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EU guidelines on claims
I am working at a small company and I am working on the artwork for our new product range. (Just as a bit of background I started as a Technician working with a consultant chemist who no longer works with us and I have picked up the admin and technical side).
I am currently really confused about what can and can’t be said under the guidelines. I have read the guidelines and I have tried looking a competitors products that I have worked on in the past- some claims are made and some aren’t hence my confusion.The company I work for the main emphasis for the products is the fragrance but they are keen on the ‘soft or fuzzy’ marketing claims on the romance for the products packaging e.g. contains aloe vera to soften and hydrate the skin and Shea butter and rose hip to deeply moisturise the skin or the refreshing extract of lime etc. A colleague who has now left the company was working on this and now i am trying to pick up where she left off. The products are body lotion, hand cream and body wash. The products contain extracts, natural oils as well as aloe vera leaf juice rather than any proper actives.Please could someone offer some advise? My instinct say no not to include the fuzzy claims just incase but the marketing department want something other than just the fragrances to draw peoples attention. -
4 Replies
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Are you in the US or the EU? (The regs are different)
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Article 20 of the Cosmetic Product Regulations 1223/2009 gives the legal standpoint:
“In the labelling, making available on the market, and advertising of cosmetic products, text, names, trade marks, and figurative or other signs shall not be used to imply that these products have characteristics or functions that they do not have.”
an example of a statement you could get away with is “contains [ingredient A], which helps to [do X, Y or Z]” since you’re not claiming that the product actually does X, Y, or Z; rather, you’re stating that ingredient A is included with the intention to do X, Y or Z, without any comment on how effective it is
also, I’d take competitors’ claims with a very big pinch of salt; the fact that the products are on the market doesn’t necessarily mean that enough evidence exists to back up the claims if the brand owner is challenged to prove them
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Thanks for your help!
I’m in the UK. Luckily I don’t have to make the products compliant outside of the EU because I would be having a serious melt down.The aloe in the formulation is a concentrate at a good level so hopefully it will help the formulation. -
I find this guide to be a good reference when creating claims.
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