Quick Answer: EU cosmetic claims are governed by Article 20 of Regulation (EC) No 1223/2009 and Commission Regulation (EU) No 655/2013. Claims on labels, websites and advertising must not mislead consumers about a product’s characteristics or functions, and they must satisfy six common criteria. The EU Responsible Person should keep evidence for claimed effects in the Product Information File before the final wording is released.
Last reviewed: 27 September 2026. Editorial review: MOOYAM cosmetic compliance content team. This guide is for international B2B beauty brands and their EU Responsible Persons; it does not decide whether a particular proposed claim is lawful.
What counts as a cosmetic claim in the EU?
Commission Regulation (EU) No 655/2013 applies broadly to text, product names, trademarks, pictures and other signs that explicitly or implicitly communicate a cosmetic product’s characteristics or functions. Its scope includes labelling, making the product available on the market and advertising, regardless of the medium or target audience. A website headline, marketplace image or influencer brief can therefore create a claim even when the carton uses cautious wording.
Article 20 of Regulation (EC) No 1223/2009 says cosmetic labelling, marketing and advertising must not imply characteristics or functions that the product does not have. The specific common criteria are in Commission Regulation (EU) No 655/2013. Read both together. The six criteria are not a list of pre-approved advertising phrases; they are a framework to assess the meaning of each claim in its commercial context.
| EU authority / instrument | Role in claim review | Practical question |
|---|---|---|
| Regulation (EC) No 1223/2009, Article 20 | Prohibits claims implying characteristics or functions the product lacks | What impression does the complete presentation create? |
| Commission Regulation (EU) No 655/2013 | Sets six common criteria and links claims to PIF evidence | Does the wording and its support satisfy every relevant criterion? |
| European Commission technical document | Interpretive examples and guidance, not a substitute for law | Which examples help explain a borderline phrase? |
The six common criteria, translated into a review checklist
Legal compliance: Do not suggest that an EU competent authority approved the cosmetic or market mere compliance with minimum legal obligations as a special benefit. Truthfulness: The claim should reflect reality; a named ingredient must actually be deliberately present, and its properties must not be wrongly attributed to the finished product. Evidential support: Explicit and implicit claims need adequate, verifiable support suitable for the asserted benefit.
Honesty: Do not exaggerate the product’s performance or imply that a test demonstrates more than it did. Fairness: Do not denigrate competitors or lawful ingredients unfairly. Informed decision-making: Claims should be clear and understandable to the average end user. The assessment considers the consumer’s likely overall impression and relevant social, cultural and linguistic factors, not only the copywriter’s literal interpretation.
| Review gate | Evidence or decision needed | Release owner |
|---|---|---|
| Product and claim meaning | Final artwork, name, visuals, translations and digital copy | Brand and EU Responsible Person |
| Substantiation | Relevant, reliable product-specific studies or other appropriate evidence | Brand with qualified reviewers |
| PIF consistency | Proof of the claimed effect where justified by claim nature/effect | EU Responsible Person |
| Change control | Records of formula, test, packaging and wording versions | Brand, manufacturer and Responsible Person |
How much evidence does a claim need?
The evidence must suit the claim actually made. A mild sensory statement, an ingredient-content statement and a quantified performance claim do not have identical support needs. The Annex to Regulation 655/2013 requires adequate and verifiable evidence for explicit and implicit claims. Where studies are used, they should be relevant to the product and claimed benefit, use well-designed methods and follow ethical principles. Do not invent percentages or extrapolate a raw-material study into a finished-product promise without a defensible bridge.
Article 11 of the cosmetics regulation requires the Product Information File (PIF) to contain proof of the effect claimed for the cosmetic product where justified by the nature or effect of the claim. The Responsible Person must ensure the claim wording is consistent with that documentation. A CPSR addresses product safety; it does not automatically prove a marketing performance claim. A CPNP notification is also not claim approval.
A controlled claim-release workflow for brands
First, define the exact consumer-facing statement and the impression created by images and product name. Second, confirm that the promised effect stays within the cosmetic-product category. Third, identify the evidence needed before commissioning package design or paid media. Fourth, review the final formula and finished product against the evidence, noting study conditions and limits. Fifth, have the EU Responsible Person check wording, translations and PIF consistency. Sixth, freeze the approved asset versions and require re-review after changes.
This workflow belongs in the same release process as EU Cosmetics Regulation compliance and ingredient screening. A compliance claim can fail even if the formula and label’s mandatory particulars are otherwise correct. Conversely, accurate test data can be undermined by an overbroad headline or visual.
What can a cosmetic manufacturer provide?
A manufacturer can supply the final INCI composition, formula version, raw-material specifications, COA, SDS where applicable, stability and microbiological results, packaging-compatibility information and batch records. It may support agreed performance tests or provide objective manufacturing facts. The brand chooses commercial messaging; the EU Responsible Person must ensure that claims meet the applicable criteria and align with the PIF. The parties should agree who retains underlying reports and who approves each market-language version.
Claims such as “dermatologist tested,” “clinically proven” or quantified results should be assessed against the actual study design and the overall consumer impression. They are not automatically forbidden or permitted as words alone. Avoid using a supplier’s generic ingredient study to imply that the finished cosmetic achieves the same result unless the evidence supports that specific inference.
FAQ
Is a CPNP number proof that a cosmetic claim is approved?
No. CPNP is a notification mechanism, not a marketing-claim approval. The Responsible Person must separately assess claims and supporting evidence.
Do social-media and product-page statements count?
Yes. Regulation 655/2013 applies across marketing media, including implied messages from names and images, not only words on the physical pack.
Can the brand use results from an ingredient supplier?
They may be relevant background, but the claim about the finished cosmetic must be adequately supported. Do not automatically transfer ingredient-level properties to the final product.
Who is responsible for the final claim wording?
The EU Responsible Person must ensure the wording meets the common criteria and matches the proof in the PIF. The brand, agency and manufacturer should provide controlled inputs.
Are “natural” or “free-from” claims always allowed?
No blanket answer applies. Review truthfulness, evidence, fairness and the impression created for the intended market. Consult the Commission’s guidance and qualified advice for borderline cases.
Official sources
Regulation (EC) No 1223/2009, Articles 11 and 20; Commission Regulation (EU) No 655/2013; European Commission cosmetics legislation and claims guidance.
Manufacturer support: MOOYAM provides cosmetic OEM/ODM manufacturing and technical documentation support for international beauty brands. We can help assemble product facts and agreed test records for a brand’s EU claim review; marketing approval remains with the appropriate Responsible Person and qualified reviewers.
Regulatory requirements may change. Brands should verify current requirements with the relevant regulatory authority or a qualified compliance professional before placing cosmetic products on the market.