Cosmetic claims are central to how products are marketed and understood. They communicate the benefits, values, and differentiators that help shape consumer perception and influence purchasing decisions. In today’s market, however, the regulatory environment has become increasingly complex and demanding. The European Union has introduced stricter requirements to ensure that all claims made about cosmetic products are not only compelling, but also fair, substantiated, and transparent to consumers.
Regulation (EU) No 655/2013 is at the heart of this shift, establishing six common criteria that underpin all cosmetic claims within the EU. These criteria are designed to safeguard consumers, promote fair competition, and uphold the integrity of the cosmetics industry as a whole. For brands operating in this sector, gaining a comprehensive understanding of these rules and applying them consistently is not only vital for legal compliance, but also fundamental to building long-term consumer trust.
Claims must adhere fully to all applicable laws and regulations.
Example: In the EU, animal testing for cosmetics has been banned for many years. Therefore, marketing a product as “cruelty-free” might seem like a point of distinction, but in reality, every cosmetic product must comply with this legal requirement.
Key point: Legal compliance is non-negotiable and cannot be promoted as a unique selling feature.
Claims should accurately and honestly represent the product’s characteristics and performance.
Example: If a product claims to be “eco-friendly,” it must be able to demonstrate tangible, measurable environmental benefits. Using generic or subjective terms such as “green” is not permitted unless specific evidence is provided.
Key point: Avoid ambiguous or unsubstantiated language. Ensure each claim can be precisely described and verified.
All claims must be substantiated by reliable and sufficient evidence.
Example: Stating that a product “reduces wrinkles” requires supporting data from randomized clinical trials. Similarly, a claim of “sustainably sourced” ingredients must be supported by recognized certifications like RSPO or FSC.
Key point: Claims should be underpinned by data or third-party certification. Personal testimonials or informal supplier statements are not enough.
Claims must not exaggerate benefits or create false impressions about the product.
Example: The label “dermatologist-recommended” should not imply widespread endorsement if feedback was obtained from only a small number of professionals.
Key point: Avoid exaggerated statements. Clearly define the context and scope of endorsements or tested benefits.
Claims should be made without unfairly discrediting competitors or inciting unnecessary fear among consumers.
Example: The phrase “free from chemicals” is misleading since all cosmetics are composed of chemical ingredients. Such a statement could unfairly suggest that rival products contain harmful substances.
Key point: Marketing messages should be balanced, factual, and not exploit misconceptions or unfounded concerns.
Product claims must empower consumers by providing them with clear and accessible information.
Example: When using terms like “natural,” brands should disclose exact percentages and specify the standards followed (such as ISO 16128). Similarly, a “recyclable” claim should clarify what is actually recyclable based on local facilities.
Key point: The goal is to give consumers meaningful, actionable information to guide their purchasing choices.
Bondi Sands “Reef Friendly” Sunscreen
Denmark’s Ombudsman on “Recycled Plastic”
These examples highlight the business and reputational risks associated with unsubstantiated or unclear claims—demonstrating the importance of robust compliance.
Adhering to these criteria is about more than just following the law,it’s a strategic differentiator in a crowded marketplace.
Recent surveys reveal that 73% of consumers are willing to pay more for brands that demonstrate transparency, while 90% of Gen Z customers expect businesses to play an active role in combating climate change. Brands that consistently make transparent, substantiated claims build trust, deepen loyalty, and set themselves apart from less scrupulous competitors.
Regulation (EU) No 655/2013 provides a comprehensive structure for cosmetic claims that all brands must follow. By systematically ensuring that every claim demonstrates legal compliance, truthfulness, evidential support, honesty, fairness, and a commitment to informed decision-making, brands can not only stay on the right side of regulation but also build lasting relationships with their customers.
Taking proactive steps to audit current practices, define and substantiate standards, communicate with transparency, and foster team alignment will empower brands to turn regulatory obligations into genuine opportunities for growth and reputation building.
At Olalla Consulting, we are dedicated to helping brands navigate this evolving landscape. With three decades of experience in cosmetic compliance, our team can guide you in transforming cosmetic claims from regulatory risks into opportunities for increased trust and competitive advantage.
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