Making Cosmetics Claims: How To Do It Right


All information in this blog post comes from Marie Gale’s excellent book “Soap & Cosmetic Labeling.

First, what is a cosmetic? The Food, Drug, and Cosmetic Act defines a cosmetic as: “A product, except soap, intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance.”

Cosmetics include scrubs, bath fizzies, shampoo, facial toners, lotions/creams, bubble bath, face masks, hair pomades, eye serum, exfoliants, mustache wax, and foot soaks, to name a few. Soap is sometimes considered a cosmetic as well depending on its intended use.

When we make products, such as lotions and creams, we want to tell potential buyers what to expect from that product and what is its intended use. We can say things such as it smells good, makes you feel or look younger, or promotes restful sleep. Those are all cosmetic claims. Conversely, drug claims would be that the smell increases hormonal attraction, the product prevents/slows aging or is anti-aging, or it treats insomnia.

See the difference?

Marie Gale puts it this way in her book: “Cosmetics change purely physical characteristics (i.e., cleanliness, color, look, appearance, smell) not functionality (i.e., reducing acne, anti-itch, dandruff treatment, cavity prevention).”

Here is a handy chart taken from Gale’s book for some of the most common cosmetic items we as makers produce.

Cosmetic Claim
1. smells good
2. helps to relax
3. wrinkles appear/look reduced
4. soothes skin
5. moisturizes/colors lips
Drug Claim
1. increases hormonal attraction
2. muscle relaxant
3. anti-wrinkle/reduces wrinkles
4. treats eczema outbreaks/anti-itch
5. plumps lips, protects against/treats chapped lips

We always advise that you steer away from making any drug claims, even when an ingredient is approved for such. As long as you make no claims to treat or cure an illness or disease, you are within the bounds of a cosmetic.

If you have any questions about this topic, we highly recommend you get your own copy of Marie Gale’s “Soap & Cosmetic Labeling.”

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About Denise

I'm a crazy goat lady who got into making my own soap with goat milk, found MMS to order supplies, and now I get to combine my love of creating skin care products with a job to pay the feed bill. I live in Alaska and greatly enjoy the unique aspects of my northern home - summer days when it never gets dark and the Northern Lights dancing above in winter. Favorite scents include Wild Mint and Ivy, Rhubarb & Sugar Cane, and Eucalyptus Spearmint.

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