Cosmetics Claims in France - An Update on Usage

The ARPP (the French professional advertising Regulatory authority) has published new recommendations on cosmetic products, which have come into force in France from July 1, 2019. The recommendations are in line with the Technical Document on Cosmetic Claims published by the European Commission (EC) on July 3, 2017. The purpose of the recommendations is to provide guidance on the interpretation of the cosmetic regulations.

Cosmetic Products New Labeling Rules in France

According to the new labeling rules, the labels of cosmetic products are required to focus on the positive claims of the product. From July 1, 2019, no cosmetic product will be allowed to use “free-from” claims for ingredients that are already banned by the competent authority. The use of claims such as “Paraben-free” is also prohibited as it criticizes the nature of the ingredient. Additionally, the products are also not allowed to use the claim “Allergen-free”, as no product must give the impression that it is 100% free from allergic reactions. The rules are applicable to products, which are marketed after July 1, 2019. However, the products that support such claims and are already in the market need not be recalled as of now.

Meanwhile, the competent authority can still authorize some of the claims to ensure that the consumers make an informed choice. For example, the use of “alcohol-free” claim is allowed for mouthwashes targeting families or use of “free from ingredients of animal origin” for vegan products.

The new rules also suggest some specific alterations to claims:

1. New Claim

The word “new” can be used only if there is a modification in the formula of the cosmetic product or its use. The “new” claim can be used in the packaging and presentation for only one-year from its introduction in the market.

2. Environmental Allegations

Cosmetic products must follow these rules with respect to impact on the environment.

  • The packaging and label of the product must not mislead the consumers on the ecological benefits of the product
  • The product must not guarantee total safety of the environment
  • The packaging and label must not suggest any ecological virtues that the product does not possess

3. Hypoallergenic

In case of allergies, the only word permissible is “Hypoallergenic”. The word can be used for products that can reduce the risk of allergies. The product using the word must follow the following criteria:

  • The product must not contain any allergens or precursors of allergens
  • The product must not portray the total absence of allergic substances

The above-mentioned rules are already in place as per the regulations. While some of the industry experts say that new rules are an over-interpretation of the law, others believe that the stronger rules can help prevent the consumers from being misled and make informed buying decisions. Are you a cosmetic product manufacturer looking to market your product portfolio in France? Aim for compliance under a Regulatory expert’s supervision. Stay up-to-date. Stay compliant.