Why you need to substantiate your cosmetic claims
Often, the cosmetic industry is accused of lying to consumers. About half of the time the people making the accusations are wrong. No, the cosmetic industry is not trying to poison people with carcinogens. But cosmetic companies definitely stretch the truth with some of the claims they make about products. Big companies like P&G, L’Oreal and Unilever have all been found to have produced misleading advertising. Little companies, who are not scrutinized nearly as much, often produce much more blatant misleading statements. 
Cosmetic Claims
When it comes down to it all the things you say about your products are your claims. These are just statements about what your product is and what it will do. So, on a shampoo bottle you’ll see the word “Shampoo”. This is a claim. When you have a bottle of lotion you might see the statement “moisturizes skin.” This is another claim. Technically, for every statement you have on your container (or in advertising) you need to be able to substantiate the claim. The type of substantiation you need depends primarily on the type and strength of the claim you are making. Remember “extraordinary claims require extraordinary proof.”
Some claims are naturally misleading and we’ve previously covered the top 10 misleading cosmetic claims.
Substantiating cosmetic claims
This story about PZ Cussons’ attempt to substantiate their claims was interesting and instructive. Someone complained to the ASA (the advertising standards group in the EU) about some claims that PZ Cussons was making about their shampoo. In their advertising they claimed a variety of things such as…
- 7927 tingling mint leaves
- 40 real zingly limes
- 10 zesty lemons
The company was challenged to support those claims. And they did!
How do you substantiate claims like that?
They did it by providing detailed calculations which supported the exact numbers that they were claiming. The ASA accepted their data and backed off allowing PZ Cussons to continue making the claims. If they didn’t have the proper data and hadn’t thought of it before selling their product, no doubt the result of this action would have been different.
So, when you are making claims for your cosmetic product, just remember that you need to be able to support EVERY claim that you make. It can be a logical rational or (better) some lab study which demonstrates the validity of your statements. Either way, you need to have this done prior to launching your product. You don’t want to get caught with products that have unsubstantiated claims on the market. It could kill your entire company.
