At the European Forum on “Cosmetic Claims, Justification and Certifications”, held on 10 September 2026, Emma Trogen of Cosmetics Europe gave a presentation on the framework for claims in Europe. She highlighted the political and regulatory context, which is becoming increasingly demanding, particularly with regard to the new rules governing environmental claims.
Cosmetic claims are essential in the day-to-day world of cosmetics: they convey innovation, the benefits of products and their relevance to consumers in language that everyone can understand. They must comply with strict regulatory requirements, but are also strongly influenced by culture and linguistic differences: there are, in fact, 27 Member States in Europe, and almost as many languages, customs and traditions, which means that claims may vary slightly from one country to another.
They fall within the remit of businesses, and more specifically the Responsible Person, who is accountable for the way in which they are actually presented on the market and how the average consumer perceives them. “This is, in fact, one of the fundamental principles of the regulations governing claims,” emphasised Emma Trogen, who also recalled how the average consumer has been defined by the Court of Justice of the European Union: a reasonably well-informed, reasonably observant and circumspect person, taking into account social, cultural and linguistic factors.
The regulatory framework
It is important to bear in mind that claims relating to cosmetic products must comply not only with the entire applicable regulatory framework of the European Union, but also with any specific requirements …
