Let’s explore the most common pitfalls and misconceptions about cosmetic claims, helping you navigate the fine line between effective marketing and regulatory adherence.
Most of the “Free From …” Claims
A claim that “does not contain” or “free from…” that implies an ingredient prohibited by the Cosmetics Regulation should not be used. For example, “Free from corticosteroids”, “Free from hydroquinone” etc.
“Preservative Free”
This claim can be used if the cosmetic product does not contain any of the preservatives listed in Annnex V of the Cosmetic Regulation. Cannot be used in products containing high amounts of alcohol.
“Paraben Free”
Some of the paraben group are safe when used in accordance with the Regulation. Considering that all cosmetic products must be safe, the claim of “does not contain parabens” is prohibited because it creates unfair competition by denigrating all paraben derivatives.
“Silicone Free”
It is prohibited because the ingredient “cyclotetrasiloxane”, which is a silicone derivative, is prohibited but the ingredient “cyclopentasiloxane” is not prohibited in cosmetic products and therefore it creates unfair competition by tarnishing all silicone derivatives.
Free From Phthalates
It is prohibited to use this claim because it has a group of ingredients on the prohibited ingredient list such as «Benzyl butyl phthalate (BBP)», except for the ingredient «Dimethyl Phthalate», which has no usage limit of the phthalate group.
“Does Not Contain Triclosan”
The relevant ingredient is safe if used in accordance with the Regulation. Therefore, the claim that it does not contain these substances is prohibited because it will be understood as a tarnishing specific to the ingredient.
“Paraffin/Mineral Oil Free”
“Well tolerated because it does not contain paraffin/mineral oil” is an unfair statement against other products that are equally well tolerated. Therefore, the claim is prohibited.
“Allergen Free”
The fact that a product does not contain perfume or preservatives does not guarantee that it will not cause an allergic reaction. Therefore, the claim “allergic substance free” is not allowed for these products. “Does not have any risk of allergic reactions”, “Does not contain allergenic substances” or “Does not have any side effects” are not non-compliant since each human being has a unique immune metabolism.
Claims to Promote the Ingredient
If the product contains 10% Hyaluronic Acid, the claim “10% Hyaluronic Acid Serum” is appropriate. On the other hand, if the product contains “Allantoin”, the phrase “Snail Extract” used on the product packaging will not be appropriate. Moreover, claim stating that a product contains honey but there is honey flavor in the finished product is not compliant.
Claims to Promote the Ingredient’s Effect
If the product does not have a moisturizing effect, the claim “moisturizing” It is not appropriate to use the claim “contains aloe vera” or a prominent aloe vera image.
Environmental Claims
In order for the claim to be used, the sustainability of the company, production conditions or the entire life cycle of the product and many other factors must be taken into account.
In line with the “EU Green Claims Directive”, which is still in the draft phase, in order for any claim related to sustainability to be used, special labeling requirements or certification procedures must be met in order to be supported by measurable, relevant, meaningful, verifiable and concrete evidence.
Other Non-Compliant Claim Examples
- It is not appropriate to include health statements (cellulite reducer, wound healer, bruise reducer, diaper rash reliever, pain reliever, acne reducer, etc.) in the product name and claims.
- If skin redness claims only cover blemished skin and affect the red appearance with the function of makeup, the claim can be used; otherwise, claims referring to redness are not appropriate.
- Within the scope of product-specific evaluation; if a claim is made by mentioning an underlying disease for the product (for example, itching may be presented as a symptom of a disease even if it is not a disease), such claims are not compliant.
- Claims regarding effects and application methods such as Botox and mesotherapy are not appropriate because they are contrary to the definition of a cosmetic product.
Having trouble on choosing which claims to use for your cosmetics? Check out our Cosmetic Label Review service. Let our professional team reviews and guides you on your cosmetic labelling.
