Ever since I started my own company, I’ve never dreaded Mondays again. And I wish the exact same for you too. But that can’t happen if your products are not compliant with your country’s cosmetic regulation.

So let’s dive in and stir up some magic in the lab with today’s hot topic, understanding which claims on cosmetic products you can make to stay compliant without losing impact.

Let’s get real. Most indie beauty brands are not intentionally breaking the rules. But if your marketing includes phrases like “heals eczema”, “treats acne”, or “kills 99.9% of bacteria”, you may be making unauthorised medicinal or therapeutic claims, even if your product genuinely helps with those concerns.

Here’s the catch. Truth is not always a legal defence. If you are marketing cosmetic products in the EU, US, Canada, Australia, and other regulated markets, your wording must reflect the legal definition of a cosmetic and respect how claims on cosmetic products are assessed by regulators.

In this article, we break down what makes a claim cosmetic versus medicinal, which phrases put brands at risk, how to communicate benefits legally, and how to write cosmetic claims guidelines that protect your brand while keeping your marketing compelling.

What Counts as a Cosmetic Claim?

Across the EU, US, Canada, Australia, and many other countries, cosmetics are defined by intended use. A cosmetic product is designed to cleanse, perfume, protect, or keep the skin in good condition. It works externally and cannot claim to treat or cure medical conditions.

The moment claims on cosmetic products imply altering the body’s function, offering therapeutic effects, or treating diagnosed conditions, the product may fall under drug, natural health product, or medicinal regulation, depending on the market. This is a costly and complex compliance pathway.

Why “But It’s True” Is Not a Legal Defence

You may have clinical studies, testimonials, or before and after photos. However, claiming to “heal rosacea” or “treat eczema” places your product outside the cosmetic category.

In the EU, even implied medicinal claims are prohibited. In the US and Canada, making such claims without drug or natural health product approval can result in warning letters, forced relabelling, or product recalls. This is why understanding how to write cosmetic claims guidelines correctly is essential from day one.

Common Phrases That Trigger Regulatory Red Flags

Certain phrases repeatedly trigger regulatory action when used in claims on cosmetic products, including:

“Heals eczema”
“Treats acne”
“Stimulates hair growth”
“Cures psoriasis”
“Kills bacteria”

These statements may feel powerful, but they imply medical action. Even well meaning indie brands fall into this trap when trying to express results.

Some ingredients sit close to regulatory boundaries. Salicylic acid, zinc oxide, and tea tree oil are known for therapeutic properties. Using them is allowed, but how you describe them matters. Saying “tea tree oil kills acne bacteria” crosses into drug territory, while “formulated with tea tree oil to help clarify skin” remains cosmetic.

Environmental and Ethical Claims: Avoiding Greenwashing

Beyond medicinal wording, environmental and ethical claims are also regulated. Statements like “100% natural” or “eco friendly” must be substantiated.

Under EU Regulation 655/2013, green claims require evidence. For example, “biodegradable” must be supported by degradation testing, while “100% natural” requires fully plant derived ingredients with supplier documentation. Making these statements without proof can expose brands to greenwashing enforcement.

Cruelty free labelling is also regulated. In the EU, animal testing is already banned, so the claim adds no legal value. In other markets, cruelty free claims must reflect the entire supply chain and are best supported by recognised certifications.

Understanding how to write cosmetic claims guidelines helps avoid these pitfalls while still appealing to conscious consumers.

How to Talk About Benefits Safely

You can remain compliant without sounding dull. Instead of “treats eczema”, use “soothes dry, irritated skin”. Instead of “stimulates hair growth”, say “supports a healthy looking scalp”.

These alternatives focus on appearance and condition rather than medical outcomes. They are legally safer and often more emotionally engaging. Writing effective claims on cosmetic products is about reframing benefits, not weakening them.
Influencer content is another risk area.

In 2026, regulators increasingly assess claims made by creators as part of a brand’s marketing activity. If influencers describe your product as curing or treating conditions, your brand may still be held responsible. Clear guidance on how to write cosmetic claims guidelines should always extend to influencers and partners.

Country Specific Rules to Know

EU and UK brands must follow Regulation (EC) No 1223/2009 and Regulation 655/2013. Claims must be truthful, substantiated, and not misleading.

When selling across the EU, translations must also remain compliant. Labels must appear in national languages, and mistranslations that introduce medicinal meaning are still the brand’s responsibility. Understanding claims on cosmetic products includes mastering compliant translations.

In the US, cosmetics are regulated by the FDA. Claims suggesting changes to skin structure or function may classify a product as a drug. The MoCRA update also introduces new labelling and safety requirements.

In Canada, Health Canada enforces the Cosmetic Hotlist. Products claiming to prevent, treat, or cure conditions may be regulated as Natural Health Products.

In Australia, AICIS and the TGA oversee cosmetics. Claims such as “kills 99.9% of germs” require therapeutic product registration. Cosmetic claims must remain limited to cleansing, protecting, or improving appearance.

How to Check If Your Claim Is Safe

Before publishing marketing content, ask yourself:
Does the claim describe appearance or condition rather than a cure?
Could it be interpreted as a drug or natural health product claim?
Is the claim consistent across packaging, website, and social media?
Do you have evidence to support it?
Would it withstand a regulatory audit?
Is it aligned with ingredient supplier documentation?

If the answer is no, the wording should be revised.

Ingredient studies alone are not sufficient. EU regulations require substantiation at finished product level for claims like “hydrates for 24 hours” or “reduces wrinkles in 14 days”. Understanding how to write cosmetic claims guidelines means recognising this distinction.

Social Media and Influencer Claims

Social media is a powerful marketing tool, but it carries compliance risks. A single post claiming your product “cures acne” can trigger enforcement action.

To stay compliant, provide influencers with approved wording. Replace medical language with cosmetic descriptors such as “reduces the appearance of redness”. Disclaimers like “not a medical treatment” can help clarify intent but do not replace compliant wording.

What Counts as Claim Substantiation?

Substantiating claims on cosmetic products may involve:
Ingredient studies at effective concentrations
In vivo or in vitro testing
Consumer perception trials
Expert assessments
Finished product testing for time based claims

Ingredient efficacy does not automatically translate to finished product performance. Percentages, formulation stability, and delivery matter.

If budgets are limited, early stage brands can collect structured user feedback and retain it in the PIF. While this does not support claims like “dermatologically tested”, it can help justify softer cosmetic wording until proper testing is conducted.

How to Be Compliant and Compelling

Compliance does not mean boring. You can still say:
“Loved by sensitive skin”
“Hydration that lasts. Glow that shows.”
“Formulated with plant extracts used for centuries to calm and comfort”

The key is honest, appearance based language that aligns with how cosmetic products are legally defined. Knowing how to write cosmetic claims guidelines allows creativity without regulatory risk.

If you are working with influencers, ensure they follow the same rules. Regulators do not distinguish between brand and ambassador when assessing claims on cosmetic products.

Final Thoughts

You can be compliant, clear, and captivating at the same time. But crossing the line, even unintentionally, can cost your brand time, money, and trust.

Marketing builds visibility. Compliance protects it long term.

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

P.S Want to learn more about cosmetic regulation and compliance?

We have created an ebook to help you avoid any legal triggers. Click the link below to download your copy.

https://www.mbcosmeticsacademy.com/product/cosmetic-labelling-guide/

From My Lab to Yours,
Rose