Cosmetic Claims and Certifications

How do you establish your brand’s values in a busy marketplace?  One way is to get accredited to an ethical standard that will give you the seal of approval to put on your pack.

Which scheme is right for you? Well this blog is the ideal place to start as it provides an overview of the key standards and the claims associated to them.

With our knowledge and experience of these standards we have launched an advisory service to guide you through the process of selecting the most appropriate standard, providing an overview of the application processes as well as what is needed to comply to with the audit processes associated with these standards, which is something you will undergo on an annual basis.

If you would like to discuss this further please get in touch with us.

Common claims 

ISO 9001 – Quality Management

The requirements of ISO 9001 are applicable to any organisation, regardless of industry or the products or services they provide. It is a standard used to demonstrate that an organisation’s processes are appropriate and effective at producing or delivering the products they make or services they deliver. This is a position we would ideally wish for you to be in before you apply for any of the following standards of interest within the cosmetic industry.

ISO 14001 – Environmental Management

This standard allows you to demonstrate a commitment to reducing your impact on the environment and is available to any business of any size or sector. It is focused on helping you set up an Environmental Management System (EMS) to reduce waste and improve resource efficiency. 

The requirements of the standard are grouped together over four key areas:

  • Identifying the processes needed to run a successful EMS
  • Identifying areas for you or your management team to focus on
  • Examination of how your resources (staff, facilities etc) are best utilised
  • Analysis to determine if your EMS is working as expected

The cost to apply varies depending on the size and annual turnover of your business. 

Not Tested on Animals/ Cruelty-Free 

The testing of cosmetic products and ingredients on animals has been banned in the UK and EU since 2016, currently making it illegal to have this claim on cosmetic packaging. 

That said, the use of this claim is still widely visible within the industry and so it is understandable if you wish to use this claim in order to compete for the attention of compassionate and animal loving consumers.

One way around the regulation is to seek accreditation to an ethical standard for animal welfare, so that you can claim accreditation to an approved standard.  This is both legal and adds some credibility.

Some accreditation schemes have a strong position in this area. An example being the Leaping Bunny Programme, which is mostly recognised in the UK.  PETA runs a similar scheme, and this is the best known one in the US.

Organic and Natural 

Unless you are making your products yourself, it is important to note that both organic and non organic stock (this can be applicable to the same ingredient) is used by manufacturers. It is therefore very important to specify the organic materials within any formulation you provide to a supplier or manufacturer. 

In terms of visualising this claim, an accreditation with a strong position in this area is COSMOS

(Note, COSMOS is being phased in to replace the Soil Association’s organic accreditation and the ECOCERT accreditation. Both logos will still be appearing on cosmetic and personal care products but it won’t be available to new brands.)

Vegan and Vegetarian

This is an increasingly used claim in response to a growing consumer demand for non-animal products. To make this claim it is vital that you check that vegan versions of raw materials are used by your manufacturer and that you keep a record of those materials which you can refer to if ever challenged by vegan customers or regulators.

To provide an example, glycerin exists as both a plant derived ingredient, from various vegetable oils, and an animal derived ingredient from beef tallow. The latter has not been commonly used for about 20 years but it is still important to specify. 

An accreditation scheme with a strong position in this area is The Vegan Society

Carbon Neutral

This global standard will allow you to demonstrate action to reduce your carbon footprint.   

There are 5 steps to achieving the accreditation:

  1. Define what is covered in your footprint Eg. Is it your whole company or a particular product or service you wish to make carbon neutral
  2. Accurately calculate your footprint
  3. Set goals to reduce your footprint and offset remaining emissions
  4. Deliver your emission reduction projects. The standard provides support to identify and deliver your project and the type of renewable energy that works best for you
  5. Communicate your climate action to your customers and stakeholders

Ethically Sourced 

To reiterate that already said above, it is important to trace the source of the raw materials used in your products to be sure they are ethically sourced. Simply making the claim will not suffice if you are unaware of where each of your ingredients come from, particularly if they are being purchased for you by a supplier. It is vital that you check with them, particularly after having changed to a new supplier. 

An accreditation in this space is the Fairtrade Foundation

Free From GMOs

You can see a pattern forming here in that we again advise that you check the source and manufacturing process/conditions of your ingredients. An example of an accreditation scheme in this area is A Greener World

Free From Allergens

We have an account with Allergy Certified so can submit an application on your behalf if you are wanting to use the allergy certified claim on your cosmetic product. This is based on an assessment of every raw material within a product, looking at it’s composition to ensure it is free from allergens.

RSPO (Sustainably Sourced Palm Oil)

If you use, or wish to use, palm oil from certified suppliers in your products you may wish to investigate this accreditation.

Gluten Free

Most cosmetics can safely be used as if gluten free. This applies in most cases on account of the removal of gluten as part of the cosmetic manufacturing process but most importantly due it’s safe use on the skin on account of its inability to pass through the skin’s barrier, only entering the body through the mouth.  

That said, if you are catering to the gluten free market an accreditation scheme in this space is Coeliac UK

‘Clean’ Beauty/ Free From Toxins

This is a claim we usually advise against.  Any cosmetic product on the market will be non-toxic. It would not be ethical or legal to put a toxic product on the market, and it certainly would not be profitable. This includes ingredients that have negative images, such as parabens, sulfates, silicones, alcohol and fragrance.  


