New regulations for "free from" claims in EU

Many products have texts and labels that inform consumers about what the product does not contain, so-called "Free from" claims. This type of claim has been under investigation by the EU and recently a technical document, an indicative guideline for product claims of cosmetic products, was released. The Swedish Medical Products Agency (Läkemedelsverket) has now provided information that they see this technical document as a requirement and will use it when inspecting cosmetic products and its labeling. The document will be valid from July 1st, 2019, and will be valid throughout the whole EU.


The document addresses a general view of product claim evidence, but also a number of specific claims, those that are most common. In short, the following is stated regarding "free from" claims:


- It is forbidden to write "free from substances prohibited by law". This is something you can not clarify or state as it is a prerequisite to follow the law in order to be allowed to release the product on the market. “Not tested on animals” /Cruelty free is one such example as products in the EU are not allowed to be tested on animals by law.


- It is forbidden to write "free from a particular commodity/all categories of commodities considered safe in accordance with legislation". F.ex free from parabens. It has been found that parabens are safe for use in cosmetic products if they meet strict restrictions, which is a prerequisite for releasing the product on the market.


- Free from preservatives – this is considered ok, however, one must prove that none of the ingredients contain any preservative substances. The product should be completely free from preservatives.

- Free from perfume – considered ok if you have proof that the product is completely free from perfume. Products with this claim may not contain essential oils with fragrances or contain an ingredient that has a perfuming function in the product, regardless of its other possible features in the product.


In terms of "free from perfume" claims, authorities have chosen to approve this because a large number of people are allergic to perfumes. It is therefore considered to be an information choice for end users. However, if the scent of a product is made with, for example, essential oils, "perfume" must be included in the table of contents.

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