In today’s luxury skincare market, “natural” is one of the most powerful words a brand can use. Not only does it evoke a sense of purity and sustainability, but it also fosters consumer trust and gives the impression of a brand’s ethical commitment. However, the reality beneath this appealing image is far more nuanced: the term “natural” within cosmetics lacks a universally accepted definition. Unlike the food or agricultural sectors, which have well-established, regulated organic and natural standards, cosmetics in both the EU and UK operate without such legal clarity. This absence of regulation often results in widespread confusion, inconsistent product claims, and, at times, accusations of greenwashing as companies interpret “natural” to suit their own marketing narratives.
To address this ambiguity, ISO 16128 was developed, a globally recognised standard aimed at bringing more clarity, structure, and scientific rigor to claims about natural ingredients in cosmetics. Released in two parts (2016 and 2017), ISO 16128 provides a robust framework that guides brands in classifying ingredients and in accurately calculating natural origin indices. For professionals like formulators, CEOs, and R&D leads, the standard acts as a crucial navigational tool; it enables robust claim substantiation anchored in scientific methodology rather than subjective opinion or marketing spin.
Credibility lies at the heart of luxury brands. Discerning consumers expect more than just rich textures and elevated sensory experiences, they also demand full transparency and reliable proof behind product claims. ISO 16128 offers a bridge between brand storytelling and science by:
By implementing ISO 16128, brands can provide accurate and transparent percentages to support their “natural” claims, meeting the expectations of not only regulators and certifiers but also well-informed consumers who are increasingly wary of vague or misleading messaging.
The first section of the standard is devoted to clear definitions. It categorizes cosmetic ingredients according to both their original source and the nature of processing involved:
This systematic classification is vital in reducing the risk of deceptive marketing. Importantly, any material sourced from fossil fuels is categorically excluded from being described as “natural,” which protects both brand integrity and consumer interest.
The second part of the standard outlines the specific formulas to be used for calculating the natural origin indices of cosmetic products. These calculations empower brands to make claims such as “95% natural origin” with confidence and consistency.
Key steps include:
Such a process not only ensures a uniform approach across the industry but also supplies the necessary documentation for certification bodies like COSMOS or NATRUE, which routinely require validated natural origin data as part of their approval process.
Despite its strengths, ISO 16128 is not intended as a catch-all. Some critical aspects remain outside its remit, including:
This is why brands must turn to guidance such as the Common Criteria, which emphasizes that claims should be transparent, evidence-based, and must not mislead consumers into thinking “natural” equates to increased safety. The UK’s Advertising Standards Authority (ASA) underscores this: “Claims that organic products are inherently safer than non‑organic ones are likely to be problematic.”
For CEOs, adherence to ISO 16128 is a strategic move to protect and enhance brand reputation in an era where consumer skepticism and regulatory scrutiny are at an all-time high. Unsubstantiated or vague “natural” claims can jeopardize trust and open brands to reputational and legal risks. Conversely, substantiated percentages and clear compliance offer a compelling narrative to justify premium positioning and build long-lasting trust.
For R&D leads, the standard is a practical blueprint for responsible and innovative formulation. It not only facilitates the creation of products that meet evolving consumer preferences and regulatory standards but also enables seamless collaboration across teams—whether working with suppliers, certification agencies, or marketing departments.
While ISO 16128 is not a tool for crafting compelling marketing slogans, it does provide the scientific backing needed for credible product stories. Formulators should leverage it to develop claims that are precise and compliant with local regulations and documentation needs, such as CPSRs or Product Information Files. Consider the following best practices:
This responsible approach helps prevent consumer confusion while reinforcing brand integrity and trust.
Looking to the future, several key trends are set to influence how ISO 16128 will be applied in the industry:
Forward-looking brands that embrace these developments will meet, and often exceed, regulatory and consumer expectations for openness and authenticity.
In today’s luxury skincare landscape, effectively mastering natural ingredient claims is not just a compliance exercise—it’s an essential pillar of leadership and competitive differentiation. ISO 16128 delivers the scientific groundwork needed to substantiate claims, align with esteemed certifications, and foster robust consumer trust.
For CEOs, it safeguards and props up brand equity. For R&D professionals, it guides responsible innovation. For formulators, it brings much-needed clarity to a complex and evolving marketplace. And for consumers, it transforms “natural” from a mere marketing buzzword into a substantiated and meaningful promise.
At Olalla Consulting, we view substantiation as a path to leadership. By fully embracing ISO 16128, brands don’t just tick regulatory boxes, they elevate their stories, reinforce trust, and secure a place at the forefront of luxury skincare innovation.