In the world of cosmetics, deciding what claims are acceptable can be a minefield. Marketing teams want bold, benefit-driven language that pushes allowances to their limits, while R&D teams are meticulous about technical accuracy. 

And Responsible Persons (RPs) and regulatory teams? They’re stuck in the middle, possibly frustrated by marketing teams questioning: “Why can Brand X say that, but we can’t?”

The truth is that cosmetic claims are a grey area. What’s allowed isn’t just about the science, it’s about how the science is phrased. If a claim gives too strong an impression that leads the end consumer to believe it is healing, it’s not permitted. But, if it’s phrased to match the definition of a cosmetic, it is acceptable.

Take hair volume, for example:

• Stimulates growth – implies a physiological effect, so is not acceptable.
• Volumises or makes hair appear fuller – stays safely within cosmetic territory so is compliant.*

Or consider skin repair:

• Heals damaged skin” – suggests a therapeutic/healing action, so is not allowed.
• Improves the appearance of dry or damaged skin – this is a cosmetic benefit, so is permitted.*

Even the mention of a medical condition can shift a product into pharmaceutical territory.

• Suitable for eczema – references a medical condition, so is not permitted.
• For dry and sensitive skin – describes skin types without implying treatment, remaining cosmetic and therefore acceptable.*

These nuances matter. If a claim implies altering body function or structure, it risks breaching cosmetic definitions and triggering regulatory scrutiny. 

Remember, just because a claim is out there doesn’t mean it’s acceptable. With the right testing, language, and regulatory insight, we help brands make cosmetic claims that are compelling – but not misleading. 

That means checking:

• Ingredients – does the claim match what the ingredient is permitted to do?
• Substantiation – is there robust, scientific evidence to support the claim?
• Consumer interpretation – could the wording be misunderstood as therapeutic or healing?
• Markets – does the phrasing comply across different regions?
• Visuals – does the imagery reinforce or undermine compliance?
• Competitors – what’s being said elsewhere, and is it truly allowed?

For more support with cosmetic claims, please contact us.

*These examples are acceptable when supported with robust substantiation.