Let’s stir up some magic in the lab with a hot topic: how to write compliant cosmetic claims using EU cosmetic claims guidance.
If you are learning formulation or beginning your journey as a cosmetic brand, claim wording can feel like a foreign language. One extra verb and your moisturiser sounds like a medicine.

One vague sustainability boast and your body oil reads like greenwashing. Understanding claims on cosmetic products early will save you time, money and stress.

I will focus on the European Union first because that is where most of my brand clients launch, then highlight the big differences in the UK, US, Canada, Australia and ASEAN countries.

First principles: what the law actually regulates

In the EU, cosmetic products sit under Regulation 1223/2009. Article 2 defines what a cosmetic is, and Article 20 clarifies that any text, names, trade marks, pictures or other signs used in labelling, marketing or advertising must not imply characteristics or functions the product does not have. This regulation is the foundation of EU cosmetic claims guidance and governs all claims on cosmetic products.

On top of that, Regulation 655/2013 sets out six common criteria that every cosmetic claim must meet: legal compliance, truthfulness, evidential support, honesty, fairness and allowing informed decision making. Think of 655/2013 as your writing rubric. If a sentence fails any of the six, it does not belong on your packaging, website or product description page.

To help interpret those criteria, the European Commission published a Technical Document with practical examples, including how to handle “free from” and “hypoallergenic” statements. While not law, it is a key reference used by assessors when evaluating claims on cosmetic products.

Borderline products: spotting when a claim changes the category

Before you obsess over adjectives, confirm you are in the right regulatory family. The EU Borderline Manual provides case-by-case examples of products that sit between cosmetic and medicinal categories. It is an essential tool when applying EU cosmetic claims guidance in practice.

If a claim pushes your product toward preventing or treating disease, or toward changing physiology through pharmacological action, it may stop being a cosmetic altogether. Claims on cosmetic products must always remain within cosmetic intent.

Outside Europe, the boundary is drawn differently, but the principle remains the same. In the United States, the FDA classifies products based on intended use shown through claims. Acne treatment, dandruff control and SPF are drug claims in the US.

Health Canada assesses claims on cosmetic products through representation, composition and site of action. Australia applies similar logic via AICIS and the TGA.

The six EU common criteria
Legal compliance: Your claim must not suggest compliance with the law is a benefit. Claims such as “cruelty-free” or “paraben-free” can be misleading under EU cosmetic claims guidance.

Truthfulness: If you highlight an ingredient, it must contribute meaningfully to the cosmetic effect. Do not exaggerate concentration or form.

Evidential support: All claims on cosmetic products must be backed by appropriate evidence stored in the Product Information File.

Honesty: Testing conditions must be presented fairly, without cherry-picking data.

Fairness: Avoid denigrating competitors or lawful ingredients.

Informed decision making: Claims should provide meaningful, usable information for consumers.

How to learn claims writing

Start with three core documents that define EU cosmetic claims guidance.

Read Articles 2 and 20 of Regulation 1223/2009 to understand scope and claims boundaries. Study Regulation 655/2013 in full. Then review the Technical Document for applied examples. These three documents form the backbone of compliant claims on cosmetic products.

Bookmark the EU Borderline Manual and refer to it whenever a claim feels questionable.

If you plan to sell in the UK, review CAP and ASA guidance. For non-EU markets, familiarise yourself with FDA, Health Canada and TGA guidance to understand how claims on cosmetic products are interpreted globally.

Writing functional cosmetic claims: safe starting points

Appearance or feel claims
Examples include “visibly smooths”, “leaves skin feeling soft” and “adds shine”. These align with EU cosmetic claims guidance by focusing on cosmetic effect rather than medical outcome.
Mechanism phrasing that stays cosmetic

Use phrases such as “supports the skin barrier function” or “helps detangle for easier combing”. Avoid medical verbs like treats, heals or cures.

Time-bound outcomes

Statements like “absorbs quickly” or “hair feels softer after first use” are acceptable when substantiated.
Sensitive skin positioning

Many brands avoid “hypoallergenic” and instead use factual claims on cosmetic products such as fragrance-free or essential oil free.

From evidence to sentence: a classroom workflow
Define the visible or sensory promise
Select appropriate evidence
Test within the final formula and packaging
Write claims that reflect the data
File all substantiation in the Product Information File in line with EU cosmetic claims guidance
Green claims and “free from” statements

The Technical Document makes clear that claims on cosmetic products must not imply safety superiority over lawful alternatives. Statements must be factual and specific. In the UK, the ASA enforces similar standards for environmental claims.
Borderline practices to memorise

Acne
Cosmetics may cleanse or reduce the appearance of blemishes but not treat acne.
Hair growth
Claims must remain cosmetic in nature and focus on appearance or feel.
Tattoo aftercare
Moisturising and appearance claims are cosmetic. Fading or removal is not.
Aromatherapy

Claims must stay within perfuming and sensory experience to remain cosmetic.

Non-EU differences at a glance

The UK follows EU cosmetic claims guidance with enforcement by the ASA.
The US classifies products based on intended use.
Canada assesses claims on cosmetic products through representation and site of action.
Australia distinguishes between cosmetics and therapeutic goods using TGA tools.

What to do when you feel stuck
If wording feels medical, refocus on appearance or sensation. Replace treatment language with cosmetic framing. When unsure, consult EU cosmetic claims guidance and borderline manuals rather than social media advice.

Before I leave you,
If you want help reviewing claims on cosmetic products before launch, we offer consultations to align labels and marketing materials with regulatory expectations.

Email: contact@mbcosmeticslab.com for more information and advice on regulation.

Here’s to formulas that work and brands that thrive.
From my lab to yours,
Rose