Common criteria for the justification of claims that may be used for cosmetic products
- compliance of standards,
- evidential support,
- informed decisions.
DECLARATIONS OR CLAIMS
Declarations related to cosmetic products include a range of information, indications and adjectivizations which appear on the label or on product advertising material. These indications are mainly necessary to define a cosmetic product and inform the end-users about the features, the qualities and the effects attributed to the cosmetic.
The main aim of adopting common criteria is to ensure a high level of protection for end-users. Especially with regard to misleading claims on cosmetic products. As these products have a relevant role in the end-users’ life, it is important to guarantee that the information provided with these claims are useful, understandable and reliable. Moreover, they must enable them to make informed decisions and choose the products best suited to their needs and expectations.
It is fundamental that the Responsible Person is able to apply this standard to his own cosmetic products following the six criteria indicated on the Regulation. Otherwise it will be essential to rely on a professionial who will consider on a case-by-case basis the appropriate description of the claim to be made on the label.
A fairly explanatory example of the interpretative complexity of the regulation is that of claiming the absence of certain ingredients permitted by the regulation as absent claims and/or as justifications for other claims. In these cases, the following misinterpretation would occur: on one hand, a permitted (and therefore safe) ingredient is implicitly attributed a non-conformity character; on the other hand, a cosmetic characteristic is validated without supporting it with appropriate data.
It can therefore be deduced how important a correct interpretation of EU regulations and the characteristics of the cosmetic is in order to be able to declare on the label:
- a suitable claim,
- a claim accompanied by suitable and specific declarations,
- a suitable language which considers the target population for which the product is intended,
- – any claims at the border that may soon be considered non-compliant, leading to subsequent label changes.
CLAIMS VERIFICATION TESTS
Furthermore, it is important to point out that the world of tests for the demonstration of a claim is really vast and diversified, not only in terms of type, but also in terms of the method chosen to carry out the same test. From what has been said so far, it is evident how important and complex it is to choose the most suitable test and, on the basis of the results obtained, to declare the claim in question correctly.
On the other hand, it is the national competent authorities task to verify that the declarations on packaging meet the Community standard.
PIF ITALIA, on this particular and delicate aspects, offers a specific and focused analysis and verification service, in accordance with current legislation on claims and labelling, the validity and sustainability of marketing communication, advertising claims used for cosmetic products as well as a possible proposal for alternative claims.
The following documents are available for further information:
Guidelines to Commission Regulation (EU) No 655/2013 laying down common criteria for the justification of claims used in relation to cosmetic products.
COMMISSION REGULATION (EU) No 655/2013 of 10 July 2013
Laying down common criteria for the justification of claims used in relation to cosmetic products.