Kosher’ is a term used to describe a product that complies with the strict dietary standards of traditional Jewish law.

 ‘Halal cosmetics‘ refers to beauty products that have been manufactured and composed of ingredients that are permissible under Islamic Shariah (law) and protected from the possibility of cross-contamination by non-halal materials.

Reading these definitions it is clear that the need to check the materials used by your manufacturer is vital if you want to make these claims. In addition, accreditations with SGS or Halal Certification Europe might be of interest. 

Hopefully going through these claims has demonstrated your role in ensuring that the right materials are used in your products and that such record-keeping will allow you to demonstrate compliance with your claims. This is a type of self-auditing process we recommend you undertake on a regular basis and is a process we can guide you through upon consultation. 

Please get in touch with us to find out more.

Charlotte Tilbury Get Their Collar Felt

It isn’t easy to keep track of your influencers if you are a big brand like Charlotte Tilbury

Paying influencers to promote your stuff on Instagram, Youtube and other social media is advertising. You have to identify it as such and follow the guidance of the ASA. Charlotte Tilbury Beauty are no doubt well aware of this, but even so have got caught not doing it by the book.

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Can You Use Testimonials As Evidence of Efficacy?

Can you use a testimonial to justify a skin hydration claim for a collagen health supplement?

Do you need to prove your supplement hydrates the skin?

Proper trials to prove your claims cost a lot of money. And there’s no guarantee a trial is going to give you the results you want. So the obvious question is can you get away with just launching the product and using the feedback you get from your customers as evidence of your claims?

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The self tan shake up

Self tan products are changing and consumers are going to notice.
You should too.

DHA self tan shake up
New EU self tan regulations reduce the maximum level of DHA usage to 10%

If you sell a self tanning product you will likely be aware of a looming change to the limit of dihydroxyacetone (DHA) in self tanning products to a maximum of 10% which is going to affect a large number of products on the market. The new regulation also sets a new DHA limit for non-oxidative hair-dye products to 6.5%, which while not unimportant will probably affect far fewer skus.

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Is Mouthwash Leave On Or Rinse Off?

Mouthwash leave on

The EU cosmetic regulations make clear that mouthwashes are one of the categories of cosmetic product. They are explicitly listed as an example, and obviously fit the definition. Elsewhere in the regulations, there is a distinction made between products that are left on, and those that are rinsed off. This is important because it affects the way that allergens need to be listed – there is a lower cut off value for allergens to be listed on leave on products. Continue reading “Is Mouthwash Leave On Or Rinse Off?”

Penetrometry- An Underrated Technique

Penetrometry isn’t widely used or even known about by cosmetic formulators. But it has its uses.

A penetrometry by Ele

There’s a trick journalists use to get you to read their stuff. They set up a false but interesting premise. ‘The Beatles’ songs are underrated’ for example. In fact nobody underrates the Fab Four’s music, but the article can now be framed as an argument rather than an account. This gives it a bit of energy it wouldn’t otherwise have had. So I had better confess now, penetrometry isn’t so much underrated as hardly heard of. You can’t assume it is something a cosmetic formulator will know about.

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Ambergris is highly sought after and very rare and expensive. But what is it?

A sperm whale full of ambergris has been washed up on the beach in Holland.  The quantity is 83Kg, and will keep perfumers who use it as a fixative going for years. The origin of ambergris was unknown for many years.  It was found from time to time on beaches. Its scarcity made it enormously valuable.

Once industrial scale whaling got underway its origin in the digestive system of whales became obvious. It also led to the pursuit of sperm whales, with disastrous consequences for their numbers.  To combat this trade in ambergris is banned in many countries.

The details can be found here.

How To Handle A Scare Story

How to prepare for when your makeup product falls foul of scaremongers.

This week there has been a scare story about PFAs in makeup. (PFA is a recent acronym for perfluorocarbons.) Its origin is persistent mischief mongers the EWG who keep up a continual stream of misinformation about all manner of consumer products including cosmetics, most of which are easily linked to their fund raising activities. In this case the story was that there are dangerous components in colour cosmetics and many cosmetic companies don’t even know they are there. The monetisation comes from the EWG’s accreditation standard – where companies pay them for approval.

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Salicylic Acid – CMR2 status doesn’t affect its usefulness

Salicylic acid derived from willow trees
Salicylic Acid was first identified in willow bark

Salicylic acid has been used in cosmetics and dermatology for many years, more or less as soon as it was available in the 1840s. In fact it was used before that unknowingly as willow bark, from which it was first isolated, was already in use as a folk medicine before that. This use is referred to by Roman writers. But it has recently come under a bit of a cloud following its classification by the European Chemicals Agency as a Category 2 CMR.

Continue reading “Salicylic Acid – CMR2 status doesn’t affect its usefulness”

Hand Saniters

Hand Sanitisers

Hand sanitisers are a popular product line at all times, given that people are constantly exposed to potential contamination. But naturally there is a lot of interest in them when there is a big public health issue in the news. I am writing this on the 3rd of March 2020 where the UK Prime Minister has just been on television in the morning talking about the Corona Virus and specifically mentioning hand sanitisers. By this afternoon the price of the main alcohols used in hand sanitisers has tripled. Polymers often used in them also seem to be in short supply. Needless to say shops that haven’t already sold out are not likely to have stock for much longer. The shop above which my office is located sold its last one half an hour ago.