EU regulatory guide

Natural, clean, hypoallergenic: the claims rules.

Everything written on a cosmetic pack or product page is a regulated claim, from moisturising to dermatologist tested. The EU wrote the rulebook in Regulation 655/2013, and it is short enough to actually read. Here is what it allows, what it bans, and where brands get caught.

Reviewed by Cassandra Maddocks, chemist & biochemist · last reviewed 27 July 2026

Who regulates cosmetic claims in the EU?

Regulation (EU) No 655/2013 sets six common criteria every claim must meet: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. There is no approval step; the Responsible Person must hold evidence for every claim, and market surveillance checks after the fact.

The six criteria apply to any claim in any medium: pack, website, social post or marketplace listing. The full text sits at Regulation (EU) No 655/2013, and the claim evidence lives in the Product Information File.

Which claims are simply not allowed?

The first criterion bans any claim that a product was authorised or approved by an authority: EU approved, government certified and their variants are illegal on their face. Claims a product cannot support with evidence, and claims that denigrate lawful ingredients used by competitors, fail the other criteria.

This connects to a rule brands meet on marketplaces: since notification is a record rather than an approval, a CPNP certified badge is both meaningless and unlawful as a claim. The US mirror is the FDA's own note that it issues no certificates, covered in our marketplace guide.

The Claims Regulation on EUR-Lex prohibiting authorised-by-authority claims — Regulation (EU) No 655/2013 on EUR-Lex: claims of authorisation or approval by an authority are not allowed. Captured 26 July 2026. View the official text.

Can I say natural, clean or hypoallergenic?

Yes, if you can prove what an average consumer would understand by it. Natural needs a defensible basis for the naturalness of the formula; hypoallergenic implies the product was designed to minimise allergens and needs supporting evidence; clean has no legal definition and is judged on the impression it creates.

The test is always the reasonably well-informed average consumer. Vague terms are not banned; unsupported impressions are. This is precisely what a claims review checks: each phrase against the evidence you actually hold, before an authority or a competitor does.

What about free-from claims like fragrance-free?

Mostly not, since 2019. The Commission's Technical Document on claims, applicable since 1 July 2019, treats free-from claims about lawful ingredients as denigrating: free from parabens is the canonical prohibited example. Free-from remains possible where it genuinely informs a choice, such as fragrance-free for sensitive users, and fails instantly if the INCI contradicts it.

The 2019 change caught thousands of packs that still said paraben free, and non-EU stock printed that way keeps arriving. The claim-versus-INCI mismatch is one of the most common findings in our reviews, and consumers on forums spot it too. The label side of this, including where warnings must appear, is in the label requirements guide.

What is changing for green and sustainability claims?

A lot, and soon. Directive (EU) 2024/825 bans generic environmental claims such as eco-friendly, green and climate neutral unless backed by recognised excellent performance, restricts sustainability labels to certification schemes or public authorities, and prohibits carbon-offset-based neutrality claims. Member states apply the rules from 27 September 2026.

Treat this the way we treat pending MoCRA rules: not yet enforced everywhere, but printing artwork today that says climate neutral or eco-friendly is printing a liability. The directive is at Directive (EU) 2024/825, and a green claim now belongs in every claims review we run.

How do US claims rules differ?

The US has no equivalent of 655/2013; instead the FTC polices deceptive advertising and the FDA polices claims that turn a cosmetic into an unapproved drug. Anti-ageing puffery is tolerated; treats eczema is a drug claim. The EU asks for evidence up front, the US punishes dishonesty after.

A claim set written for the EU usually survives the US; the reverse is not true, because US marketing tolerates drug-adjacent language the EU file cannot support. Both markets' label mechanics are compared in our US vs EU guide.

Sources

Primary sources cited in this guide. Regulatory status last verified 27 July 2026.