Claim Management in Cosmetics: What Can You Actually Write on the Label?

Contents

What Is a Claim? What Are You Promising on the Label?
Types of Claims and the Burden of Proof
The "Long-Lasting" Trap: It's Volatility, Not Concentration, That Counts
Linking Claims to Documentation: A Step-by-Step Process
Common Mistakes and Frequently Asked Questions
Related Articles

What Is a Claim? What Are You Promising on the Label?

Every sentence you put on a label is a promise. "Natural", "hypoallergenic", "lasts 24 hours" — these are not decorative words; they are legal obligations. A consumer reads that promise and buys; an inspector reads it and demands evidence. Claim management means being able to stand behind everything you say.

A cosmetic claim is any statement about a product's characteristics, effects or ingredients. It can be verbal or visual; even a green leaf suggesting "pure nature" constitutes a claim. Under European regulation (Regulation 655/2013), claims must satisfy six common criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. Turkish legislation is aligned with this same framework.

The rule is simple: don't say what you cannot write; document what you intend to say. The burden of proof lies with you, not the inspector.

Types of Claims and the Burden of Proof

Not every claim requires the same level of evidence. Some statements can be closed with a simple document; others demand laboratory work, testing, and even clinical data. First classify your claim, then determine what evidence is required.

Claim	Meaning	Evidence Required	Risk
Natural / Natural-origin	A defined proportion of ingredients derived from natural sources	ISO 16128 calculation, raw material natural indices, supplier declarations	High — "natural" alone has no clear legal definition
Organic	Sourced from certified organic agriculture	Valid COSMOS/Ecocert or equivalent certification	Very high — cannot be used without certification
Hypoallergenic	Risk of allergic reaction has been reduced	Elimination of known allergens + dermatological data	Very high — does not mean "allergy-free"
Long-lasting / 24-hour	Promise of scent/effect duration	Standardised performance/sensory test, panel data	High — dependent on volatility, easily disproved
Dermatologically tested	Skin compatibility has been tested	Patch test / clinical supervision report	Medium — test result does not guarantee performance
Vegan / Contains no animal ingredients	No animal-derived raw materials	Origin declarations for all raw materials	Medium — a single raw material can invalidate it
... free (free-from)	A specific substance is absent	Formula record + analysis	Variable — disparaging a safe ingredient may be prohibited

Tip: Free-from claims such as "paraben-free" or "alcohol-free" violate the fairness criterion if they unfairly denigrate a safe ingredient. Rather than negation, highlight the genuine advantages of your own formula.

The "Long-Lasting" Trap: It's Volatility, Not Concentration, That Counts

This is the most common mistake manufacturers make: "I've increased my fragrance oil concentration, so I can claim long-lasting." Wrong. Longevity and sillage (the scent's projection trail) do not depend on concentration alone. The true determining factor is the volatility (evaporation rate) of the raw materials in the formula.

A 25% extrait heavy in citrus top notes may fade within a few hours due to its highly volatile character. Conversely, a 10% product built around amber, oud and musk base notes can last considerably longer. In other words, there is no fixed equation such as "EDP always lasts longer"; concentration alone does not determine performance — the structure of the formula and its volatility profile do.

Type	Typical fragrance oil concentration (approx.)	Performance
EDC / Cologne	~3–8%	Formula-dependent
EDT	~8–12%	Formula-dependent
EDP	~12–20%	Formula-dependent
Extrait / Parfum	~20–30%	Formula-dependent

If you intend to write "lasts 24 hours" on the label, you must substantiate this with a standardised performance/sensory test conducted under controlled conditions. Avoid absolute hour-based promises; defensible phrases such as "base notes that accompany you throughout the day" are both more honest and carry far less legal risk.

Linking Claims to Documentation: A Step-by-Step Process

Evidence must be ready in the file before the product reaches market. You need a paper trail built from the start, not evidence gathered after the fact. Here is the sequence for building a defensible claim.

Define the claim precisely
Exactly what are you saying? "Natural" or "92% natural-origin"? A vague statement leads to vague evidence. Settle on the exact wording first.
Identify the type of proof required
What does this claim require: a raw material declaration, an ISO 16128 calculation, a dermatological test, or a sensory panel? Know the type, then plan your source.
Collect and retain the evidence
Supplier certificates, analysis reports, test results — all of these must be held within the PIF (Product Information File).
Align with the CPSR
Your claim must not contradict the safety data in the CPSR (Cosmetic Safety Assessment Report). If you say "suitable for sensitive skin", the assessment must support that.
Validate through stability testing
Performance claims such as "long-lasting" or "colour-fast" must be consistent with stability and challenge test data. Can you maintain your promise throughout the product's shelf life?
Audit the visuals too
Leaves, droplets, and "%100 pure" connotations are also claims. Cleaning up the text while the visuals convey the same promise creates an evidential gap.

FIGURE 01Process Strip — Step by Step

Practical rule: mentally append "Because…" to any claim. If you cannot complete the sentence with a document, remove that claim from the label.

Common Mistakes and Frequently Asked Questions

Most penalties arise not from bad intent but from carelessness. The following mistakes are the most frequently encountered in practice — and all three are easily preventable.

First, assuming that "hypoallergenic = causes no allergies". This claim means only that the risk has been "reduced" through elimination of known allergens and dermatological data — it is not a zero-risk guarantee. Second, making an absolute safety claim based on natural/synthetic status: saying "safe because it's natural" is incorrect — safety always depends on the level of use. Some natural essential oils contain high levels of allergens. Third, reducing IFRA compliance to an overall concentration figure: the statement "my fragrance oil is at 15%, so it's IFRA-compliant" is meaningless.

IFRA limits are set not against the total fragrance oil concentration, but against individual substances/allergens within the fragrance and the product category (leave-on/rinse-off). Request the IFRA compliance statement from your supplier, read it in the context of your product category, and verify it against your formula.

What percentage of the formula must be natural in order to claim "natural"?

There is no single legal percentage threshold; the definition of "natural" is not clear-cut in its own right. The defensible approach is to calculate the ISO 16128 natural index and make the claim concrete: a quantified, verifiable statement such as "92% natural-origin" is far safer than a bare "natural". Keep the calculation and supplier declarations within the PIF.

Will writing "lasts 24 hours" cause problems at inspection?

Yes, if you have no supporting evidence. This performance claim can only be substantiated with a standardised performance/sensory panel test conducted under controlled conditions — and because longevity depends on the volatility profile of your formula, it can be disproved relatively easily. Opt for defensible, measurable language such as "base note felt throughout the day" rather than an absolute hour-based promise.

Does a green leaf illustration on my label also count as a claim?

Yes. Visuals, colours and associations are all statements. A design that creates an impression of "pure nature" violates the honesty and truthfulness criteria if the formulation does not support it. Keep your text and visuals within the same promise framework — both must rest on the same body of evidence.

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99 · COSMETIC REGULATION