Specialised Products
Natural & Organic Cosmetics
Compliance and claim substantiation for natural and organic cosmetics. There is no legal definition of natural or organic in EU or UK cosmetic law, so the claim has to be earned, and the preservation has to hold.
There is no statutory definition of “natural” or “organic” for cosmetics in EU or UK law, which is exactly why these claims attract scrutiny. The product still has to be safe and the claim still has to be true.
Substantiating the claim
Two things govern a natural or organic claim. The first is the claims framework: Article 20 of Regulation (EC) No 1223/2009 and Commission Regulation (EU) No 655/2013, with the technical guidance on “free from” and other claim types, which means a claim cannot mislead, denigrate or imply a benefit the product does not have. The second is the voluntary standards the market actually recognises: ISO 16128 for the technical definitions and calculation of natural and organic content, and the certification schemes such as COSMOS and NATRUE. We assess the claim against both, so it survives a Trading Standards challenge.
Preservation is the hidden problem
Natural-leaning formulations often rely on weaker or more limited preservative systems, which makes microbiological safety the real risk. We confirm the system with preservative efficacy testing to ISO 11930 before the claim ever reaches a label, because a “natural” product that fails a challenge test is not saleable.
Relevant services
CPSR
From £70 · 2 to 3 days
The Cosmetic Product Safety Report is the safety assessment required under Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product may be placed on the UK or EU market. Prepared and signed by a qualified safety assessor.
Learn more →Labelling
From £195 · from receipt of artwork
Independent review of packaging artwork against Article 19, and of product claims against the six Common Criteria of Regulation (EU) 655/2013. Label review £195; per-claim review from £125; substantiation dossiers from £1,495.
Learn more →Testing
From £75
Stability, microbiology, photoprotection and analytical testing carried out in our three in-house laboratories. Analytical work is not contracted out; results pass directly to the assessor preparing your CPSR.
Learn more →Frequently asked questions
How are cosmetic claims regulated?
Cosmetic claims are regulated as statements of fact, not marketing copy. Article 20 of Regulation (EC) No 1223/2009 and Commission Regulation (EU) No 655/2013 establish six Common Criteria that every claim must meet: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. Evidence must exist before a claim is published and remain on file. Oxford Biosciences reviews claims per claim (£125, minimum five) and prepares formal Claims Substantiation Dossiers suitable for the Product Information File and for production to a competent authority or the Advertising Standards Authority.
What is a CPSR?
A Cosmetic Product Safety Report (CPSR) is the safety assessment required by Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product is placed on the UK or EU market. Annex I sets out two parts: Part A, the cosmetic product safety information (composition, physico-chemical and microbiological characteristics, stability, exposure and the toxicological profile of each substance), and Part B, the safety assessment, in which a qualified assessor states and reasons the conclusion on safety. It is the pivotal scientific document held within the Product Information File.
What is a Preservative Efficacy Test (challenge test)?
A Preservative Efficacy Test, also called a challenge test, demonstrates that a product's preservative system controls microbial growth across its life. Oxford Biosciences performs it to ISO 11930 for £165: the product is inoculated with the five specified challenge organisms (Staphylococcus aureus, Escherichia coli, Pseudomonas aeruginosa, Candida albicans and Aspergillus brasiliensis), and viable counts are enumerated over a 28-day window against the Criterion A or B log-reduction thresholds. Typical turnaround is six weeks, reflecting the protocol duration plus enumeration and reporting.