The Six Common Criteria Your EU Cosmetic Claims Must Meet

"Free from parabens" sounds harmless enough to write on a bottle. Under EU rules, it's a claim, and claims get judged, not just tolerated. Regulation (EC) No 655/2013 sets out six common criteria that every cosmetic claim in the EU has to satisfy, and a surprising number of small brands write claims without ever checking them against this list.

This isn't a separate approval process on top of your CPNP notification. It's a standard your marketing language is expected to meet on its own, and it's enforceable independent of whether your formula itself is compliant.

The six criteria, in plain terms

Legal compliance. A claim can't imply your product does something illegal or that a competitor's compliant product is somehow non-compliant. You can't frame your product's legal status as special if every product on the shelf is meeting the same baseline requirement.

Truthfulness. If you claim an ingredient is present, it needs to actually be present, at a level that matches the claim. Vague truthfulness feels obvious until you look at how many labels claim an active ingredient at a homeopathic trace amount.

Evidential support. This is the one that trips up small brands hardest. Any claim, especially efficacy claims like "reduces fine lines" or "clinically proven," needs evidence behind it, proportionate to the claim's strength. A stronger claim needs stronger substantiation. You cannot lean on "it worked for me" as your evidence file.

Honesty. The claim can't create a false impression of the product's benefits or characteristics, even if every individual fact stated is technically true. Presenting one true fact in a way designed to imply something bigger and untrue still fails honesty.

Fairness. Claims can't denigrate competitors or the ingredients other products use. "Unlike other harsh soaps" is doing marketing work by implying every other soap is harsh, which is the kind of comparative jab this criterion is built to catch.

Informed decision-making. The claim has to give the consumer something genuinely useful for making a purchase decision, not vague feel-good language that sounds meaningful but tells the consumer nothing concrete.

Where "natural" and "free-from" claims usually fail

These two claim families get the most scrutiny in practice, and it's worth knowing why.

"Natural" has no single, universally enforced legal definition across every claim context, which means a brand using it needs its own clear, defensible standard for what qualifies, and needs to be able to show that standard on request. Slapping "natural" on a product because most of the ingredients are plant-derived, while one synthetic preservative sits quietly in the formula, is exactly the kind of claim that fails the honesty and evidential support criteria together.

"Free-from" claims run into the fairness and honesty criteria most often. Claiming "free from sulfates" on a product in a category where sulfates were never commonly used to begin with can create a false impression that this is a meaningful differentiator, when it's actually just describing the category norm. That's a real enforcement pattern regulators have flagged, not a hypothetical.

What this means for your Product Information File

Under Regulation (EC) No 1223/2009, you're already keeping a Product Information File and a Cosmetic Product Safety Report signed by a safety assessor. Claims substantiation should live in that same file, or be easy to produce alongside it. If a market surveillance authority asks you to justify a claim, "it just felt true" is not a file. Lab results, ingredient certificates, supplier documentation, and a clear definition of your own claim standard are.

A practical checklist before you print a label

1. Write down, in one sentence, what evidence supports each claim you're making.
2. Check the claim against all six criteria individually, not just the ones that feel obviously relevant.
3. Ask whether the claim would still sound accurate if a competitor's nearly identical product used the exact same words.
4. Keep whatever substantiation you have filed alongside your PIF, dated, so it's there before anyone asks for it.

The claims side of EU compliance sits a bit outside what Cosmetic Comply currently automates, since the tool's core strength today is ingredient mapping, screening, and notification, with Canada live and the EU on the way. But the same discipline that makes a good ingredient filing, matching every statement to something you can actually prove, is exactly what these six criteria are asking for in your marketing copy too.