How to substantiate cosmetic claims?

June 7, 2023 – Claims are used in all types of cosmetic products. They are an important tool to differentiate one cosmetic from the other and are also crucial for marketing purposes. However, it is essential to highlight that all claims on cosmetic labels must be supported by evidence.

Proofs of claims are mandatory by law

Article 20.1 of the EU Cosmetics Regulations states that: In the labelling, making available on the market and advertising of cosmetic products, text, names, trademarks, pictures and figurative or other signs shall not be used to imply that these products have characteristics or functions which they do not have. From this statement, it is important to highlight that proof of claims must be available for all claims made for cosmetic products, whether on the product label, online, or in an advertisement. Claims are not only words but also images and symbols.

Common Criteria for Cosmetic Claims

Claims on cosmetics must comply with Regulation 655/2013, establishing the common criteria for cosmetic claims. There are 6 common criteria for claims, and all of these must be taken into consideration. If a claim goes against one of these criteria, the product label cannot display such a claim. Specifically, the 6 common criteria are the following:

  • Legal Compliance
  • Truthfulness
  • Evidential Support
  • Honesty
  • Fairness
  • Informed Decision-Making

Studies, tests, and surveys to substantiate cosmetic claims

Manufacturers can refer to different types of evidential support to substantiate their claims. Some examples of proof of claims are experimental studies, consumer perception tests, publications or, indeed, a combination of these.

Product testing is crucial in substantiating claims made about cosmetic products. In such cases, qualified professionals should carry out the tests and document the results in detail. Upon request, consumers and regulators should have access to the evidence used to support claims. The data that should be accessible include the testing methodology used, the results obtained, and any limitations or caveats to the evidence.

Lastly, cosmetic claims should be truthful and not exaggerated. Exaggerated claims can mislead consumers and violate regulatory requirements. Additionally, manufacturers should phrase claims in a clear and precise language that is not open to interpretation.

If you are a manufacturer of cosmetic products and would like to know if your labels comply with the EU and UK regulations, contact us today!



European Commission. (2013). Commission Regulation (EU) No 655/2013o f 10 July 2013 laying down common criteria for the justification of claims used in relation to cosmetic products. Retrieved on 22/05/2023

European Commission. (2009). Regulation (EC) No 1223/2009 of the European Parliament and Of the Council of 30 November 2009 on cosmetic products. Retrieved on 22/05/2023

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