CLAIMS AND MARKETING TEXTS FOR COSMETIC PRODUCTS

Claims and marketing texts include written, visual and verbal messages used to present and promote cosmetic products. They communicate the benefits, characteristics and distinctive features of a product and can influence how consumers perceive it and make purchasing decisions. Brand names and cosmetic product names may themselves constitute claims because they can convey a message about the product and must therefore comply with applicable cosmetic regulations.

Claims and marketing texts may appear on:

Product labels: descriptions, directions for use, prominent claims and highlighted ingredients
Packaging: slogans, promotional statements and claims appearing on boxes, bottles or other packaging
Advertising materials: flyers, brochures, social media advertisements, print advertisements, videos and other promotional content
Websites and online sales channels: product pages, online shops, blogs, promotional content, influencer or public-figure endorsements and other digital marketing materials
In the European Union, claims made in relation to cosmetic products must comply with Regulation (EC) No 1223/2009 on cosmetic products and Commission Regulation (EU) No 655/2013, which lays down common criteria for the justification of claims used in relation to cosmetic products.
Under Commission Regulation (EU) No 655/2013, cosmetic claims must comply with six common criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. In addition, Article 20 of Regulation (EC) No 1223/2009 prohibits the use of text, names, trade marks, pictures and figurative or other signs to imply that a cosmetic product has characteristics or functions which it does not have.
Understanding the classification of certain products is important because some products may fall within borderline areas where classification depends on factors such as composition, intended purpose, mode of action and the claims made for the product. A clear distinction must therefore be made between cosmetic products and other regulated product categories, such as:
Medicinal products: Products presented as treating or preventing disease fall under medicinal product legislation and cannot be placed on the market as cosmetic products.
Biocidal products: Products presented with disinfecting, antiviral or antimicrobial claims may fall within the scope of biocidal products, which are subject to separate legislation and authorisation requirements.
Toys: Products intended for children and designed as toys, such as cosmetic play sets, must meet toy safety requirements, while any cosmetic products contained in them must also comply with cosmetic product requirements.
Medical devices: Products intended for a medical purpose whose principal intended action is achieved by physical or mechanical means, such as products for wound closure or scar treatment, must be correctly classified as medical devices.
Correct classification is essential for regulatory compliance and for avoiding claims that are inappropriate for a cosmetic product. Manufacturers and brands should carefully consider the product's intended purpose, composition, mode of action and claims when determining the appropriate regulatory category.

Examples of non-compliant claims:

This product treats acne and removes pigmentation...
The cream repairs damaged skin and stimulates cell regeneration...
This baby cream prevents infections...
This eye serum effectively eliminates dark circles...
This facial serum provides powerful lifting and anti-ageing effects... rejuvenates the skin...
This miracle shampoo stimulates hair growth...

Our Services

If you need professional support with the review or preparation of claims and marketing texts for cosmetic products, we can review your existing content or prepare new content based on the product formulation, product characteristics and available supporting documentation.
Review of Existing Claims and Marketing Texts
  • Review of existing claims and marketing texts for labels, packaging, websites, online shops and other promotional materials.
  • Assessment of whether the claims are appropriate for the specific product and can be supported by the formulation and available documentation.
  • Identification of claims that may be non-compliant or raise regulatory concerns.
  • Suggestions for correcting or reformulating problematic claims.
Preparation of New Claims and Marketing Texts
  • Preparation of claims tailored to the specific product, its formulation, characteristics and available supporting documentation.
  • Preparation of short texts and product descriptions for labels and packaging.
  • Preparation of product descriptions for websites and online shops.
  • Preparation of marketing texts for promotional materials.
  • Guidance on the documentation required to substantiate proposed claims.
Review and Development of Product and Brand Names
  • Regulatory review of proposed product and brand names.
  • Identification of names that may have problematic implications or constitute an inappropriate claim about the product.
  • Development of new name proposals based on the product characteristics and the client's requirements.
  • Development of alternative naming options and regulatory review of the final selected name.
Important
  • The scope of the service depends on the type and amount of content, the complexity of the claims, the characteristics of the product and the documentation available for review.
  • More complex claims may require a more detailed assessment of the product and the documentation used to substantiate them.
  • Where justified by the nature or effect of the cosmetic product, the Product Information File (PIF) must contain proof of the effect claimed for the cosmetic product.
  • The service does not include conducting product efficacy studies or testing.
  • The final scope of the service and price are confirmed before work begins.
If you would like us to review your existing claims or prepare new claims and marketing texts for your cosmetic product, contact us.