No, Elf Power Grip Primer is not considered non-comedogenic. It does contain several comedogenic ingredients, including isopropyl palmitate, stearyl alcohol, and glyceryl stearate, which could potentially clog pores and cause acne. It is also important to note that the primer is not designed for use on sensitive or acne-prone skin. If you have acne or sensitive skin, it is recommended that you avoid using this primer or any other cosmetic products containing comedogenic ingredients.