Cosmed demands truthful product labeling in line with legislation

French cosmetics association Cosmed has issued a document urging the personal care industry to follow clear regulatory frameworks to avoid greenwashing and misinformation. Cosmetic brands increasingly compete to appear ethical, sustainable, and safe for consumers amid consumer demand for environmentally conscious and ethical products.

Terms such as “clean,” “free from,” “with,” “cruelty-free,” and “natural,” are becoming central to brands’ marketing strategies. However, as these claims come under the spotlight, Cosmed emphasizes that they are often misunderstood or misused. The association urges businesses to be compliant with EU Regulation (EU) No 655/2013 and the latest Directive (EU) 2024/825.

EU Regulation No 655/2013 requires cosmetic claims to be truthful, evidence-based, and not misleading, while Directive (EU) 2024/825 bans vague environmental claims unless they are specific, verifiable, and backed by demonstrable performance.

“The regulation leaves some areas open to interpretation, which are sometimes complex to assess. It should be a real collaboration between regulatory, marketing, and consumer science teams,” Caroline Bassoni, director of regulatory affairs at Cosmed tells Personal Care Insights.

Transparency and misinterpretation

“Free from” claims are common on cosmetic labels, but Cosmed stresses that without proper context or evidence, they can mislead consumers or unjustly discredit ingredients that are permitted in formulations by the EU.

The guide outlines that specific “free from” claims, such as “free from endocrine disruptors,” cannot be verified, which makes them unacceptable under regulation. Meanwhile, statements like “free from parabens” may wrongly suggest these ingredients are harmful despite their authorized use under EU law.

On the other hand, claims that highlight the presence of an ingredient — such as “with hyaluronic acid” — must meet substantiation criteria. The ingredient must be present at a specific concentration and demonstrate a proven effect.

“The brands should be careful to have robust evidence on the ingredient on which they claim a specific benefit,” says Bassoni, stressing that it is not enough to list “trending” ingredients without scientific backing.

Non-compliance

France’s fraud control agency, the Directorate-General for Competition, Consumer Affairs and Fraud Control (DGCCRF), assessed companies for their compliance with the directives. According to their assessment, 40% of “free from” claims and 33% of “with” claims inspected did not meet legal standards.

Statements like “free from parabens” may wrongly suggest these ingredients are harmful despite their authorized use under EU law.Bassoni says enforcement efforts are becoming more aggressive. In France, inspections are transitioning into more repressive measures against non-compliant claims. 

“The French authorities have been conducting educational inspection campaigns for a few years. They are now switching to more repressive actions toward brands unable to justify the efficacy of such claimed ingredients.”

This signals a new era where brands can no longer rely on grey areas in legislation but are instead nudged to focus on how the claims read on shelves. “It is key that brands reflect on consumers’ perception before validating their claims,” she adds.

Clean beauty and cruelty-free

The rise of the clean beauty trend has encouraged brands to adopt more transparent and sustainable approaches — but the term itself lacks a universal definition. As a result, companies often apply their own standards, creating confusion for consumers.

“I would not say it is doing harm,” says Bassoni, “but this can surely lead to confusion in consumers’ minds. Brands should be specific in their claims and keep in mind fairness.”

Ingredient blacklists are popular among clean beauty brands and may imply safety risks where none exist, inadvertently spreading fear-based messaging. “Claims shall not denigrate the competitors, nor shall they denigrate ingredients legally used,” Bassoni emphasizes, referencing EU guidelines that call for fair and objective communication.

Cruelty-free claims pose additional challenges. While animal testing for cosmetics is banned in the EU, brands often still use labels like “cruelty-free” or “not tested on animals” claims, which are not permitted unless paired with other substantiated benefits.

Bassoni says a “cruelty-free” claim is not compliant with the EU common criteria as “claims which convey the idea that a product has a specific benefit when this benefit is mere compliance with minimum legal requirements, shall not be allowed.”Caroline Bassoni, director of regulatory affairs at Cosmed.

“Vegan” claims are permitted if they truthfully refer to ingredient origin rather than testing methods, according to Bassoni.

Curbing greenwashing

Greenwashing — the use of vague or unverified environmental claims — has triggered legislative action across Europe. According to the guide document, a recent investigation by the DGCCRF found that one in four environmental claims on non-food products were problematic, prompting regulatory updates.

Claims like “eco-friendly” or “CO2 neutral” must now be specific and verifiable, according to Directive 2024/825.

While the directive bans vague or unverifiable claims, Bassoni tells Personal Care Insights she believes it will not drastically change things for most cosmetic brands, as most already followed similar requirements under EU Regulation 655/2013.

“However, the future regulation that may have more impact on cosmetic products is the directive on the substantiation and communication of explicit environmental claims (Green Claims Directive),” she highlights.

“This directive is currently in the trilogue phase, and there are some plans to require certification by third parties for some types of environmental claims.”

The guide document details: “Cosmetic trends evolve rapidly, whereas regulations take longer to be put in place. It is worth noting that regulations often emerge after some abuses from the industry have occurred. So it is important to monitor the market and keep an eye on marketing messages.”