The global beauty category has long made claims around ingredients, product efficacy, manufacturing, and packaging. But no matter the claim, the industry must not lose sight of one simple fact: a claim is a legal statement that must be backed by research. Words matter.
In the European Union, cosmetic product claims are stringently governed by the Cosmetic Products Regulation (EC) No 1223/2009 and the Commission Regulation (EU) No 655/2013, the latter of which outlines six common criteria for the justification of claims: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. Any claims made about a product must directly link back to supporting scientific evidence and data in its Product Information File (PIF)—a mandatory legal dossier required by the European Commission. In the United States, cosmetic claims are governed by the US Food and Drug Administration's Modernization of Cosmetics Regulation Act (MoCRA), which outlines that claims must be truthful, non-misleading, and backed by robust data, though no pre-approval is necessary.
Under no circumstances can beauty and personal care companies make medical claims.
For soft cosmetic claims like “moisturizing” or “cleansing,” designed to call out basic functioning of a product, proof is relatively straightforward. Hard claims like “reduces wrinkles by 15%” or “contains 10% vitamin C for brightening” require sturdier scientific or clinical backing from suppliers, manufacturers, and brands.
So, how easy is it for the industry to innovate, compete, and succeed while simultaneously maintaining watertight product claims?
“It is becoming increasingly challenging as the science grows more sophisticated while communication must become simpler,” explained Dr. Theresa Callaghan, cosmetic claims expert, author of two books about cosmetic claim laws, and owner of Callaghan Consulting International.
Beauty companies today need a “whole claims strategy,” Callaghan told BeautyMatter. This strategy must address the claim itself, the product, its intended consumer, the benefit to communicate, the science behind it, the regulatory context, and evidence required to genuinely substantiate the claim.
Crucially, beauty claims require a multidisciplinary approach, with input from R&D, marketing, regulatory, legal, clinical, and claims specialists, she said. “Claims development is a process, not a sentence written by marketing at the end–which is why I wrote an entire book about it.”
Dr. Carla O'Connor, Global Senior Director of Clinical Research for Deciem at The Estée Lauder Companies, agrees. “At Deciem, we've invested in a large laboratory footprint that brings all five of our labs together under one roof, including research and development, clinical research, microbiology, analytical, and stability. This allows us to collaborate across the full development journey, from initial formulation prototypes through to final-formula testing and substantiation,” O'Connor explained. Data to substantiate product claims can also come from work with suppliers and external third-party clinical research organizations, she told BeautyMatter.
Additionally, work to develop and substantiate strong claims is always cross-functional at Deciem, according to O’Connor, with R&D, clinical, legal, marketing, and scientific communications all closely involved, allowing the company to translate the science from the lab all the way to the consumer accurately and responsibly. “Each team brings a different area of expertise, and alignment between them is essential. The science needs to support the claim, the claim needs to be appropriate from a regulatory and legal perspective, and we then need to be able to translate that evidence clearly into communications that the consumer resonates with. It's a collaborative process from development through to launch and beyond,” she said.
For Deciem, O'Connor said science leads new product development work, with claims carefully considered “from the very beginning of the development journey.”
Her team starts by understanding what the ingredients are designed to do, what the available evidence suggests, and what can be realistically demonstrated in a final formula before building “rigorous proof-of-concept and substantiation work around those hypotheses.” Crucially, she said the company never relies solely on ingredient-level data, but rather the action of a final formulation.
Callaghan added that reliance on ingredient data is one area where beauty brands can fail with beauty claims, because ingredient data cannot be used to imply a finished product benefit. Other failures are often linked to marketing language that extends “beyond the endpoints actually measured,” she said.
As the beauty industry continues to innovate and technologies advance quickly, she said learnings could be taken from the pharmaceutical and food and nutrition industries where evidence hierarchies, risk communication, and the limits of scientific certainty are discussed more explicitly. “Pharmaceuticals, for example, carefully distinguish between demonstrating a biological mechanism and demonstrating a meaningful outcome. Beauty does not always make that distinction clearly enough, particularly when communicating emerging science. Food and nutrition also offers useful lessons in translating complex science into consumer-facing claims without allowing the wording to go beyond the evidence,” said Callaghan.
Translating complex science into evidence-based claims is the central challenge for any business, but there are a raft of emerging technologies and platforms set to assist and streamline this process.
Stockholm-based start-up IllustraLab, for example, creates mechanism-of-action animations that can help build understanding of product claims and science—for both internal teams and consumers. The 3D animations, developed by in-house scientists and biologists via an AI-powered production platform, are scientifically accurate for R&D and regulatory teams and visually strong for marketing and commercial use. Currently operating in beta, IllustraLab will launch globally in Q1 2027.
Felix Andersson, co-founder of IllustraLab, said the company is already working with a range of companies, from large corporates and major ingredient suppliers to smaller independent brands, delivering animations quickly and far more cheaply than traditional market rates. “Until now, scientific animation was only realistic for companies with six-figure launch budgets. Now, any brand or ingredient developer with a genuine mechanism worth showing can communicate it,” Andersson said.
