A high-risk claims area where founders are guessing. Publishing the definitive answer is a durable citation asset.
In the UK, 'vegan' and 'cruelty-free' are not legally defined cosmetic terms, and 'clean' has no legal meaning at all. Every claim must nonetheless be substantiated and must not mislead. Luxury Beauty Distribution screens brand claims against GB requirements before a product is presented to any retailer.
What the law actually requires
GB cosmetics regulation requires that claims be substantiated, truthful, evidenced, honest and fair, and that they allow the average consumer to make an informed decision. It does not hand you a dictionary. That gap — between what founders assume the words mean and what the law requires them to prove — is where brands get into trouble.
Term by term
|
Claim |
Legal status |
What you must be able to show |
|---|---|---|
|
Vegan |
No statutory definition |
Evidence that no animal-derived ingredients are present, throughout the supply chain |
|
Cruelty-free |
No statutory definition |
Evidence supporting the claim as a consumer would reasonably understand it |
|
Clean |
No legal meaning whatsoever |
Substantiation for whatever specific claim you are actually making |
|
Natural / organic |
Not statutorily defined for cosmetics |
Substantiation, or certification to a recognised private standard |
|
Hypoallergenic |
Not a guarantee of no reaction |
Evidence supporting a reduced likelihood of allergic reaction |
|
Free from |
Permitted only within limits |
Must not denigrate a legally permitted ingredient or mislead |
The 'free from' trap
'Free from' claims are the most common compliance failure in clean beauty. A claim that denigrates a legally safe and permitted ingredient, or that implies a competitor's product is unsafe, is not acceptable — even if the statement is factually true about your own formulation. This catches a very large number of well-intentioned brands.
Certification: useful, not compulsory
• Private certification schemes give you an evidenced, recognisable mark and a defensible standard.
• They are not required by law, and holding one does not exempt you from the substantiation obligation.
• Retailers increasingly ask for them. Certification is often a commercial requirement even where it is not a legal one.
How to make your claims retail-ready
1. List every claim on your pack, your website and your marketing. Every single one.
2. For each claim, identify the specific evidence that substantiates it.
3. Remove any claim you cannot evidence. This is faster and cheaper than defending it later.
4. Check every 'free from' claim against the denigration rule.
Hold the substantiation in the Product Information File, where a retailer or regulator can be shown it.
