Skincare label claims: a glossary of what 13 common claims mean

A claim is the maker's statement

Claims are voluntary marketing messages, separate from the information a label must carry, such as the ingredient list.¹ In the EU they must meet six common criteria, from truthfulness to fairness, but those criteria deliberately do not define the wording a claim may use.² In the US, the FDA does not approve labelling before sale and has no list of approved or accepted claims; labelling must be truthful and not misleading.³ So for most of the claims below, no official definition exists.

Thirteen common claims

• Dermatologist and clinically tested: how to patch test a new skincare product explains what skin tests can and cannot show.
• Hypoallergenic, natural and organic: natural, organic and hypoallergenic cosmetics.
• Non-comedogenic: comedogenic ratings explained.
• Fragrance-free: fragrance free vs unscented.
• For sensitive skin: cosmetic labels and sensitive skin.
• Preservative-free and other "free from" claims: cosmetic preservatives and what clean beauty means.
• Alcohol-free: alcohol denat. in skincare.
• Tested claims, cruelty-free, vegan and pH balanced: below.

Tested claims: who tested, not what was found

EU guidance says "dermatologically tested" implies testing on people under a dermatologist's supervision, and that consumer self-assessment studies cannot support it. "Clinically tested" means testing on people under a medically or otherwise scientifically qualified professional, following a clinical protocol or in a clinical setting; the guidance says it refers to the expertise, process or conditions of the test. Consumers may expect such claims only where the results were favourable.⁴

The European Court of Justice found that the average consumer reads "dermatologically tested" as meaning the product was tested for its effects on the skin, with positive results showing it was well tolerated.⁴ The claim on its own does not say how many people took part, for how long, or with what skin. In the US, the FDA has no list of approved or accepted claims for cosmetics, these included.³

Cruelty-free and vegan

The US has no legal definition of "cruelty-free" or "not tested on animals". The FDA notes that a company may apply the claim only to its finished product while relying on suppliers or contract laboratories for any animal tests on ingredients, and that many raw materials were tested on animals when first introduced.¹⁰

EU law goes further. Article 18 of the cosmetics regulation bans testing finished cosmetics and their ingredients on animals in the EU to meet the regulation's requirements, and bans selling cosmetics whose formula or ingredients were tested that way.¹¹ The testing ban on finished products has applied since 11 September 2004, and the last part of the marketing ban since 11 March 2013.¹⁴ A product may say no animal tests were carried out only if neither the maker nor its suppliers carried out or commissioned animal tests on the product, its prototype or any of its ingredients, or used ingredients tested on animals by others to develop new cosmetics (Article 20(3)).¹¹ In the Commission's 2016 review of claims, four Member States found a rabbit logo or similar text on products whose responsible person could not show this for every ingredient.¹

Vegan is defined in neither the EU cosmetics regulation nor the FDA's labelling regulations.¹¹¹⁵ EU guidance names "free from animal-derived ingredients", in products intended for vegans, as a claim that helps people choose.⁴ On a list, animal-derived ingredients include Lanolin, refined from the fatty secretion of sheep¹⁶, and Cera Alba, which is beeswax.¹⁷ Vegan describes ingredients; whether anything was tested on animals is a separate claim.

pH balanced: a number the label leaves out

No cosmetics rule defines "pH balanced", and pH is not among the details an EU label must show (Article 19).¹¹ Published measurements of skin surface pH range from 4.0 to 7.0; a multicentre study of 330 people estimated the natural value at about 4.7, and found that plain tap water raised it for up to six hours.¹² Without the product's own pH on the pack, the claim cannot be checked against either figure.

What to look for on the label

• Claims you can check: fragrance-free, alcohol-free and vegan can be compared with the ingredient names. Tested and suitability claims cannot.
• Ingredient claims: in the EU, an ingredient a product claims to contain must be deliberately present.² The list does not give its amount.
• Logos: a rabbit or a natural or organic logo means what the scheme behind it says. In the US, a product that does not meet USDA standards may not imply that it is USDA-certified organic.⁹

Paste a list into the skincare ingredient checker to see what each ingredient does and which are fragrance or named fragrance allergens. It checks the list, not the claims on the front, and never rates a product.