Product Claims, Organic Cosmetics and Animal Testing.

Many cosmetic products promise to reduce wrinkles, improve the overall appearance of the skin, lighten & brighten the skin, prevent blemish formations…. The list is endless and with continues research and development scientists are really trying to push the boundaries of the cosmetic industry so much so that some product claims almost make the cosmetic product sound like a ‘medical’ product!!??? With strict laws on the cosmetic industry are scientists trying to possibly achieve the unachievable? Or is it all just very clever marketing to give the consumer the impression and belief of a forever youthful appearance?

Other non-scientific claims found on product packs refer to ‘free from’, natural/organic and against animal testing claims which have all developed through market trends, consumer demands and desires.

As the subject on claims can be quite complex… I have sectioned it off to ‘against animal testing’ claims, ‘Free From & Organic / Natural’ claims and lastly ‘High-Tech -scientific’ claims.

Animal Testing Claims:

I am shocked at the number of people I come across who don’t know the truth about animal testing and still think that this is common practise amongst the industry in Europe.

The Cosmetic Directive enforced (in Europe) a complete ban on animal testing of finished cosmetic products in 2004. The European cosmetics industry had already moved away from animal testing before the ban took pace. Many companies in the UK stopped using animal testing methods on finished cosmetic products since 1997, and cosmetic ingredients since 1998.

(Just to quickly brief you in the law behind the cosmetic industry – The Cosmetic Directive (European Directive and Regulations ) lays down rules on the composition, labelling and packaging of cosmetic products (The Cosmetic Directive is almost like the bible for the industry) It is continuously changing with regulations becoming stricter, but every cosmetic company must comply to in order to sell or market their products in Europe.)

Initially, the Cosmetic Directive stated that a particular animal testing method for cosmetic ingredients would be banned once an alternative way became available. This later changed and as of 2009 the Cosmetic Directive issued a ban on animal testing for cosmetic ingredients in the EU, whether or not an alternative method was available.

Large research centres and organisation bodies have hugely invested in developing alternative methods and the chance of having them validated and accepted so that they could be used to replace animal tests in the safety assessment for cosmetic products as required by the EU Cosmetics Directive.

Many brands choose to label the product with a claim such as “Not Tested on Animals” for marketing purposes; however just because a brand does not claim ‘Not tested on animals’  does not mean that a product or the ingredients used in the product have been tested on animals.

Free From & Natural/Organic Claims:

The Free From claims & Natural / Organic product trends developed purely because of consumer demand. Cosmetic consumers became extremely conscious about what products and ingredients they are putting on their skin and companies found this as a gap in the market- before you knew it new brands where being launched as Natural, Organic and Free form: parabens, SLES, glycols etc.

Organizations and certification bodies such as Ecocert & Soil Association were formed and developed standards for natural or organic formulations; however what many people do not know is that these standards or guidelines and the terms ‘natural’ and ‘organic’ are not specifically regulated under the Cosmetic Directive.

The most natural & Organic products found on the market would have been certified by either Ecocert or the Soil Association. Other brands will claim a natural percentage on pack ie: 95% natural but will not go through the hassle of certifying the finished product, however there is a number of brands who don’t claim a percentage but are still truly natural.

On the other hand many brands use very clever marketing to make the consumers believe the products are the most natural ones available without the brand actually stating that the finished product is natural!!! Companies would develop a brand which would appear to be natural using a natural story, natural inspired images and colors for artwork and packaging and actually only use a few natural ingredients purely for claims. No-where on pack would they mention a natural percentage or that the finished product is natural. What they would do is – Formulate a synthetic base, use a few natural oils (ex: jojoba oil) and one or two natural actives (ex: blueberry extract) and develop a natural story around those few natural ingredients making the consumer believe the cosmetic product is natural.

Again due to a trend you will see other brands claim Free From, Parabens, SLES, Silicones, gylcols, synthetic colors & fragrances… etc… any ingredient which the media seems to what to pick at a brand will add it to their ‘free from’ list. Not because the ingredient is ‘harmful’ but because if the media says it is then many consumers will believe this and so a new trend is born. Although these brands are more concerned about marketing their products as ‘we don’t use these ingredients’ and consumers will think the products ‘must be good for them’ however the brand does not seem to mention what is in the formulation! The brand marketing for these products is based on what is not in the formulation.

