Technical Document on Cosmetic Claims

Cosmetic product responsible persons and manufacturers should be aware of the importance of the Technical Document on Cosmetic Claims that was published, in July 2017, on the website of the European Commission.

While the views expressed in the document are not legally binding, the purpose is to provide guidance for the application of Commission Regulation (EU) No 655/2013, which established the common criteria for the justification of claims used in relation to cosmetic products.

There are four Annexes in the document, as described below:
I. Annex I provides a detailed description of the common criteria established by Commission Regulation (EU) No 655/2013, including illustrative and non exhaustive examples of claims that may or may not be appropriate.
II. Annex II provides guidance on best practices, specifically relating to the type of evidential support used for the substantiation of cosmetic claims.
III.Annex III provides guidance on the application of the common criteria to ‘free from’ claims, including illustrative and non-exhaustive examples in relation to restrictions on ‘free from’ claims. For example, claims such as ‘free from parabens’ ‘free from preservatives’, and ‘free from alcohol’ are discussed within this section of the document.
IV.Annex IV provides guidance on the application of the common criteria to ‘hypoallergenic’ claims. Guidance on this topic was originally published in July 2013 but included only Annexes I and II above. Annex III and IV were added on 3 July 2017, and were deemed to be applicable as of 1 July 2019.

Therefore, all new batches of a cosmetic product placed on the market are expected to be in line with the revised document, as well as meeting the legal requirements of Commission Regulation (EU) No 655/2013. Companies should review the technical document on cosmetic claims to ensure that the claims on their cosmetic products are acceptable.

For further information on cosmetic claims, please contact