- In the US, intended use decides whether a product is a cosmetic or a drug, and claims are evidence of intended use.
- In the EU and UK, cosmetic claims must meet six common criteria, including evidential support and honesty.
- Specific, supported statements are both safer and more quotable than superlatives.
- Have a qualified reviewer approve claims for each market you sell in.
Why claims matter more in GEO
AI assistants quote and paraphrase. A sentence on your site can be repeated to thousands of shoppers, stripped of context. That makes claim wording a GEO issue as well as a regulatory one.
United States: cosmetic or drug?
The US FDA explains that whether a product is a cosmetic, a drug or both depends on its intended use, and that claims made in labelling, advertising and online are evidence of intended use. Wording such as "treats eczema" or "cures acne" can turn a cosmetic into a product regulated as a drug. Separately, the FTC expects objective advertising claims to be substantiated.
EU and UK: the six common criteria
Commission Regulation (EU) No 655/2013 sets common criteria for cosmetic claims: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. The UK applies the same criteria.
China and Korea, briefly
China's NMPA requires efficacy claims to be supported by evaluation evidence, and Korea's MFDS regulates designated functional cosmetics such as sunscreens and anti-wrinkle products. Brands selling there should check claims market by market.
A practical rewrite table
| Risky | Safer and more quotable |
|---|---|
| Cures acne | Hydrocolloid patch that absorbs fluid and covers a blemish |
| Repairs eczema skin | Fragrance-free moisturiser with ceramides, suitable for dry, sensitive skin |
| Clinically proven best serum | In a 4-week study of 32 people, 81% said skin felt smoother (consumer perception) |
| Chemical-free | Formulated without added fragrance and essential oils |
Checklist before publishing
- Is every efficacy statement backed by a test you can name (type, sample size, duration)?
- Would any sentence read as treating or preventing a disease?
- Do claims match on your site, packaging, retailers and marketplaces?
- Has someone qualified approved claims for each market?