To substantiate a vegan claim in the EU, brands must compile documented evidence proving that no animal-derived ingredients, by-products, or animal-tested raw materials are present in the finished product. This requirement falls under the EU Cosmetics Regulation (EC) No 1223/2009, which holds brands legally responsible for any claims they make on product labels or in marketing. The sections below break down exactly what that evidence looks like and where the common pitfalls lie.
To support a vegan claim in the EU, brands need a documented technical file that includes a full ingredient list with confirmed animal-origin status for each raw material, supplier declarations confirming no animal-derived inputs were used, and evidence of manufacturing controls that prevent cross-contamination. This file must be kept on record and made available to authorities on request.
The EU Cosmetics Regulation requires that all product claims be truthful, evidenced, and not misleading. For vegan claims specifically, this means going beyond the finished formula and tracing each ingredient back to its source. Supplier-issued Certificates of Analysis, ingredient specification sheets, and written declarations of vegan status are the core documents you will need. If you use a contract manufacturer, they should be able to provide much of this documentation as part of their standard product file.
It is also worth keeping records of any internal quality checks or audits that support the claim, since regulators may ask for proof that the vegan status of the product is actively maintained over time, not just verified once at launch.
Under EU rules, an animal-derived ingredient is any substance sourced from an animal’s body, secretions, or by-products. This includes obvious examples like beeswax, lanolin, carmine, collagen, and keratin, but also less visible inputs such as certain emulsifiers, glycerin of animal origin, and stearic acid derived from animal fat.
The challenge for brands is that many cosmetic ingredients can be either plant-derived or animal-derived depending on their source. Glycerin, for example, can come from vegetable oils or from animal fat processing. Squalane can be sourced from olives or from shark liver oil. Without supplier-level traceability, it is impossible to know which version you are using.
This is why ingredient sourcing documentation is so central to vegan claim substantiation. A vague ingredient name on a formula sheet is not sufficient. You need written confirmation from each supplier that specifies the biological origin of the raw material used in your product.
No, EU law does not currently provide an official legal definition of “vegan” for cosmetic products. The EU Cosmetics Regulation sets out general rules on claim substantiation and prohibits misleading claims, but it does not specify a binding standard for what qualifies a product as vegan.
In the absence of a legal definition, the industry largely operates on the commonly understood meaning: no animal-derived ingredients and no animal testing at any stage of production. The European Commission’s Common Criteria for cosmetic claims, established under Regulation (EU) No 655/2013, require that claims be honest, evidenced, and not misleading, which means the brand is responsible for defining what “vegan” means in the context of its product and then proving it meets that definition.
This regulatory gap is one reason third-party certification has become so widely adopted. It gives brands a defined, externally verified standard to point to when their vegan claim is questioned.
Both approaches are legally permissible in the EU, but third-party certification offers significantly stronger substantiation. Self-declaration is possible if you have robust supplier documentation and internal controls, but it places the full burden of proof on the brand. Certification from a recognised body provides an independently verified standard and reduces regulatory and reputational risk.
Organisations such as The Vegan Society, EVE VEGAN, and BeVeg offer cosmetic vegan certification programmes. Each has its own criteria, audit processes, and logo licensing terms. Certification typically requires a full ingredient review, supplier declarations, and a site inspection or documentation audit. Once certified, brands can use the certifier’s logo, which carries consumer recognition and signals credibility.
Self-declaring a product as vegan is a lower-cost route, but it requires equally thorough documentation. If a consumer complaint or regulatory inspection arises, the brand must be able to produce the same level of evidence a certifier would have reviewed. For smaller brands or those early in their vegan product journey, self-declaration without strong documentation carries meaningful legal exposure under EU claim rules.
Cross-contamination with animal-derived substances can invalidate a vegan claim if it is not identified, managed, and disclosed appropriately. If a product is manufactured on shared equipment that also processes animal-derived ingredients without adequate cleaning validation, the vegan claim becomes difficult to defend under EU substantiation requirements.
This is an area where manufacturing controls matter as much as the formula itself. Brands should ask their contract manufacturer for documented cleaning and segregation procedures, and ideally for evidence that those procedures are validated. Some certification bodies require a specific cross-contamination risk assessment as part of their audit process.
