Without
So-called "free of..." or "no..." claims are used in cosmetics to communicate the absence of an ingredient or an entire class of ingredients.
Paragraph 2 of Article 20 of Regulation (EC) No 1223/2009 has required the Commission to issue common criteria for justifying claims, which are based on criteria of honesty, as well as truthfulness, compliance with regulations, correctness, evidentiary support and informed decision-making.
Some Practical Examples
- Is it possible to use a "paraben-free" claim? No, this is not permitted, as it is derogatory toward the entire class of parabens, which are in fact allowed and included in Annex V of Regulation 1223/2009. The same applies to other preservatives such as Phenoxyethanol and Triclosan.
- Is a "preservative-free" claim allowed for fragrances? Given that fragrances typically contain a high volume of ethanol, which makes the additional use of preservatives unnecessary, it would be dishonest to highlight that the fragrance does not contain preservatives, so this claim also has no valid basis.
- Is it possible to use a "allergen-free" claim to indicate the absence of allergenic or sensitizing substances? No, this is not permitted, as the concept of allergy is based on individual response, so a complete absence of the risk of an allergic reaction cannot be guaranteed.
- What, then, does a "fragrance-free" claim mean? Very often, manufacturers of skin, hair and body care products offer fragrance-free versions to meet the needs of those who are allergic to fragrances or prefer unscented alternatives. In reality, very few people are allergic to fragrances, and there are now many fragrances on the market that do not contain allergens and are therefore harmless.