So next time you pick-up a natural inspired product, have a good look at the ingredient list.

High-Tech ‘Scientific’ Claims:

The definition of a cosmetic product stated by the Cosmetic Directive is as follows:

‘A “cosmetic product” shall mean any substance or preparation intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance and/or correcting body odours and/or protecting them or keeping them in good condition.’

The definition of a medical product outlines the below:

A medicine is intended to Treat (cures) & Prevent Diseases, and Restore, correct & modify physiological functions.

But with many creams and serums using the words ‘prevent’, ‘restore’ & ‘correct’ to claim the functionality of a product, how could they possibly do this when it would seem to fall out of the definition of what a cosmetic by law is allowed to do.?

Example claims, which you might find on products – and what they are actually saying.

‘targets the stem cells of the skin’ OR targets the deeper layers of the skin OR ‘works with the skin cells to rejuvenate and improve the overall appearance of’ = Clever Marketing!!!!

Makes you believe that the product will work deep inside the skin and improve the cells!! Right???

Mention of stems cells or any other cells would refer to cells of the epidermis (which is the very top layer of skin- the layer of skin which we can see) – and no other layer of the skin structure.

The dermis which is the second (middle) layer in the skin structure (this is the layer the claims make you think of!! but has not officially been stated) It is in the Dermis where ageing begins, however once you mention the Dermis in any product claim, the product would no longer be seen as a cosmetic product, but would fall under the regulations of a medical product.

I am not saying that the above claim is false and that the product doesn’t work; however the cosmetic product will only have an effect and improve the appearance of the Epidermis- the top layer of your skin and not the Dermis- the layer in which ageing begins.

Formula helps prevent future damage of the skin: When you put the word ‘Helps’ in front of a claim- it positions the product as a cosmetic because you are not 100% guaranteeing that the product will 100% prevent future damage of the skin.

I bet only now you will begin to notice how many products use the word ‘helps’ in their claims!!

Formula acts at all levels of the skin to help restore the skin’s natural hydration mechanisms to break this claim down for you ‘acts at all levels of the skin’– doesn’t mean anything! This is just good marketing as the claim does not refer to what the ‘Act’ is.

Helps restore the skin’s natural hydration mechanism’ again using the word ‘helps’ in order to make the claim lighter and fall under cosmetic regulations.

The rules surrounding the cosmetic products are very strict and it is a legal requirement that all claims made on-pack are substantiated. So the above claims need to be supported with evidence to show and allow for that claim to be put on pack.

There are different ways of doing this.

1)      Support the claim with robust clinical testing carried out on the finished product. This is the best and most effective way and does put value on your product. Products which have been clinically test for anti-wrinkles claims, whitening claims etc…would mention this on their packaging or website. However this type of testing is expensive & brands on the market which have had their products tested in order to state an anti-wrinkle claim are expensive.

2)      The cheaper option with no added cost to product development is using Clinical testing results which have been carried out by the manufacturers of the actives which a brand would like to use. So if a brand wanted to use an algae extract from a known manufacturer they are able to use the data which that manufacturer compiled on the active.

There are many variables to consider when doing this:

–          Your formulation is not the same as the formulation which the manufacturer used to test the algae extract.

–          Your formulation could consist of about 20-30 ingredients in total and out of these about 4-5 are actives. Who is to say that the other ingredients in the product will/won’t have an effect on the efficacy of the algae extract? And until the finished product is tested as above this won’t be known.


The term “Cosmeceutical” is used by many ‘high-tech’ scientific brands- However the word “cosmeceutical” is a marketing term used within the industry and amongst the media to describe cosmetic products which have actions and effects that go further than the purely ‘decorative’ cosmetics. These would be known as ‘performance’ cosmetics. Because the term ’cosmeceutical’ was developed by a group of marketers, it isn’t an official, legal category of product.

A product can only be either a cosmetic or a medicine and cannot be both at the same time. There are very clear legal definitions for a cosmetic and for a medicine – and that’s it!!! There is no ‘third’ category and there is no in between!!

So if you are wondering about the efficacy of a product you want to try there is nothing wrong with asking a brand for some more information. If the brand has the data, and has nothing to hide, then they will be open about it and willing to discuss it with you.

For those who finally reached the end of this hideously long post and didn’t give up mid way are probably dying for a cuppa tea, but I do hope the above is helpful with understanding the industry in more detail.


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