The new Cosmetics Europe’s Charter and Guiding Principles on Responsible Marketing Communications

On September 15, 2020, Cosmetics Europe published the updated version of the Charter and Guiding Principles on Responsible Marketing Communications, in order to ensure better consumer protection in the new digitalized world.

We are all aware of the increasing importance of digital advertising, and of the more and more popular phenomenon of influencer advertising. The Cosmetics sector, of course, is deeply affected by the evolution of digital technologies, and now more than ever, consumer protection has become of primary relevance.

The Cosmetics Europe Charter was first published in 2012 and its main goal is to offer EU stakeholders best practices in cosmetics advertising through a self-regulating approach. In fact, the document does not contain only legal requirements (such as the ones included in the EC Common Criteria for Claims Regulation), but it goes further, creating a comprehensive common baseline for cosmetics’ advertising across Europe.

Hence, the Charter assures consumer protection and fair competition among companies in the EU.

The last revision mainly focuses on 3 areas:

  1. Digital and influencer marketing;

2. Advertising to vulnerable population: children and teens;

3. Environmental impact awareness.


Digital and Influencer Marketing

As for digital and influencer marketing, the Charter reaffirms the principle of image honesty: pre and postproduction techniques do not have to alter images to such a point that they become misleading for the consumer. Moreover, Models’ retouches cannot suggest a performance in reality by the product.

On the other side, social influencers must make clear when their contents are marketing, so that consumers can distinguish between advertising and genuine recommendations: a company cannot use influencers to covertly advertise cosmetic products.

Influencer communications are considered to be an advertisement under the marketer’s responsibility in case they meet three requirements:

1. Payment or reciprocal arrangement between the Company and the content creator;

2. Editorial control of the Company over the content (a final approval is sufficient);

3. The Company has intentionally linked, endorsed or distributed the communication for advertising purposes.


Advertising to Vulnerable Population: Children and Teens

Children and teens are more vulnerable than adults towards advertising and this is why they need special protection. Therefore, cosmetic companies have to align their marketing campaigns to the following guidelines:

- Advertising should not promote early sexualisation of young people;

- Advertising should not incite children to overuse decorative cosmetics and perfumes;

- Companies should consider promoting the concept of sanitary benefits of cosmetics, like sun protection products, acne cover-ups and oral care products;

- Companies should carefully evaluate the effects that advertising in social medias, smartphone applications and games may have on children and teens.


Environmental Impact Awareness

Cosmetic Europe believes that marketing should allow consumers to make sustainable choices. At the same time, advertising should not abuse of consumers’ concern for the environment or take advantage from their possible lack of sectorial knowledge.

Therefore, each claim, image and symbol emphasizing the environmental benefits of a product has to be duly supported by proofs, understood by an average consumer and should not give false impression or exaggerated benefits.

All considered, the EU cosmetics industry gave, once again, proof of its responsible attitude towards consumers, with a special attention to technological development and sustainability awareness.


Francesca Santacatterina

Regulatory Affairs Department

16/12/2020


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