A cosmetic claim is not made safe by adding an asterisk. In the EU, claims must be supported by adequate and verifiable evidence and must not imply functions the product does not have. Build the claim file while formula and packaging are still changeable, then keep the published wording aligned across label, website, marketplace and sales material.
Turn marketing language into a testable statement
Separate subjective scent description from an objective product claim. “A luminous floral impression” describes creative character; “lasts 12 hours,” “hypoallergenic” or “clinically proven” makes a proposition that needs a defined population, method and result. Write the exact sentence first, including qualifiers, before choosing evidence.
Match evidence strength to the claim
- Formula and ingredient records can support composition statements.
- Instrumental or laboratory methods may support measurable performance.
- Controlled consumer studies can support perception claims when the sample and questions are suitable.
- Published literature may provide context but does not automatically prove the finished product claim.
The evidence must relate to the marketed product and conditions of use. A supplier presentation for one raw material rarely proves the same effect in the finished fragrance.
Review the six EU common criteria
Commission Regulation (EU) No 655/2013 frames cosmetic claims through legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. Review the overall impression, images and product name as well as the literal sentence. A technically qualified footnote cannot repair a dominant misleading message.
Create a claim register
| Field | What to record |
|---|---|
| Claim ID | Exact approved wording and language |
| Evidence | Report, specification or study version |
| Scope | SKU, market, channel and permitted qualifier |
| Owner | Approver and next review trigger |
Reopen review when something changes
A formula revision, supplier substitution, new translation, redesigned visual or marketplace abbreviation can alter the claim. Archive withdrawn wording and link every active claim to evidence in the product information file. For borderline therapeutic, health or environmental language, obtain qualified market-specific advice before publication.