Consumer-facing product advertising claims and brand communications are highly regulated in the cosmetics industry. These rules come from both product-specific regulations and general advertising laws in the UK.
When a product promotes its benefits - whether on packaging, in a TV ad, via an influencer, or other means - those statements are called “claims.” Claims describe what a product does or contains, and they must be fair, honest, and backed by evidence.
But a claim isn’t just a written statement. It can include:
- Text, brand names, and trademarks
- Images, symbols, colours, and logos
- Implied messages such as benefits suggested by the inclusion of certain ingredients or implied by influencers
- User reviews highlighted by the brand
If a message can be interpreted as a claim - explicitly or implicitly - it must follow the rules.
The Common Criteria for Cosmetic Claims
In the UK, cosmetic claims must comply with the UK Cosmetics Regulation (UKCR) and the Common Criteria for Cosmetic Claims, a framework also used across the EU. These guidelines ensure claims meet high standards based on six key principles:
1. Legal Compliance
All cosmetic products must comply with the law. Claims can’t imply that a product is superior simply because it complies with the law; for example, claiming that a product is ‘free from lead’ or ‘safety assessed’ because this is mandatory for all cosmetics in the UK.
2. Truthfulness
Claims must be factually correct. If a product says it contains an ingredient, that ingredient must be present.
3. Evidential Support
Every claim must be backed by reliable evidence.
4. Honesty
Claims must reflect what the product can genuinely achieve without exaggerating the results.
5. Fairness
Claims must not misrepresent or unfairly criticise competitors. Comparisons should be respectful and accurate.
6. Informed Decision-Making
Information should be clear and easy to understand, helping consumers make confident choices.
If a claim doesn’t meet all six criteria, it is not allowed.
Who Oversees These Rules?
Several bodies are responsible for ensuring cosmetic claims are compliant:
- Office for Product Safety and Standards (OPSS) and Trading Standards enforce the UK Cosmetics Regulation.
- Advertising Standards Authority (ASA) regulates advertising across media and provides guidance on acceptable claims.
- Competition and Markets Authority (CMA) oversee broader consumer protection laws.
- Clearcast pre-approves TV adverts to ensure they meet ASA codes before airing.
There is no official list of approved claims or required evidence. It is up to each company to ensure their claims are fully supported and compliant.
How Are Advertising Claims Developed?
Cosmetics companies take these rules seriously and build compliance into the product development lifecycle. It often starts with ingredient selection, but for more complex claims like anti-aging benefits, companies may use:
- Instrumental testing to measure physical changes in the skin
- Consumer trials to gather feedback on real-world use
These methods help ensure that claims are accurate, truthful, and not misleading.
What to Do If You Spot a Misleading Claim
If you think an advert is misleading, whether in print, on social media or on TV, you can report it to the Advertising Standards Authority (ASA).
If the misleading claim appears on the product itself, report it to Trading Standards, who investigate unfair trading and illegal business practices. While Trading Standards can take enforcement action, they do not handle customer service issues like refunds.
