"Clean beauty" has no regulatory definition in any major market. It means what the brand using it says it means, which is why two clean products can have almost nothing in common and why retailers have filled the vacuum with their own standards.
That does not make the term useless. It makes it a commitment you define and then have to keep, and the cost of keeping it lands on the formula. This article is about which claims cost what, and which ones somebody will actually check.
It is orientation, not legal advice. Sources at the end.
Three Categories of Claim
Sorting claims this way is more useful than sorting them by how good they sound.
Regulated. Defined in law with specific requirements. Getting these wrong is a compliance problem. Efficacy claims fall here — in the EU they must satisfy the common criteria, and in the US a claim about the structure or function of the body makes the product a drug.
Certifiable. Not defined in law, but with established third-party schemes that audit against a published standard. Organic, vegan, cruelty-free and halal are the common ones. The claim is only as strong as the scheme behind it, and the audit reaches your supply chain rather than just your formula.
Self-declared. Free-from, natural, clean, sustainable. You define the meaning. Nobody grants it. And two things follow: a retailer may impose its own definition on you, and consumer protection law still applies to statements that mislead.
Most of what brands call clean beauty sits in the third category, which is where the risk is — not because it is prohibited, but because it is unbounded.
What Each Claim Actually Commits You To
Free-from
The most common clean beauty claim and the most constrained by rules you may not know about.
The EU applies specific criteria to free-from claims. Two of them catch brands regularly: a free-from claim should not denigrate an ingredient that is legally permitted and safe, and it should not be made about an ingredient that could not lawfully be in the product anyway. "Free from parabens" as a way of implying parabens are unsafe is the archetype of the first; "free from" a banned substance is the second.
There is also a supply chain consequence. A free-from claim covers the finished product, which means raw materials, processing aids and carryover from suppliers. Some raw materials arrive with a preservative in them. Verifying this is work, and it needs raw material documentation from your manufacturer — see how the formulation brief should carry exclusions from round one.
Cost: low if planned early, high if retrofitted, because substituting a preservative or an emulsifier means repeating stability and challenge testing.
Natural and naturally derived
"Natural" has no cross-market definition, and the percentage a brand claims depends entirely on the calculation method used. Two products claiming the same figure can be composed very differently.
Standards exist — ISO 16128 provides definitions and calculation methods — but using one is a choice rather than a requirement, and a claimed percentage without a stated method is not a comparable number.
Cost: moderate. Naturally derived alternatives are often more expensive, less stable, more variable batch to batch, and more likely to carry colour and odour. This is real formulation work.
Vegan and cruelty-free
Distinct claims that are frequently conflated.
Vegan means no animal-derived ingredients. Beeswax, lanolin, carmine, some glycerin and some collagens are the usual issues. In a Korean context it also touches marine-derived materials, which matters for exactly the ingredients the industry is known for — see PDRN and its salmon-derived source.
Cruelty-free means no animal testing. The EU already prohibits animal testing for cosmetics, including for ingredients, so within that market the claim is closer to a statement of compliance than a differentiator. It becomes meaningful for markets that require or permit animal testing.
Both are certifiable, and certification audits the supply chain rather than just the finished formula.
Cost: low to moderate on formulation, real on certification and documentation.
Reef-safe
Applies to sunscreen and carries a trap. There is no agreed definition, the science is contested, and it usually refers to excluding specific UV filters.
The complication is that the excluded filters are often the ones permitted in the US. Combined with sunscreen being an over-the-counter drug there rather than a cosmetic, a reef-safe US sunscreen is a narrow formulation problem. See what the US market requires.
Cost: potentially high, because it constrains the filter system, which is the hardest part of a sunscreen formula.
Sustainable and eco-friendly
The vaguest of them, and increasingly the most scrutinised. Regulators in several markets have been tightening rules on unsubstantiated environmental claims, and generic phrasing is the specific target.
