Is this the end of “free-from” claims?

An additional annex - Annex III, ‘Free from’ claims, was recently added to EC Regulation No. 655/2013. Effective July 2019, claims highlighting the absence of substances will be regulated and restricted. A big part of this change is highly relevant for preservatives. “Parabens Free” claims for example, will no longer be allowed, and “Preservatives Free” is also in question.

Read more details below, to find out how this impacts your products.


New ‘Free from’ claims restrictions:

Cosmetic product claims are governed by EU Regulation (EC No. 655/2013). This regulation provides 6 common criteria that should be followed. Basically, each claim made on the label should be substantiated.

The adoption of common criteria for cosmetic claims was the most important step of the implementation of Article 20 of the Cosmetics Regulation (CPR)[1].  Most products today contain, mostly for marketing purposes, one or more of the following categories of claims:

  • Claims characterizing ingredients or product functions (e.g. ‘anti-aging’);

  • Claims related to the product’s efficacy (e.g. ‘total block sunscreen’);

  • Claims highlighting the absence of substances (e.g. ‘fragrance free’);

  • Claims addressing skin compatibility of the product (e.g. ‘hypoallergenic’, ‘for sensitive skin’);

  • Claims addressing health or additional benefits other than the cosmetic purpose


On 3 July 2017, annex III, ‘Free from’ claims, was added to EC No. 655/2013, and should be applicable as of

1 July 2019. More details and examples found in the table below. 1 July 2019. More details and examples found in the table below.


How does it impact us?

with regards to preservatives, there are a few points to highlight:

Parabens-Free (and similar) are no longer allowed as a claim: as long as the ingredient is legal for use, this claim is forbidden.

‘Preservative free’ is no longer allowed as a claim: if until now materials with anti-microbial properties not in Annex V could be used to justify this claim (such as Caprylyl Glycol, Phenyl Propanol, and others), this is no longer the case. So, although we could continue to provide many preservative solutions which are not listed in Annex V (such as Sharomix™ CPP, CPA or Sharon™ Biomix FREE ), the claim on the packaging of the final product should be re-considered.


Table 1: ‘Free from’ claims - examples

Type of ‘Free from’ claim 



‘Free from’ + ingredient prohibited by the EU Cosmetics Regulation

E.g. ‘Heavy metals free’ 

Claims which convey the idea that a product has a specific benefit when this benefit is mere compliance with minimum legal requirements shall not be allowed. 

‘Free from’ + ingredient not supposed to be present in the product

E.g. ‘Preservative free’ (if the product is a fine fragrance containing high amounts of alcohol or bath salts, not expected to contain preservatives) 

Claims shall not attribute to the product concerning specific characteristics if similar products possess the same characteristics.

‘Free from’ + ingredients category (e.g. fragrance, preservative, colorant)

⊗/ OK if

E.g. ‘Preservative free’ is wrong if the product contains an ingredient, not in the official list of preservatives (Annex V) but having antimicrobial properties. 

E.g. ‘Fragrance free’ is wrong if the product contains an ingredient that exerts a perfuming function, regardless of its other possible functions in the product. 

This claim is acceptable except only if the product contains an ingredient having properties of this ingredients family as a side function. 

‘Free from’ + an ingredient or an ingredients family that are legally used

E.g. ‘Parabens free’ 

Claims for cosmetic products shall be objective and shall not denigrate the competitors, nor shall they denigrate ingredients legally used. 

‘Free from’ claims that allow an informed choice to a specific target group or groups of end users


E.g. ‘Free from alcohol’ in a mouthwash intended as a family product. 
or  ‘Free from animal-derived ingredients’ in Vegan products. 

Claims are an integral part of products and shall contain information allowing the average end user to make an informed choice. 



[1] Article 20 - EC Regulation 1223/2009 - In the labelling, making available on the market and advertising of cosmetic products, text, names, trademarks, pictures and figurative or other signs shall not be used to imply that these products have characteristics or functions which they do not have.
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