Start by defining your performance claims first. These are the promises your product makes to the consumer: what it does, how it feels, and what results it delivers. Performance claims shape every formulation decision that follows, from ingredient selection to testing protocols. This article walks through the key questions around cosmetic product claims, including which are regulated, what evidence you need, and when to bring sustainability claims into the process.
Cosmetic product claims fall into three broad categories: performance claims, ingredient claims, and sustainability claims. Performance claims describe what the product does (moisturizes, strengthens, soothes). Ingredient claims highlight what is or is not in the formula (natural, preservative-free, vegan). Sustainability claims speak to environmental or ethical values (biodegradable, cruelty-free, recyclable packaging).
Each type of claim serves a different purpose in the consumer’s decision-making journey. Performance claims address efficacy, the core reason someone buys a product. Ingredient claims build trust and speak to values around health and transparency. Sustainability claims connect a brand to a broader mission and increasingly influence purchasing decisions in the natural cosmetics space.
It is also worth noting that some claims overlap. A product labeled “100% natural” is simultaneously an ingredient claim and, depending on the context, a sustainability claim. Understanding how your claims interact helps you build a coherent, credible brand story from the start.
In the European Union, cosmetic label claims are regulated under the EU Cosmetics Regulation (EC) No 1223/2009 and the associated Common Criteria Regulation (EU) No 655/2013. These rules require that all claims be truthful, substantiated, honest, fair, and not misleading. Certain specific claims, such as “hypoallergenic,” “dermatologically tested,” or any claim suggesting a medical effect, face stricter scrutiny and require documented evidence.
Claims that are not tightly regulated in terms of format or definition include general terms like “natural,” “eco-friendly,” or “sustainable.” While these are not banned, they are increasingly subject to scrutiny under broader consumer protection and green claims legislation. The EU Green Claims Directive, which is progressing through the legislative process, is expected to tighten requirements around environmental claims significantly.
The practical implication: regulated claims require formal substantiation before you go to market. Unregulated claims may feel more flexible, but they carry reputational risk if they are vague or unverifiable. Precision and honesty are always the safest approach, regardless of regulatory status.
Define performance claims first. Performance claims establish what the product needs to achieve, which directly determines which ingredients can and should be included. If you start with ingredient claims, you risk building a formula around a story rather than around efficacy, and that often leads to reformulation later.
For example, if your performance claim is “intensely hydrates dry skin within 24 hours,” your formulation team knows to prioritize humectants, emollients, and occlusive agents. From that ingredient selection, your ingredient claims follow naturally. You might then truthfully claim “enriched with plant-based hyaluronic acid” or “free from synthetic emollients.”
Ingredient claims should be treated as a consequence of formulation, not a driver of it. When brands reverse this order, they often end up with products that lead with ingredient marketing but underdeliver on results, which is damaging both commercially and for consumer trust in natural cosmetics claims more broadly.
Product claims act as a technical brief for formulation. Every claim you make places a requirement on the formula, whether that is a specific ingredient, a performance threshold, or a restriction on what can be included. Defining claims early in product development prevents costly reformulation and ensures your testing strategy is aligned from the start.
If your cosmetic product claim includes “suitable for sensitive skin,” your formulator will avoid known irritants and may choose to run a repeat insult patch test (RIPT) to substantiate that claim. If you claim “long-lasting,” the formulation needs to be optimized for durability and tested accordingly. Claims and formulation are not separate workstreams: they are interdependent.
In practice, the most efficient product development process involves aligning marketing, regulatory, and formulation teams around the intended claims before a single ingredient is selected. This collaborative approach reduces back-and-forth and ensures the finished product can genuinely support everything stated on the label.
To substantiate a cosmetic claim, you need documented evidence that is proportionate to the claim being made. Under the EU Common Criteria, evidence can include consumer perception studies, clinical trials, in vitro testing, or established scientific literature. The type and rigor of evidence required depends on how specific and how bold the claim is.
All substantiation data should be stored in your Product Information File (PIF), which is a legal requirement for cosmetics placed on the EU market. The evidence must be available for inspection and must directly relate to the finished product, not just individual ingredients in isolation.
