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Claims review

A claims review is a reading of your own words back to you, one sentence at a time, with a verdict and a reason attached to each. It is the cheapest part of registration. It is also the part that changes the copy, because the copy is what is being read.

What a claim is judged against

Art. 20(2), Reg. (EC) 1223/2009 is the article that empowers the common criteria; the criteria themselves are in the Annex to Regulation (EU) No 655/2013. There are six: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making.

Six criteria, and any one of them can be the one that fails. That matters for the way a review is done. A sentence is not "compliant" or "non-compliant" in the abstract — it fails, or does not fail, against a named criterion, and the substantiation that would change the answer is usually specific and findable.

Check my product — free

Paste the product's public listing URL. We check which of the eight obligations are visibly met — free, while you wait — a screen of the public words, not a safety assessment.

Free. A gap list, not a safety assessment; not legal advice; a listing is not a label.

No public page, or the list is only on the pack? Paste it instead

How the review runs

Your page, label or leaflet is split into sentences. Each sentence gets:

  • a verdict against a named criterion;
  • the ingredient or annex entry it depends on, resolved to the registry where it depends on one;
  • the substantiation that would support it, where support is possible;
  • a flag where something is unresolved.

The flags are the point. A claim that mentions an ingredient we cannot match to your formula, a citation we cannot find at the source, a sentence that does not map to any criterion, or a reading the model itself is not sure of — each of those blocks delivery until a person has acknowledged it by name. A review that came back with no flags at all would be a review that had stopped looking.

Every human decision is recorded and kept. Nothing is overwritten. What was sent to you is archived as it was sent.

Natural and botanical brands

This is where the real questions are, and it is the formulation we know best.

"Natural", "organic" and "free from" are the three that decide a natural brand's whole front-of-pack, and they are not equally difficult. A free-from claim has a specific problem the others do not: it depends on the status of the thing it excludes, so it can fail on fairness even when it is perfectly true.

Essential-oil formulas carry a second layer. Fragrance allergen components have to be named on the label at the disclosure thresholds, and the list they are named from has been extended (Annex III, Reg. (EC) 1223/2009, as amended by Reg. (EU) 2023/1545) — which means marketing copy written around "no synthetic fragrance" can end up sitting beside an ingredient list that has just grown several allergen names. The claim did not change. The label did.

How a claim is settled

If a claim cannot be supported, we say so and we do not quietly rewrite it and charge for the edit. You get the criterion it turned on and the substantiation that would change the answer. We intend to publish those rulings by type — the claim, the verdict, the criterion or annex entry it turned on — with no client names in them.

Check what your listing says

Paste the URL of a product you already sell. Without an email you see the listing screen: what the page can answer, marked visible on the listing or not visible on the listing, and a note for the work that lives in the file — plus how many ingredient names resolved, and any Annex II lines the screen matched. That part is free and asks for nothing.

Give an email and the report adds the claims read — each sentence with the criterion it touches — and arrives as a mail you can keep. We email you the full report. We may write to you once about registering the product. No newsletter, no list, and we delete the report and your address when you ask. What the check does, in full → · Privacy →

A listing is not a label, so what comes back is a screen of the public words rather than a safety assessment.

Check my product — free

Paste the product's public listing URL. We check which of the eight obligations are visibly met — free, while you wait — a screen of the public words, not a safety assessment.

Free. A gap list, not a safety assessment; not legal advice; a listing is not a label.

No public page, or the list is only on the pack? Paste it instead

A claims review can be bought on its own — it does not require the rest of the registration to be under way. It is priced as one line on the pricing page: €320, per web page, label or set of ads, taken to the point where a person has approved every verdict. Get a fixed quote → with the page you want read, and you get that scope confirmed and a fixed price in writing before anything starts.

Questions people ask

Can I say natural on a cosmetic label in the EU?

There is no single article that bans the word. It is judged like any other claim against the six common criteria (Annex, Reg. (EU) No 655/2013), and the two that usually bite are truthfulness and informed decision-making: what proportion of the formula is natural, by what method of calculation, and would an average user reading your pack understand the same thing you meant. A claim with a stated basis survives that. A claim with an implied basis usually does not.

Can I say hypoallergenic?

You can make the claim only if you can support it, and the support is the hard part: it is a claim about the likelihood of an allergic reaction, so evidential support and honesty are both engaged. In a formula containing essential oils with declarable allergen components, the claim and the ingredient list will be read together, and they need to agree.

Is a free-from parabens claim legal?

It is the most fragile family of claims on this list, and the criterion is fairness: "Claims for cosmetic products shall be objective and shall not denigrate the competitors, nor shall they denigrate ingredients legally used" (Annex, point 5(1), Reg. (EU) No 655/2013). A free-from claim is a statement about an ingredient rather than about your product, which is how it can fail on fairness while being perfectly true. Where we can, we suggest a positive claim about what is in the formula, because it is easier to support and harder to lose.

What evidence do I need for a cosmetic claim?

Evidential support is one of the six criteria, so the answer is: enough that someone else could reach the same conclusion from it. In practice that is a study, a supplier's substantiation dossier, a consumer test with a described method, or a compositional fact that follows from the formula itself. The evidence lives in the product information file (Art. 11, Reg. (EC) 1223/2009), which is where an authority will look for it.

Is the price per product or per range?

A claims review is priced by what is reviewed — one page, one label, one campaign — not by how many products the copy mentions. You get the scope and a fixed price in writing before anything starts. The lines we charge, and what moves them →

Sources
Reg. (EC) 1223/2009 Art. 20(2)Art. 11Annex III
Reg. (EU) No 655/2013 Annex (common criteria)
Reg. (EU) 2023/1545

Start with the free check — see what your listing is missing, while you wait.