Cosmetics claims such as “dermatologically tested”, “hypoallergenic” or “paraben-free” are allowed in the EU only if they are true, substantiated and fair – that is Article 20 of the Cosmetics Regulation and the common criteria of Regulation (EU) No 655/2013. Medicinal claims are off limits. What you may write, what to drop and which mandatory information belongs in the online listing.
The basic rule
Under Article 20 of Regulation (EC) No 1223/2009, the labelling, making available and advertising of cosmetic products must not use text, names, trade marks, pictures or other signs that imply characteristics or functions the product does not have. That covers every medium – including the title, bullet points, description and images of a marketplace listing.
Since 11 July 2013, Regulation (EU) No 655/2013 has set six common criteria against which every claim is measured:
- Legal compliance: no “approved by the authorities” claims, no selling mere legal compliance as a benefit.
- Truthfulness: an ingredient you advertise must be deliberately present.
- Evidential support: every explicit or implied claim needs adequate, verifiable evidence.
- Honesty: do not promise more than the evidence shows.
- Fairness: do not denigrate competitors or legally used ingredients.
- Informed decision-making: clear and understandable for the average consumer.
The evidence sits with the responsible person (usually the manufacturer or importer) in the product information file. As a seller you take over their claims – if you reword or sharpen them, you are answerable for the new claim. How authorities read the criteria is set out in the “Technical document on cosmetic claims” of the Commission’s working group on cosmetic products. It is not legally binding, but authorities and courts use it.
Common claims and what must back them
| Claim | What you need |
|---|---|
| dermatologically tested | A test on humans supervised by a dermatologist, with a favourable result; consumer self-assessment is not enough. The Court of Justice (C-99/01) held that consumers expect the product was tested on the skin and well tolerated. |
| clinically tested | A test on humans supervised by a medically or scientifically qualified professional, following a clinical protocol or in a clinical setting. |
| hypoallergenic | A product designed to minimise its allergenic potential, with known allergens and allergen precursors avoided entirely, backed by robust data. It must not suggest that allergic reactions are ruled out. |
| paraben-free, phenoxyethanol-free | Not acceptable under the technical document: the claim denigrates safe, authorised substances. |
| preservative-free | No ingredient with a preserving effect, including ones outside the Annex V list such as alcohol – unless a challenge test shows it does not preserve. |
| fragrance-free, perfume-free | No ingredient with a perfuming function, whatever its main function. |
| free from corticosteroids, free from hydroquinone | Not allowed: these substances are banned in cosmetics anyway. |
| free from animal-derived ingredients, alcohol-free, acetone-free | Allowed if true – such claims help a specific group choose (vegans, families, people sensitive to smell). |
| natural, natural cosmetics | No legal definition in EU law. The claim still has to be true and must not overstate the formula; use a seal such as NATRUE or COSMOS only if the product is certified. |
Environmental claims also fall under the ban on generic green claims, which applies in Germany since 27 September 2026 (the date set by EU Directive 2024/825 for all member states): “sustainable skincare” or “eco-friendly packaging” are out without a recognised ecolabel (see green claims ban).
Medicinal claims: the red line
A cosmetic cleans, perfumes, changes the appearance, protects, keeps in good condition or corrects body odour (Article 2 of the Cosmetics Regulation). Claim that a cream treats or prevents a disease and it is presented as a medicinal product under Article 1(2) of Directive 2001/83/EC – which needs a marketing authorisation it does not have. National health-advertising rules come on top; in Germany the Heilmittelwerbegesetz applies to cosmetics as soon as the advertising refers to recognising, removing or alleviating a disease (§ 1 HWG) and bans attributing therapeutic effects they do not have (§ 3 HWG).
| Instead of | Write |
|---|---|
| cures eczema | cares for very dry, sensitive skin |
| treats acne | cleanses pores, for blemish-prone skin |
| anti-inflammatory | soothes the skin (only with evidence) |
| stops hair loss | cares for scalp and hair |
| relieves psoriasis | drop it |
Customer reviews you quote in bullet points (“it healed my rosacea”) are your advertising too.
Mandatory information in the online listing
- Ingredient list (INCI): the Cosmetics Regulation requires it on the packaging (Article 19(1)(g)). Online, consumer law requires the main characteristics of the product before purchase (Article 6(1)(a) of the Consumer Rights Directive), and omitting material information is unfair (Article 7 of the Unfair Commercial Practices Directive). German courts have held that the ingredient list is such information, for example LG Karlsruhe (13 O 26/20, 7 April 2020) against an Amazon seller. The safe option is the full list as text in the description, not only a photo of the packaging.
- Nominal content: the quantity in ml or g (Article 19(1)(b)). Online you need it for the unit price anyway.
- Unit price: the price per litre or kilogram next to the selling price (Directive 98/6/EC); exemptions differ by country – Germany, for example, exempts packs under 10 g or 10 ml, decorative cosmetics and certain perfumes (see unit price in Germany).
- Precautions and warnings: special precautions from the packaging (Article 19(1)(d)), plus the manufacturer and EU responsible person under the GPSR (see GPSR information in listings).
Before and after
| Instead of | Write |
|---|---|
| 100 % allergen-free | hypoallergenic – only with evidence, otherwise drop it |
| free from harmful parabens | drop it |
| dermatologically tested (no study) | drop it or ask the manufacturer for the study |
| 48-hour hydration | only if the study shows 48 hours – otherwise the proven figure |
| with moisturising aloe vera | with aloe vera – only if the product itself moisturises |
| approved by authorities, EU compliant | drop it – every cosmetic must comply |
| CE certified face cream | drop it – cosmetics do not carry a CE marking |
Check your listing
The free listing check recognises cosmetics listings, flags a missing ingredient list and nominal content, and marks medicinal claims and wording such as “dermatologically tested” or “hypoallergenic” as hints – only you can tell whether you hold the evidence. Test single phrases quickly in the claims checker.