Where cross-contamination cannot be fully eliminated, some brands choose to add a precautionary statement to their labelling. This is a more transparent approach and may protect against a misleading claim finding, but it does mean the product cannot carry an unqualified vegan claim.
If a vegan claim cannot be substantiated, the brand is in breach of the EU Cosmetics Regulation and the Common Criteria for cosmetic claims. National market surveillance authorities can require the brand to remove or correct the claim, and in more serious cases, enforcement action, including fines or product withdrawal, can follow.
Beyond regulatory consequences, unsubstantiated vegan claims carry significant reputational risk. Consumer advocacy groups and vegan communities actively scrutinise label claims, and a credibility failure in this space can be difficult to recover from. With the EU’s Green Claims Directive also advancing through the legislative process, the regulatory environment around environmental and ethical claims is only becoming stricter.
The practical takeaway is that a vegan claim should never be treated as a marketing shorthand. It is a technical assertion that requires the same level of documented support as any other product claim.
As a contract manufacturer working exclusively with natural ingredients, we are well positioned to support brands that want to make credible, substantiated vegan claims. Here is what we bring to the process:
Whether you are launching a new vegan product line or reviewing the substantiation behind an existing claim, we are here to help you get it right. Get in touch with our team to discuss your formulation needs, or learn more about how we work with brands from concept through to finished product.
The timeline varies depending on how many ingredients are in your formula and how responsive your suppliers are, but brands should typically allow four to twelve weeks to compile a complete vegan substantiation file. The most time-consuming part is usually chasing supplier declarations for ingredients with ambiguous biological origins. Working with a contract manufacturer that already holds traceability documentation for its raw materials can significantly shorten this process.
Most recognised vegan certification bodies, such as The Vegan Society and EVE VEGAN, focus their criteria on the absence of animal-derived ingredients rather than the historical testing history of individual raw materials. However, their programmes do require that no new animal testing has been conducted on ingredients or finished products as part of your supply chain. It is worth reviewing each certifier’s specific criteria carefully, as they differ on how they handle legacy testing records and what documentation they require to confirm no current animal testing is taking place.
If a supplier is unable or unwilling to confirm the biological origin of a raw material in writing, that ingredient should be treated as unverified and should not be included in a product carrying a vegan claim. In practice, this means either finding an alternative supplier who can provide the required documentation or substituting the ingredient for one with a confirmed plant-based origin. Proceeding with a vegan claim on an ingredient that lacks proper documentation creates direct legal exposure under EU claim substantiation rules.
The Green Claims Directive, which is still progressing through the EU legislative process, is primarily aimed at environmental claims such as ‘eco-friendly’ or ‘carbon neutral,’ but its broader push for substantiated, verifiable ethical claims will likely raise the bar for all product claims, including vegan ones. Brands that already have robust documentation practices in place will be better positioned to adapt when the Directive comes into force. Now is a good time to audit your existing vegan claim files and ensure they would withstand a stricter scrutiny standard.
Yes, vegan claims can be made at the individual product level and do not need to apply to an entire range. However, brands should be careful about how this is communicated, particularly on websites and in marketing materials, to ensure consumers are not misled into thinking the broader range is vegan when it is not. Clear, product-specific labelling and claim language is essential in this scenario to stay compliant with the EU’s prohibition on misleading claims.
Vegan status should be re-verified whenever there is a change in the formula, a supplier change for any ingredient, or a change in the manufacturing site or process. Beyond these trigger events, it is good practice to conduct an annual review of your supplier declarations, since ingredient sourcing can change on the supplier’s side without proactive notification to you. Regulators expect vegan claims to be actively maintained, not just verified once at launch, so building a review schedule into your quality management process is strongly advisable.
Yes, several ingredients that appear in natural cosmetics are frequently assumed to be plant-based but may not be. Common examples include glycerin (which can come from animal fat), stearic acid and stearyl alcohol (often derived from tallow), shellac (secreted by lac insects), and certain hydrolysed proteins such as keratin or collagen. Even some natural waxes and emulsifiers can have animal-derived variants. This is precisely why ingredient-level supplier declarations are so important — the ingredient name alone is never sufficient to confirm vegan status.
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