Sustainability claims should be defined early in the product development process, ideally at the same time as performance claims. If sustainability is a core part of your brand positioning, as it is for most natural cosmetics brands, it needs to influence decisions about ingredient sourcing, packaging, manufacturing, and supply chain before those decisions are made, not after.
Defining sustainability claims late in the process often means retrofitting. A brand that decides to claim “biodegradable packaging” after selecting packaging materials may find that its chosen components do not meet the required standards, leading to delays or additional cost. The same applies to ingredient-related sustainability claims: “ethically sourced” or “fair trade” require supply chain verification that takes time to establish.
With the EU Green Claims Directive on the horizon, the bar for substantiating environmental claims is rising. Vague or unverifiable sustainability claims are increasingly a legal and reputational liability. Defining them early gives you the time to build genuine, documented evidence, which is the only kind worth putting on a label.
At Rebel Nature, we work with brands to align claims, formulation, and substantiation from day one. Here is what that looks like in practice:
Getting your product claims right from the start saves time, reduces risk, and builds a stronger brand. If you are ready to develop a natural cosmetic product with claims you can stand behind, get in touch with our team and let us help you build something worth talking about.
Not always. Substantiation evidence must relate to the finished product in its specific formulation, concentration, and application context. If two products share the same active ingredients at the same levels and make identical claims, some data may be transferable, but this should be assessed on a case-by-case basis with your regulatory advisor. Reusing data from a different formula, even a similar one, without proper justification can leave your claims legally vulnerable during a market inspection.
If a claim cannot be substantiated, you are exposed to enforcement action by national competent authorities, potential product recalls, and significant reputational damage. Under the EU Cosmetics Regulation, unsubstantiated claims are considered non-compliant, and regulators can require you to withdraw or amend your labelling. The safest course of action is to conduct a claims audit immediately, remove or revise any unsupported claims, and build your substantiation documentation before relaunching. Acting proactively is always less costly than waiting for enforcement.
Start by identifying the strictest regulatory framework among your target markets and use that as your baseline for claims and substantiation. The EU, for example, has more prescriptive requirements than many other regions, so EU-compliant claims and evidence will typically hold up well elsewhere. Work with a regulatory consultant familiar with each market, and maintain a flexible labelling strategy that allows claim wording to be adjusted per region without reformulating the product itself.
Yes. Avoid any claim that implies a medicinal or therapeutic effect, such as ‘heals,’ ‘treats,’ or ‘cures,’ as these cross the boundary from cosmetic into medicinal product territory and trigger an entirely different regulatory framework. Also steer clear of absolute claims like ‘100% effective’ or ‘the most natural formula,’ which are nearly impossible to substantiate and are flagged as misleading under EU Common Criteria. Vague environmental buzzwords like ‘green,’ ‘eco,’ or ‘planet-friendly’ without specific, verifiable backing are also increasingly risky under incoming EU Green Claims legislation.
There is no single legally mandated minimum, but industry practice and regulatory guidance suggest that consumer perception studies should involve at least 60 to 100 participants to be considered statistically meaningful for a general cosmetic claim. The sample should be representative of your target consumer group in terms of age, skin type, or hair type, depending on the product. Smaller panels may be acceptable for exploratory or supporting data, but they should not be the sole basis for a bold on-pack claim.
‘Dermatologically tested’ means the product has undergone a defined test under the supervision of a qualified dermatologist, which is a process-based claim you can substantiate with documented protocols and results. ‘Dermatologist approved’ implies an endorsement or recommendation, which is a stronger and more subjective claim that requires clear evidence of the dermatologist’s assessment and, in some markets, their explicit consent to be referenced. For most brands, ‘dermatologically tested’ is the safer and more straightforward claim to substantiate, provided the testing has been conducted properly and the results are stored in your Product Information File.
Ideally, from the very beginning, before claims are finalised and before formulation starts. Bringing in regulatory expertise at the concept stage means your claims are shaped by what is actually permissible and substantiable, rather than having to be walked back later. At a minimum, involve a consultant before any claim goes on a label, particularly for sensitive categories such as SPF, anti-ageing, sensitive skin suitability, or any sustainability-related claim that may fall under the EU Green Claims Directive.
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