Specialised Products
Vegan & Cruelty-Free Cosmetics
Compliance and claim support for vegan and cruelty-free cosmetics, including the nuance that animal testing is already banned in the EU and UK and the tension with REACH ingredient data.
Vegan and cruelty-free are two different claims, and both need handling with care because the regulatory background is more nuanced than it first appears.
Cruelty-free
Animal testing of finished cosmetics and their ingredients, and the marketing of products tested on animals, is already prohibited in the EU and UK under Article 18 of Regulation (EC) No 1223/2009. A “cruelty-free” claim therefore has to be framed so it does not imply an advantage over competitors who are equally bound by the ban, which the claims guidance treats as misleading. There is also a genuine tension where an ingredient has required animal data under REACH chemicals law, and we make sure a claim accounts for it. Certification such as Leaping Bunny is the usual route to a defensible position.
Vegan
“Vegan” has no legal definition, so it rests on substantiation: confirming the absence of animal-derived ingredients, including the ones that are easy to miss such as carmine, beeswax, lanolin, tallow derivatives, collagen and keratin. We verify the formulation and supplier documentation, and build the claim so it holds.
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 →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 must appear on a cosmetic label?
Article 19 of Regulation (EC) No 1223/2009 sets out the mandatory particulars: the Responsible Person's name and address, the nominal content, the date of minimum durability or the period-after-opening (PAO) symbol, precautions for use, the batch number, the product function, and the list of ingredients in INCI nomenclature. In Great Britain the same requirements apply through the Cosmetic Products Enforcement Regulations 2013, and since 1 January 2026 the UK Responsible Person's details must appear on the label of products sold in GB. Oxford Biosciences reviews packaging artwork against these requirements for £195.
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.