Clarity, Harmony & Old Dinosaurs

Many of you will have seen Hans Ingels Ingels recent post https://www.dhirubhai.net/posts/hans-ingels-07136658_the-cosmetics-regulation-was-adopted-15-years-activity-7256767554864431104-eaTq?utm_source=share&utm_medium=member_desktop, highlighting a launch of a review and evaluation of the current EU Cosmetic Regulation (1223/2009) to identify strengths and weakness, with a view to publish these findings in the first half of 2026 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14433-Cosmetic-Products-Regulation-evaluation_en

How much change will we see?

Hopefully part of the review, at least at some point, will include the EU cosmetic claims legislation (655/2013), which is crucial for consumer protection and market fairness. Here are some aspects that I would like to be considered for change to avoid “Claims Washing”:

1. Transparency and Clarity: There should be clearer guidelines on what constitutes substantiated claims.
2. Scientific Evidence Requirements: Strengthening the requirements for scientific evidence behind claims could ensure that products are backed by reliable studies, helping to reduce the potential for misleading marketing.
3. Digital and Social Media Influence: With the rise of influencer marketing, regulations may need to be more robust in addressing claims made in digital spaces to ensure they comply with existing laws. This includes promoting products/hacks that were not developed for cosmetic application.
4. Sustainability Claims: As sustainability becomes more important to consumers,? a continued drive for clearer definitions and standards, logos, labels, etc., are further necessary to keep the “anti-greenwashing” momentum running.
5. Consumer & Industry Education: Implementing initiatives to educate consumers and newbies to the industry, about the meaning of claims, their substantiation and development, can empower them to make better marketing judgements and informed choices.
6. Monitoring and Enforcement: Enhancing mechanisms for monitoring compliance and enforcing the regulations could help address non-compliant products more effectively…and linked to point 7.
7. Harmonisation Across Member States: Ensuring consistency in how claims are interpreted and enforced across different EU countries can create a fairer market environment.

These changes could enhance consumer trust and ensure that we the cosmetic industry remains not only accountable but innovative as well. What are your wishes?

Harmonisation and Transparency Key

As the review and evaluation of the Cosmetics Regulation approaches, it would be valuable for the reviewers to hear your thoughts on the need for greater harmonisation and transparency among advertising standards authorities across EU member states. It's essential that, as an industry, we have access to consumer complaints, understand their reasons, and learn from the judgments made. This transparency can offer valuable insights for improving our practices.What do you think? Do you believe you (and the consumer) has easy access to complaints and the rulings?

Why not share your views on this topic — as well as your broader thoughts on the Cosmetics Regulation — through the EU’s “Have Your Say” initiative when it becomes available? Your input could help shape the future of the regulation.

If consumers and regulators are calling for greater transparency from the industry, it’s only fair that regulators also hold themselves to the same standard. They should work to ensure consumers are fully aware of their rights to lodge complaints, and make these complaints publicly accessible, free of charge, for the benefit of both consumers and the industry. Perhaps this is an area the EU regulators could consider as part of their review of the Cosmetics Regulation.

Let’s see what happens!

A Banal Old Dinosaur

Regarding a public critique of my recent book, I fully appreciate that everyone has their own view of what is most helpful or engaging. I wrote it with the intention of prompting thought, and in an area like cosmetic claims regulation, where the landscape is complex and constantly evolving, it's important to encourage readers (consumers and new entrants to the industry, especially) to ask the right questions and think critically about the bigger picture. I’ve always believed that we learn best when we are challenged to think for ourselves. As to the large print, it was a multiple request, so I did just that!

As for being labeled an "old dinosaur," I’ll admit, that label does make me smile. Yes, I’ve been around for quite a while—and while I may not be the youngest face in the room, I believe my experience offers a depth of insight that others might not yet have. In fact, I think my battle with cancer back in 2009, has only deepened my appreciation for what truly matters: staying relevant, staying true to one’s values, and making a positive difference in whatever way I can. I’m proud to offer my services to anyone who finds value in them, and if someone prefers to shop elsewhere, I respect that too.

I’ve always believed in the power of giving back, which is why I continue to share free insights on LinkedIn and in other journals whenever possible. As much as I’d love to work with everyone who asks for my help, like everyone else, I do have to eat—and I have to balance that with my desire to support the industry as best I can.

I’m grateful for those who have supported my work, and I’ll keep doing what I do for as long as I can—regardless of the opinions that come my way. If anything, it just fuels my commitment to making a difference.

And for those who are genuinely interested…

Look out for my HPCtoday editorial in the end of year edition reviewing key highlights of 2024 cosmetic claims, and what we might expect going into 2025.

Articles early next year include an extensive paper on Ai and Claims with Personal Care (plus the Chinese edition in February), and of course, not forgetting my regular column with EuroCosmetics and monthly articles with BEAUTYSTREAMS. As consulting scientific editor for Eurocosmetics we welcome papers from you, or you can send directly to Claudia Oderwald

SCANCOS have their annual conference later this month where I am pleased to speak on the potential of Ai in cosmetic claims, and? look out for the SGS-PRODERM Academy Claims Seminar 25-27 February 2025