Let’s stir up some magic in the lab with today’s hot topic: how to create cosmetic marketing claims that excite your customers while staying perfectly aligned with EU Regulation 655/2013. For beauty founders, formulators and brand builders, compliant claims are not only a legal requirement but a powerful tool for shaping brand trust, product positioning and long-term customer loyalty.

Yet the moment the words “claims regulation” appear, most founders tense up. It feels rigid, intimidating and overly technical. But here is the truth: once you understand the logic of the rules, crafting compliant cosmetic claims becomes fun, empowering and even strategic. And that is exactly what we will do today.

This article breaks down the EU’s common criteria for cosmetic claims into plain language, using practical examples and industry insight to help you write claims that are compliant, marketable and uniquely yours.

Why Cosmetic Claims Matter More Than Ever in the EU

Marketing claims shape how consumers understand your product’s benefits. They influence purchasing decisions, define brand voice and determine your position on the market. But they also serve another purpose: they prevent confusion between cosmetics and other regulated categories such as medicines, biocides and medical devices.

This is why Article 20 of Regulation (EC) 1223/2009 requires that all cosmetic claims be truthful, evidence-based and never misleading. And to make this even clearer, Regulation 655/2013 established six common criteria that every cosmetic claim must meet.

When you understand these six criteria, you can write claims confidently, creatively and compliantly.

The Six Common Criteria for Cosmetic Claims (Explained Simply)

1. Legal Compliance: The Claim Must Respect EU Law

In practice, this means you cannot imply:

• That a product has obtained official approval

• That the product is safer or more compliant than others

• That you respect laws that everyone already must follow

For example, the claim “this product complies with EU cosmetic regulations” is not acceptable because all products must comply. Likewise, you cannot claim “Approved by the EU” because no such approval exists. Nor can you claim “cruelty-free”, because all brands selling in the EU have to comply with the ban on animal testing

A compliant claim focuses on benefits, not legal status.

2. Truthfulness: Say What You Mean and Mean What You Say

Truthfulness requires that:

• If you claim a product contains an ingredient, it must actually contain that ingredient.

• If you highlight a benefit associated with the ingredient, the finished product must deliver that benefit.

• If you show a visual of aloe vera, consumers must reasonably expect moisturising benefits from the product and include Aloe Vera.

This avoids misleading implications and protects consumer trust.

3. Evidential Support: Every Claim Must Have Adequate Proof

Evidence can come from:

• Clinical testing

• Instrumental measurements

• Consumer perception studies

• Peer-reviewed literature

• In vitro or ex vivo models (when used appropriately)

But regardless of the type of evidence, it must be:

• Relevant

• Scientifically sound

• Reproducible

• Reflective of the finished product

For example, you cannot claim “48-hour hydration” if your data only supports 24 hours. And you cannot rely solely on ingredient claims without demonstrating the finished formula performs as claimed.

This is the core of compliant claim substantiation.

4. Honesty: Stay Within the Limits of Your Evidence

Honesty is about avoiding exaggeration. You cannot imply a product performs better than your data supports, and you cannot digitally manipulate “before and after” photos in a way that misleads.

The rule is simple: if your tests do not prove it, do not claim it.

5. Fairness: Do Not Denigrate Competitors or Ingredients

EU law discourages claims that unfairly criticise:

• Competing products

• Legally approved cosmetic ingredients

For instance, you cannot say “better tolerated because it contains no mineral oil,” because this implies mineral oils are poorly tolerated, which is not scientifically supported.

The EU protects both consumer understanding and fair competition.

6. Informed Decision-Making: Claims Must Be Easy to Understand

Claims should be:

• Clear

• Transparent

• Understandable by the average consumer

• Supportive of consumer choice

If your audience is professional (e.g., dermatologists), more technical wording may be appropriate. For general consumers, keep the language simple and accessible.

This is the regulatory foundation for all compliant cosmetic communication.

How to Turn These Rules into Magnetic, Compliant Claims

Now that we have the legal criteria, let’s translate them into a practical, creative process for founders and marketing teams.

Creating EU-compliant claims is not about limiting creativity. It is about giving your product a clear, credible voice that resonates with consumers and stands up to scrutiny.

Here is how you can approach claim development with confidence.

Step 1: Understand Your Product’s Primary Function

EU law defines a cosmetic based on its intended use. Your claims must align with cosmetic functions such as:

• Moisturising

• Cleansing

• Smoothing

• Perfuming

• Protecting

• Maintaining good condition

If your claims drift toward treating or preventing disease (e.g., “treats eczema,” “heals psoriasis”), you fall outside the cosmetic scope. That is where many new brands make mistakes.

Step 2: Build Claims Directly From Your Evidence

Ask yourself:

• What does my testing actually demonstrate?

