THE END OF “FREE-FROM” CLAIMS
An additional annex – Annex III, ‘Free from’ claims, was recently added to EC Regulation No. 655/2013. Effective July 2019, claims highlighting the absence of substances will be regulated and restricted. A big part of this change is highly relevant for preservatives. “Parabens Free” claims for example, will no longer be allowed, and “Preservatives Free” is also in question.
Most products today contain, mostly for marketing purposes, one or more of the following categories of claims:
- Claims characterizing ingredients or product functions (e.g. ‘anti-aging’);
- Claims related to the product’s efficacy (e.g. ‘total block sunscreen’);
- Claims highlighting the absence of substances (e.g. ‘fragrance free’);
- Claims addressing skin compatibility of the product (e.g. ‘hypoallergenic’, ‘for sensitive skin’);
- Claims addressing health or additional benefits other than the cosmetic purpose
On 3 July 2017, annex III, ‘Free from’ claims, was added to EC No. 655/2013, and should be applicable as of 1 July 2019.
Table 1: ‘Free from’ claims – examples
|Type of ‘Free from’ claim||Status||Reasoning|
|‘Free from’ + ingredient prohibited by the EU Cosmetics Regulation||⊗||E.g. ‘Heavy metals free’ 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.|
|‘Free from’ + ingredient not supposed to be present in the product||⊗||E.g. ‘Preservative free’ (if the product is a fine fragrance containing high amounts of alcohol or bath salts, not expected to contain preservatives) Claims shall not attribute to the product concerning specific characteristics if similar products possess the same characteristics.|
|‘Free from’ + ingredients category (e.g. fragrance, preservative, colorant)||⊗/ OK if||E.g. ‘Preservative free’ is wrong if the product contains an ingredient, not in the official list of preservatives (Annex V) but having antimicrobial properties. E.g. ‘Fragrance free’ is wrong if the product contains an ingredient that exerts a perfuming function, regardless of its other possible functions in the product. This claim is acceptable except only if the product contains an ingredient having properties of this ingredients family as a side function.|
|‘Free from’ + an ingredient or an ingredients family that are legally used||⊗||E.g. ‘Parabens free’ Claims for cosmetic products shall be objective and shall not denigrate the competitors, nor shall they denigrate ingredients legally used.|
|‘Free from’ claims that allow an informed choice to a specific target group or groups of end users||OK||E.g. ‘Free from alcohol’ in a mouthwash intended as a family product. |
or ‘Free from animal-derived ingredients’ in Vegan products. Claims are an integral part of products and shall contain information allowing the average end user to make an informed choice.
At Skin Match Technology transparency is key in consulting end-customers for our brands and retailers. As a third party consultation provider, our consultation is and will always be independent and only highlighting and answering questions your customers ask. Today, we have taken a quick look at the importance of such claims and the requests for “free-from” information in Skin Care:
50% are looking for paraben-free products
30% are looking for alcohol-free products
28% are looking for fragrance-free products
25% are looking for pigment-free products
Help your customers find what they are looking for fast and seamless with all the information they need.