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The French DGCCRF’s and ANSM’s recommendations on "Free from” claims on cosmetic products


Aug 06, 2023

The French General Directorate for Competition, Consumer Affairs and Fraud Prevention (DGCCRF) and the National Agency for the Safety of Medicines and Health Products (ANSM) have given the recommendations on compliance with the provisions of the Regulation (EU) No. 655/2013 of July 10, 2013 laying down common criteria for the justification of claims used in relation to cosmetic products, when using "free from" claims. Different types of “free from” claims have been analyzed with regard to the criteria of the Regulation (EU) No. 655/2013 and accompanied by examples and useful questions to decide on the legality of their use.

  1. Claims “free from [prohibited substance]" or  “without [name of substance]” "when the substance is prohibited by regulation are against the criterion  1.3 of the Regulation  655/2013 “compliance with legislation” and are therefore not admissible (for example: “ without corticosteroids ”). The same applies to claims highlighting characteristics that are actually imposed by the regulations. for example: “ not tested on animals ”.
  2. Unverifiable “no…” claims are contrary to criteria “truthfulness” and “probative elements” of Regulation 655/2013. This is particularly the case for the claim “ without endocrine disruptors ”, because there is no official definition of what an endocrine disruptor is. Likewise, the “allergen-free ” claim (in the sense of the 26 perfume substances recognized as allergenic listed by the regulations) is potentially misleading because it is unverifiable, given the fact that any substance is a potential allergen. On the other hand, “ hypoallergenic ” is acceptable, provided that the product has been designed to minimize its allergenic potential, and that proof of this is provided by the person responsible.
  3. Claims “free from [regulated/ authorised substance name but subject to controversies]” should be avoided if the absence of these substances is clearly visible in the ingredients list. For example: “paraffin-free”, “sodium laureth sulphate-free”.
  4. Claims “free from [group or family of substances, some of which are prohibited and others authorized]”. A claim must be withdrawn when it relates to a chemical family of substances, some of which are prohibited and others authorized, so as not to create unfounded fear or confusion, according to criterion “fairness » of Regulation 655/2013, with regard to products which contain authorized substances. For example: the claim “ paraben-free ” (parabens being a chemical family of substances, of which those which are harmful have been banned), but also “ phthalate-free ” and “ nanomaterial-free ”(phthalates and nanomaterials. being for some prohibited, for others authorized, the latter being also identifiable in the INCI list when they are present in a product). Furthermore: "free from titanium dioxide" would cause confusion, given that this substance can be authorized or prohibited depending on its form (nano or not) or its purpose (UV filter or dye). The claim “ without aluminum salts ” should be banned from deodorants clearly identified as such which by definition do not have antiperspirant activity. On the other hand, in antiperspirants, or antiperspirants, this claim could be tolerated provided that the antiperspirant activity is maintained. 
  5. Certain "free from..." claims may be acceptable when they provide useful information to people who, given their particular health problems or their lifestyle or their convictions, wish to avoid a substance or a category of substances. This usefulness is reinforced when these substances are difficult to identify by reading ingredients list. For example: “alcohol-free” “GMO-free”, “free of ingredients/substances of animal origin” (equivalent of vegan or vegan), “preservatives free”,  "without sulfated surfactants”, “ without silicones ” or “ without mineral or synthetic oils ”.


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