How are cosmetic claims regulated and evidenced?

1. Legal compliance: claims implying authorisation by a competent authority are not allowed.
2. Truthfulness: claims must not attribute properties the product does not have.
3. Evidential support: every claim must be supported by adequate and verifiable evidence.
4. Honesty: claims must not exaggerate the performance.
5. Fairness: claims must not denigrate competitors or legally used ingredients.
6. Informed decision-making: claims must allow the average end user to make an informed choice.

The 2017 Technical Document on Cosmetic Claims sets out acceptable evidence types: experimental studies (in vivo, in vitro, ex vivo), consumer perception studies for sensory claims, published literature for established ingredient effects and bibliographic data for well-known mechanisms. Marketing materials, customer testimonials and influencer content are not evidence.

The 2019 update to the Technical Document tightened claims that disparage entire ingredient categories. "Free-from preservatives" is not allowed if the product is preserved by an ingredient with secondary preservative function. "Hypoallergenic" requires evidence of minimised allergen potential. "Natural" and "organic" are not legally defined in the EU; if used, the methodology (e.g. ISO 16128, COSMOS) must be specified.

MoCRA's safety substantiation requirement extends to claims: the Responsible Person must hold evidence supporting safety, which in practice includes claim substantiation for any performance or skin compatibility claim. The FTC separately polices deceptive advertising. Free-from and natural claims in the US are governed by FTC guidance and state-level legislation (notably California).

Every claim on a cosmetic, on-pack, online or in marketing, needs evidence on file that meets the EU Common Criteria, UK CPR or the equivalent in each market. Keeping the evidence linked to the SKU, the claim wording and the channel is where most teams lose control.

Worldover ties every claim to the SKU, the substantiating evidence and the markets it applies in. When a claim wording changes or new market guidance lands, affected SKUs, artwork and digital assets surface automatically, and Willow drafts the substantiation gaps for the regulatory team to close.