To the extent that consumer interest in age-defying skincare increased, so became regulatory scrutiny towards the marketing claims made about consumer products within the European Union (EU) in the year 2025. The EU reaffirmed, as has been said above, the precepts of truthfulness, substantiation, and non-misleading claims—especially in fast-growing segments like anti-aging cosmetics.
This article deals with the current EU framework for cosmetic claims focusing on anti-aging products as interpreted with reference to the Cosmetics Regulation (EC) No 1223/2009, the Common Criteria for Cosmetic Claims, and some recent guidance from Cosmetics Europe.
Per Article 2.1(a) of Regulation (EC) No 1223/2009 (Cosmetics Product Regulation, CPR), a Cosmetic products are defined as any substance or mixture intended for application to external parts of the human body (skin, hair, lips, and nails) with the intention of primarily performing a cleaning, perfuming, altering appearance, or protecting function for the person custodian of good works. Typical anti-aging creams, serums, moisturizers, or sunscreens will fall under this definition, unless, of course, they exert some pharmacological effect on the skin or body in which case they come under the definition of medicinal products.
Tip: If a product’s primary function isn’t clearly cosmetic, regulatory authorities may assess it case-by-case to determine the correct classification.
Under Article 20 of the CPR, claims made about cosmetic products—whether on packaging, in advertising, or online—must not be misleading and must be substantiated by appropriate evidence.
To further guide the industry, the European Commission introduced the Common Criteria for Cosmetic Claims, structured around six principles:
Claims shall not suggest approval by authorities for the product. Meeting legal requirements (e.g. safety) may not be claimed as a special benefit.
Any claim must conform to solid evidence that is reproducible:
“Ensure your anti-aging claims are backed with lab-verified data. Get help from our Regulatory Consulting Team.“
According to Cosmetics Europe’s Technical Document on Cosmetic Claims, the following main types of criteria for cosmetic claims are established:
Examples:
These claims demand proof via soundly designed efficacy tests or consumer-use studies.
Examples:
These conditions are acceptable only on the condition that the ingredient is there in effective concentrations, while the product is showing the benefits assumed by the consumer.
Descriptive attributes for sensorial characteristics such as, “non-greasy” or “fast absorbing” could have relied upon expert panels or trained sensory assessors.
Examples:
These These claims must have a foundation in statistically relevant consumer testing and representativeness of the target group.
Examples:
Such comparisons must be fair, factual, and representative. Refer to the guidance under the Misleading and Comparative Advertising Directive.
Terms like “eco-friendly” and “sustainable packaging”; these need to be evidenced, as well as being compliant with the EU Unfair Commercial Practices Directive.
Claims from such as “vegan,” “halal,” or “organic” must include:
Under statements, such as, “this cream makes you fly,” are acceptable where no sensible consumer would interpret the claim in a literal sense.
“Our team can help develop scientifically backed anti-aging products with regulatory compliance in mind. Explore our Cosmetic Formulation Services.”
According to Cosmetics Design Europe, anti-aging is besides being one of the fastest growth categories in skin care among the other countries. The demand profiles that both Europe’s older population and younger-generation consumers looking for” preventive” care created.
On the in-cosmetics ingredients database, there now exist:
The marketing did manage to move along with it:
EU update 2025 revision is not meant to create a rule but to continue to strengthen transparency, scientific integrity, and consumer protection. In the competitive field of anti-aging, brands that align their claims with EU regulations not only stay compliant but also build long-term consumer trust.
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