What you can and cannot say

One rule underneath all of it

There is no list of forbidden words. What there is instead is a set of common criteria that every claim about a cosmetic has to meet, and almost every specific question resolves to one of them. Learn the criteria and you can answer questions this page never anticipated.

Natural and organic

Neither word has a legal definition in cosmetics. That surprises people in both directions: you are not forbidden from using them, and you also cannot point at a rule that says what you meant.

What exists instead is an international standard giving a method for calculating how much of a product is of natural origin, which is a calculation and not a certification, and a handful of private certification schemes with their own thresholds and their own marks. If you want the word to mean something specific to a buyer, one of those is how you do it.

The trap is the informed decision-making criterion. A product that is 5 percent botanical extract and 95 percent everything else, sold as natural, may be literally arguable and still mislead the average buyer, which is the test that actually applies. If you use the word, be ready to say what you meant by it and to show the figure.

Clean, chemical-free, and free-from claims

Free-from claims are the most restricted family, and the reasoning is the fairness criterion: a claim that your product is free from something lawful implies the something is unsafe, which denigrates every competitor using it and every supplier making it.

So free-from claims about ingredients that are lawful and safely used are generally not acceptable, and neither is a free-from claim about something that could never have been in the product anyway. Chemical-free is worse than merely unacceptable: everything is chemicals, including water and every essential oil you own, so the claim is not true of anything that exists.

Clean has no definition at all and carries the same implication by association. Non-toxic is a safety claim, and safety is already a legal requirement, which puts it on the wrong side of the legal compliance criterion: you cannot market as a feature the thing the law obliged you to do.

Hypoallergenic, and the ones that need evidence

Hypoallergenic is permitted and is expensive to justify. It requires evidence that the product has been formulated to minimize the potential for allergic reaction, and it cannot be a claim that no reaction is possible, because no such product exists. Fragrance in particular is the category most associated with contact allergy, so the claim is scrutinized hardest exactly where it is most tempting.

One that catches people out for the opposite reason: animal testing. It is prohibited for cosmetics in the EU, so advertising that your product is not animal tested is claiming credit for obeying the law, which the legal compliance criterion is precisely about. Certification marks are treated differently from a bare claim.

The line where it stops being a cosmetic

This is the most serious one on the page, and it is almost always crossed in the marketing rather than on the label.

A product is a cosmetic because of what it is for: cleaning, perfuming, changing appearance, protecting, keeping in good condition, correcting body odor. Say instead that it relieves anxiety, helps you sleep, eases headaches, boosts immunity or balances hormones, and you are no longer describing a cosmetic. You are describing a product with a different legal category, an approval process and evidence requirements a small house cannot meet.

This is the specific risk in aromatherapy-adjacent copy, where the vocabulary is borrowed from a tradition that talks freely about effects. The rule is not about whether the effect is real. It is about what claiming it turns your product into.

The same trap exists in the United States, where a claim to affect the structure or function of the body moves a product out of the cosmetic category, and it applies to your social media and your customer emails as much as to the bottle.

What evidence actually looks like

The standard is that the evidence has to be relevant to the claim, sufficient for it, and held before the claim is made. Not gathered afterwards when somebody asks.

• A study on the finished product, where the claim is about the finished product. A study on an ingredient supports a claim about that ingredient and rarely about your blend of it.
• Supplier documentation where the claim is about origin or composition, and far enough down the chain to actually cover the claim.
• Consumer testing where the claim is about perception, described as perception rather than as fact.
• Your own composition figures, which is the one kind of evidence you already have and the reason a percentage claim is the cheapest defensible claim available to you.

That last point is worth taking seriously. A specific, verifiable statement is both more defensible and more persuasive than a vague superlative: naming what is in it, at what percentage, and where it came from is a claim you can prove from your own records and one nobody else in your category is making.

How Orris Bench handles this

The product file it compiles has a place for the evidence behind each claimed effect, because the regulation requires the file to hold proof of any effect the product claims. A claim with nothing behind it is visible as a gap rather than forgotten.

The composition figures that make a specific claim defensible come out of the same record as everything else: what is in the product, at what percentage of the finished bottle, from which lot. If you say a product is a fifth jasmine absolute, that is a sentence you can prove from the batch that was actually made.

Sources

The common criteria are Commission Regulation (EU) No 655/2013, with the Commission's own technical document on cosmetic claims and its annex on free-from and hypoallergenic claims. The definition of a cosmetic product, and therefore the line beyond which a claim moves the product out of the category, is Article 2 of Regulation (EC) No 1223/2009; the requirement that the product file hold proof of claimed effects is Article 11. The animal testing prohibition is Article 18. For the United States, the cosmetic definition is in the Federal Food, Drug, and Cosmetic Act. This page is written for people who make fragrances and it is not legal advice; whether a particular sentence about a particular product is defensible depends on the evidence you hold for it.