Specific, verifiable statements — a stated percentage of post-consumer recycled content, a named refill system, a defined reduction — hold up. "Eco-friendly" does not.
Cost: varies enormously. Component-level changes are where the money is.
What Retailers Will Actually Check
Regulators enforce the regulated claims. Retailers enforce the self-declared ones, and this is where most brands first encounter a real audit.
Major beauty retailers publish their own clean standards: a restricted substance list, documentation requirements, sometimes testing. These lists are not identical to each other and are usually stricter than the law. A product that is legally compliant everywhere can still fail a retailer's standard.
Two practical consequences:
Ask your target retailer for its list before you formulate. Not after. Reformulating to meet a retailer standard after stability testing means repeating the testing.
Retailer lists change. A product compliant at listing can fall outside a revised standard. Keeping raw material documentation organised is what makes reformulating tractable when that happens.
Deciding What to Claim
Four questions, in order.
1. Which markets? EU claim rules are stricter than most. US classification turns on intended use. If you are selling into both, write for the stricter one — maintaining two claim sets across artwork versions is a recurring cost that rarely pays for itself.
2. Which retailers? Get their restricted substance lists before formulation.
3. What can you actually substantiate? Every claim needs support proportionate to what it asserts. Substantiation for a claimed effect belongs in your Product Information File in the EU and in your safety substantiation file under MoCRA — see what CPNP notification requires.
4. What does it cost the formula? Some exclusions are free. Some cost you stability, sensory quality or preservative robustness. A brand that excludes on principle without pricing the consequence often ships a worse product for a claim its customers were not asking for.
Then put all of it in the brief. Exclusions and claim intent are two of the six things a formulation lab needs, and discovering an exclusion at round four means discarding rounds one through three.
A Note on Honesty
The commercially strongest position in this category is usually the specific one.
"Formulated without fragrance, essential oils and drying alcohols, because it is built for reactive skin" is a better claim than "clean". It is verifiable, it explains itself, it tells a customer whether the product is for them, and no retailer will ever challenge it.
Vague claims transfer risk to you and information to nobody. Specific ones do the opposite.
Frequently Asked Questions
Is clean beauty a regulated term?
No, not in any major market. It means what the brand using it says it means. Regulators enforce efficacy and safety claims; retailers enforce their own clean standards, which are usually stricter than the law and differ between retailers. If you use the term, define what you mean by it in your own copy.
Can we say our product is paraben-free?
Usually, but check the market. The EU applies criteria to free-from claims that rule out denigrating a legally permitted, safe ingredient and rule out claiming absence of something that could not be present anyway. The claim also covers the finished product including carryover from raw materials, so it needs supplier documentation behind it rather than an assumption.
What is the difference between vegan and cruelty-free?
Vegan is about ingredients — no animal-derived materials. Cruelty-free is about testing — no animal testing. A product can be one without the other. Both are certifiable through third-party schemes, and both audits reach into the supply chain rather than stopping at the finished formula.
Does natural mean anything?
Not without a stated method. There is no cross-market legal definition, and the percentage claimed depends entirely on how it is calculated. ISO 16128 provides definitions and calculation methods, so citing a standard makes a number meaningful; a percentage on its own does not.
Should we chase a retailer's clean standard?
Only if that retailer is central to your plan, and only if you get the list before formulating. Retailer standards are stricter than the law, differ between retailers, and change over time. Reformulating to meet one after stability testing means repeating the testing, which is a cost worth avoiding by asking six months earlier.
- Regulation (EC) No 1223/2009 on cosmetic products — EUR-Lex, European Union, accessed 2026-08-06
- Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?) — U.S. Food and Drug Administration, accessed 2026-08-06
- CosIng — Cosmetic Ingredient Database — European Commission, accessed 2026-08-06
This page is general information for manufacturing planning. It is not legal or regulatory advice, it has no legal effect, and no rights can be derived from it. Requirements change by market and over time — before acting on anything here, confirm the current position with the authority concerned or with qualified counsel.