A Timely Reminder About Cosmetic Claims
Each summer, sunscreen returns to the spotlight as consumers seek protection from increasing UV exposure. This year, the conversation has shifted beyond sun protection alone.
Recent testing in Australia questioned whether several sunscreen products delivered the SPF protection stated on their labels. While investigations remain ongoing and some manufacturers have challenged the findings, the debate has already highlighted something much bigger than just sunscreen.
When consumers begin questioning one type of cosmetic claim, it naturally raises a broader question: how can manufacturers demonstrate that the claims they make are accurate and trustworthy?
Cosmetic Claims Need Evidence
A cosmetic claim is far more than a marketing statement.
For consumers, cosmetic claims often influence purchasing decisions, making confidence in those claims just as important as the product itself.
Whether a product promises SPF protection, 24-hour hydration, anti-ageing benefits or suitability for sensitive skin, every claim creates an expectation. Consumers rely on those statements when choosing products, while regulators expect manufacturers to be able to demonstrate that those claims are supported by appropriate evidence.
In the European Union, this principle is reflected in the Common Criteria established under Regulation (EU) No 655/2013. Rather than simply avoiding misleading wording, manufacturers should be able to demonstrate that their claims are truthful, adequately supported and proportionate to the available evidence.
This process is known as claim substantiation.
Why Can Questions Arise, Even When Products Have Been Tested?
The Australian sunscreen discussion also serves as a reminder that scientific testing is rarely as simple as a single pass-or-fail result.
SPF testing follows recognised methodologies, yet factors such as biological variability, laboratory conditions, manufacturing consistency and batch variation can all influence results. Different laboratories may even produce different outcomes despite following accepted procedures.
Documentation Remains the Foundation
Generating evidence is only one part of claim substantiation.
Manufacturers should also be able to demonstrate how that evidence supports the claims appearing on product labels, websites, technical documentation and other marketing materials.
Overall, documentation is the backbone of regulatory compliance. It is the evidence that proves compliance is an ongoing responsibility throughout a product’s lifecycle.
At Obelis, we believe effective regulatory compliance should never only be about approaching compliance as a procedural exercise. When manufacturers can confidently support the claims they make, everyone benefits. Businesses gain greater confidence, consumers benefit from more trustworthy products, and the market becomes safer and more transparent.
Claim substantiation continues to be a growing area of regulatory attention. What challenges have you encountered when supporting product claims? Share your thoughts below.
References:
European Commission. (2013). Commission Regulation (EU) No 655/2013 of 10 July 2013 laying down common criteria for the justification of claims used in relation to cosmetic products. Retrieved on 26/06/2026
Leave a Reply