• Can I quantify the results?

• Does my data support an objective or subjective claim?

For example:

Clinical measurement → “Improves skin hydration by 32 percent after one application.”
Consumer perception → “93 percent of users reported softer, smoother skin.”

Choosing the right type of claim depends entirely on your data.

Step 3: Avoid Implicit Medical Claims

You cannot imply medical treatment even if you do not use medical words.

For example, “reduces inflammation associated with eczema” is not acceptable for a cosmetic product. Instead, you can say something like:

• “Helps soothe dry, irritated skin.”

• “Helps maintain the skin’s comfort and suppleness.”

This stays within cosmetic territory.

Step 4: Keep Your Claims Consistent Across All Touchpoints

EU compliance extends to:

• Packaging

• Websites

• Social media

• Advertising

• Retailer listings

• Clinical studies summaries

If you revise your marketing, make sure the claims remain consistent with the product information file (PIF) and do not create a new intended purpose.

Making Sense of “Free-From” Claims (Annex III)

The beauty industry loves “free-from” claims. Consumers love them too. But the EU has very specific rules about how they can be used, and misusing them is one of the most common compliance mistakes seen in audits and market surveillance. Here is what the regulation says, simplified:

When “Free-From” Claims Are Not Allowed

A free-from claim is unacceptable when:

• It refers to an ingredient already banned in the EU (e.g., “free from corticosteroids”).

• It implies safety concerns where none exist (e.g., “free from parabens,” because approved parabens are considered safe).

• The ingredient is not typically used in this product category (e.g., “free from preservatives” in high-alcohol fine fragrances).

• The product actually contains an ingredient with the same function under a different name.

This protects ingredient groups from unfair denigration and prevents misleading messaging.

When “Free-From” Claims Are Allowed

They can be acceptable when they support informed consumer choices about:

• Vegan needs (“free from animal-derived ingredients”)

• Scent sensitivities (“free from perfume”)

• Lifestyle preferences (“free from alcohol” in family-friendly products)

The key requirement remains: the claim must be truthful and not imply a safety advantage that cannot be scientifically guaranteed.

Understanding Hypoallergenic Claims (Annex IV)

Hypoallergenic claims require a strict standard of evidence. According to the EU guidance, a product may only claim to be hypoallergenic if it has been formulated to minimise allergenic potential and avoids all known or suspected sensitising ingredients.

This means:

• No known allergens

• No known allergen precursors

• No ingredients classified as skin sensitisers (Category 1, 1A or 1B)

• Continuous assessment through consumer feedback

A hypoallergenic claim does not mean a product can guarantee zero allergic reactions. It simply indicates an intentional minimisation of risk.

Practical Examples of Compliant Claims (and Why They Work)

Here are examples that comply with EU rules, along with their reasoning.

“Boosts skin hydration for up to 24 hours.”

Acceptable when supported by clinical data.

“Helps maintain the skin’s natural moisture barrier.”

A cosmetic function that remains safely within regulatory boundaries and should be proven with scientific literature.

“Tested under dermatological supervision.”

Allowed when testing followed the correct methodology described in Annex II.

“Suitable for sensitive skin.”

Acceptable with appropriate evidence and no sensitising ingredients.

“Free from animal-derived ingredients” 

Allowed because it supports ethical consumer choices without denigrating other products.

These examples strike the right balance between engaging marketing and regulatory compliance.

Mistakes That Frequently Lead to Enforcement Actions

Authorities across the EU monitor compliance through in-market controls. The most common issues include:

• Overstated efficacy claims

• Implicit medicinal claims

• Ingredient-related claims that do not reflect the finished product

• Unsupported longevity claims (e.g., 72-hour moisture)

• Misleading before/after imagery

• Unacceptable free-from claims

• Claims that contradict the formula’s safety assessment

How Founders Can Build a Strong Claims Strategy From Day One

The most successful beauty brands develop claims early in the formulation process. This ensures that the lab, marketing team and regulatory consultant work in perfect alignment.

A robust claims strategy includes:

• Defining marketing goals

• Matching claims to formula capabilities

• Selecting the right substantiation methods

• Documenting all evidence

• Training the marketing team in compliant language

This transforms claims from a “risk area” into a competitive advantage.

As I end this article today, let me leave you with my final thoughts:

Compliance and creativity can absolutely coexist! The EU Regulation 655/2013 is not designed to restrict creativity. It is designed to protect consumers and ensure fair competition. And when you understand the rules, you gain the freedom to write claims that are exciting, emotionally resonant and regulatory-proof.

Compliant claims are a hallmark of a trustworthy brand. They elevate your authority and strengthen everything you do as a formulator and founder.

Here’s to formulas that work and brands that thrive!

From my lab to yours,

Rose