What is a claim:
Claim is a slogan or description of the product that allows you to present the product itself to the customer, focusing attention on the main features, allowing him to choose the most suitable cosmetic product for his needs and for the company to stand out in the market.
For this reason, to avoid untrue or misleading words that prevent the customer from making an informed choice and that provide an improper advantage to the company, even the claims that can be applied on the labels of cosmetic products are governed by a specific regulation.
The reference regulation is Reg. (EC) 655/2013 ” laying down common criteria for the justification of claims used in relation to cosmetic products” and in particular its only annex, which groups together the common criteria that must comply with the claims of cosmetics product.
Common criteria for claims:
The common criteria are divided into six points:
- Legal compliance
For cosmetic products no registration or authorization by the authorities are needed. For this reason, claims such as “authorized by the European Commission” or “Registered Cosmetic” are not allowed. Similarly, it is not allowed to use claims that may give the impression of a particular benefit, if this benefit is a legal requirement. For example, the claim “Not tested on animals” is not allowed because animal testing for cosmetic products and their ingredients is prohibited by the European regulation, or “Without formaldehyde” since every cosmetic product must be formaldehyde-free as an ingredient prohibited within cosmetic products.
If the presence of a specific ingredient is declared or a specific property of an ingredient is reported, the finished product must contain that specific ingredient or having that property itself. For example, it is not possible to report “With lemon juice” if only lemon flavor is present or “With moisturizing plant extracts” if the finished product does not have moisturizing properties. Then, commercial messages must not give the impression that the opinions expressed are verified statements, unless they are supported by verifiable evidence.
- Evidential support
This section establishes some criteria regarding the studies and evidence that must be presented in support of a claim. It is also specified that for claims that are clearly exaggerated or abstracted, there is no need for supporting evidence. For example, the claim “For hair as soft as a cloud” does not need proof because it is an abstracted and exaggerated comparison.
The presentation of a product’s performance should not go beyond the available supporting evidence. Furthermore, specific characteristics cannot be attributed to the product if similar products possess them and the specific conditions to which the action of a product is linked must be declared. For example, if the anti-wrinkle effect of a cream is bound to the simultaneous use of a face serum, then it must be specified. Writing “This cream makes your skin younger” is incorrect, as the consumer does not perceive that he also needs the serum to benefit from the declared effects.
Product claims must not disparage competing products or create confusion with them. For example, “Without acidic ingredients that can irritate the skin” is disparaging towards competitive products that contain them.
- Informed decision-making
Marketing communications shall take into account the capacity of consumers to understand the messages and be easily understandable. Furthermore, the claims are an integral part of the products and shall contain information that allows the average end user to make an informed choice.
For more information:
REGULATION (EU) N. 655/2013