Cosmetic Claims in the EU: What You Can (and Can't) Say

Marketing creativity often clashes with regulatory reality. Regulation (EU) No 655/2013 establishes common criteria for the justification of claims used in relation to cosmetic products.

The 6 Common Criteria

1. Legal Compliance: You cannot claim what is already required by law (e.g., "No Hydroquinone" – it's banned anyway).
2. Truthfulness: If you claim "contains honey," it must contain honey, not a flavor.
3. Evidential Support: Claims must be supported by adequate and verifiable evidence (studies, tests, or literature).
4. Honesty: You cannot claim "repairing" if it only "moisturizes."
5. Fairness: You cannot denigrate ingredients legally used (e.g., "Paraben-free" is often considered denigrating and misleading).
6. Informed Decision-Making: Claims must be clear and understandable to the average consumer.

The "Free-From" Controversy

The EU Technical Document on Cosmetic Claims specifically targets "Free-from" claims. Claims like "Paraben-free" or "Preservative-free" are largely prohibited because they imply that safe, legal ingredients are harmful. Instead, focus on what your product does contain.

Medicinal Claims

Cosmetics cannot claim to treat, cure, or prevent disease. Claims like "heals acne," "anti-inflammatory," or "pain relief" reclassify your product as a medicine, requiring a completely different (and expensive) authorization process.