On the B2B side, these animations help suppliers explain their active ingredients to formulators, R&D teams, and brand marketers, shortening the sales cycle and making the science “easier to pass along,” according to Andersson. On the consumer side, the same video, cut to a different length and tone, can be used in a retail setting or on social media to tell a brand's scientific story. “Most people can't picture the antioxidant effects of xanthines in the cells or how SPF creams deposit UV filters across the skin. A good animation makes something invisible visible, and people remember what they see far better than what they read,” he said.
This visual aspect will become an increasingly important part of future scientific storytelling, he said. “I think consumers will come to expect to see how a product works, not just be told that it does. Mechanism-of-action content will become as standard on a product page as the ingredient list.”
Andersson agrees with Callaghan that much can be learned from the pharmaceuticals industry, where a visual is treated as part of the scientific record, and accuracy and medical reviews are nonnegotiable. “Beauty doesn't need to become pharma, but it can borrow that mindset: decide exactly what you can prove, then communicate that as vividly as possible.”
Varun Sharma, founder of ingredient and formulation research group Varuné, said that its AI-powered software program Pharmoris, which runs under its pharmaceutical infrastructure and tech firm Neuvior,
is designed to bridge the gap between pharmaceutical data and human decisions, inspired the development of its formulation-led research and development venture Varuné Labs. Currently in the pre-launch stage and due to launch in April 2027, the predevelopment program will bring together formulation scientists, academic researchers, and established beauty development teams on focused research programs to inform “exceptional products and create verifiable evidence for their claims.” Initial focus will be on beauty, specifically addressing projects around skin protection, uneven skin tone, and radiance.
Varuné Labs' highly structured claims development framework should enable teams to navigate from a proposed claim to the supporting study result, as well as the exact product version tested, according to Sharma. “For scientists and developers, that would mean a shared, traceable record linking each finding to the formulation version and conditions actually tested. The aim is to make it easier to see which evidence remains relevant, where the gaps are, and how the next experiment can build on the work already done,” he said.
Working with this type of claims architecture, Sharma added, ensures that exact promises or final claims are connected to precise formulations and the evidence behind them, throughout the entire product development and iteration process.
Sarah Arana-Morton, CEO of UK claims verification platform Provenance, said this is certainly key but requires the industry to address its fundamental problem: treating claims as copy rather than data. “Claims are written for a pack or campaign and then copied across websites, retailer pages, and other channels. Over time, different versions emerge, and it becomes difficult to know which claim is current, what evidence supports it, and whether that evidence is still valid,” Arana-Morton said.
A better model, she said, would be to treat every important claim as a data point with evidence attached to it. These can then be checked, kept up to date, and distributed consistently wherever the product appears, from lab to shelf.
O'Connor said that keeping track of data throughout the entire development process also helps successful decision-making. “Formulation development is inherently iterative, and we typically work through multiple prototypes and rounds of testing before arriving at the final formula. As we optimize and scale a product, the data may show that a particular aspect of the formula needs to be refined. These learnings allow us to refine the formula and the claims we can confidently make, ultimately using the science and data to guide us toward the best possible product.”
Callaghan added that tracking claims data closely also means beauty companies can share what the evidence does not show yet, too—a move that can “strengthen credibility rather than weaken the story.”
Looking ahead, the claims expert said it will also be important to maintain claims development protocols as beauty edges further into complex areas like longevity, the microbiome, neurobiology, and personalizations. “The challenge is that the science is advancing faster than the regulatory frameworks and the claims language developed to describe it. That will make the boundary between cosmetic benefit and health or medical implications increasingly important. Whatever changes, though, the fundamental question remains the same: can you prove what the consumer is being led to believe?”
Another challenge facing the beauty industry around claims is visibility, as AI gains important ground online—a challenge Provenance is working hard to address, according to Arana-Morton. The company works with suppliers and brands to both validate claims and structure them for AI citation and distribute them wherever shoppers and AI are deciding what to buy. “A validated claim that nobody can find is essentially a compliance file sitting in a drawer,” she said.
“We're moving into what I call an evidence economy, where proof is becoming part of product discovery rather than something that sits behind the product,” the CEO said. Giving visibility to that proof, therefore, is increasingly key in today's beauty market, but it remains challenging given how fragmented evidence usually is and how fast the world of AI discovery is evolving. “AI is changing how people discover products. They're no longer just searching for the 'best moisturizer'; they're asking much more specific questions about ingredients, efficacy, values, price, and suitability. Those systems need clear, trusted, and structured information to answer those questions. If your claims aren't verified and machine-readable, you increase the chances of being overlooked—or represented inaccurately.”
Looking ahead, Arana-Morton said proof will become the minimum bar for product discovery. “That changes the role of claims,” she said, shifting them into part of the data infrastructure that allows a product to be discovered and recommended. “Claims will be treated as data: checked, evidenced, kept up to date, and shared consistently wherever a product appears. Retailers will increasingly expect suppliers to provide substantiated claims as part of their product data, and consumers will expect to be able to interrogate those claims more easily.”
Andersson believes claims will become an increasingly important part of storytelling across beauty. “The beauty industry has a lot of real science behind it, and it's often undersold because it's hard to explain, or oversold because it's easier to exaggerate. We think there's a better middle ground: tell the true story, clearly and beautifully.”
According to Callaghan, the challenge is to “simplify without distorting.” Scientific storytelling, she said, should make complex evidence understandable to consumers, but it should never make that evidence seem stronger or more certain than it really is.