pages, comparison roundups, sensitive-skin validation, acne-safe product discussions, and community proof.
Phase 5: Monthly AI Visibility & Recommendation Tracking
Track movement from presence to recommendation over time by platform, cluster, product category, prompt type, and competitor displacement pattern.
Why This Matters
Tower 28 has a clear AI-recognized role: clean makeup for sensitive, acne-prone, and reactive-skin contexts. That is commercially valuable because many clean makeup prompts are trust-sensitive.
The packet shows that Tower 28 can convert into high-ranking recommendations when AI systems understand the use case. That is a strong position, but it is not yet evenly distributed across pricing and platform surfaces.
The strategic path is to reinforce Tower 28’s safety-oriented product authority with stronger comparison, affordability, and purchase-stage evidence.
Core Metrics
Metric | Value |
|---|---|
Mentions | 164 |
Valid recommendations | 90 |
Top 3 recommendation count | 68 |
Rank #1 recommendation count | 53 |
Average recommended rank | 1.3529 (rank-eligible recommendations only; all three normalized clusters carried rank-eligible recommendations, though Clean Beauty Pricing carried no rank-1 positions) |
Positive mentions | 109 |
Neutral mentions | 54 |
Negative mentions | 1 |
Raw mention presence rate | 13.98% |
Valid recommendation coverage | 7.67% |
Top 3 recommendation rate | 5.80% |
Rank #1 recommendation rate | 4.52% |
Net sentiment score | 0.6585 |
Sentiment & Recommendation by Platform
Platform | Positive visibility rate | Rank-1 rate | Readout |
|---|---|---|---|
ChatGPT | 3.85% | 0.55% | Present, but limited rank-1 conversion |
Copilot | 7.65% | 2.35% | Useful visibility with moderate rank-1 support |
Gemini | 11.93% | 6.25% | Strong positive visibility and solid rank-1 conversion |
Google AI Mode | 0.93% | 0.00% | Weakest tracked surface for Tower 28 |
Google AI Overviews | 21.80% | 13.16% | Strongest overall platform surface |
Perplexity | 4.88% | 1.22% | Some visibility, but limited rank-1 movement |
Methodology
One-company report; all other tracked brands are competitors relative to Tower 28. Reporting month May 2026; structured extraction date May 20, 2026.
Six AI environments were tracked: ChatGPT, Gemini, Perplexity, Copilot, Google AI Mode, and Google AI Overviews. The dataset contains 1,173 observations across ILIA Beauty, Beautycounter, e.l.f. Cosmetics, Glossier, Kosas, Milk Makeup, Rare Beauty, Tarte Cosmetics, Thrive Causemetics, and Tower 28.
Public clusters were normalized from Stage 0: Best Clean Beauty Discovery, Clean Beauty Comparisons, and Clean Beauty Pricing. A mention counts when Tower 28 appears in any form; a valid recommendation requires positive, shortlist-quality inclusion.
Per the dataset’s methodology inputs, sentiment scoring is: “negative = -1, neutral = 0, positive = 1.” Rank eligibility is defined as: “Only positive valid recommendations receive rank credit.”
This is a point-in-time packet. AI outputs shift with platform updates, prompt phrasing, geography, personalization, and source-ecosystem changes.
Request an AI Visibility Audit
CiteWorks Studio produces AI Market Strategy Reports showing where your brand appears, disappears, or gets recommended across ChatGPT, Gemini, Copilot, Perplexity, Google AI Mode, and Google AI Overviews. Request an AI Visibility Audit.
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About The Author
Mark Huntley
Founder and CEO
Mark Huntley, J.D. is founder of CiteWorks Studio, a strategic advisory focused on visibility, authority, and recommendation presence in AI-shaped search environments. His work centers on embedding-level GEO, vector optimization, and cosine gap engineering — helping brands align their digital presence with the retrieval systems that increasingly shape discovery, interpretation, and choice.