Substantiating Anti-Ageing and Brightening Claims

What anti-ageing and brightening claims actually mean under cosmetic regulation, the principle of proportionate evidence, and how each kind of claim is measured and proven.

Written by Allison Wild, Clinical Pharmacologist, MSc (University of Oxford)

Anti-ageing and brightening are two of the most commercially valuable claim areas in cosmetics, and two of the most scrutinised. A claim is a statement of fact in regulatory terms, and the evidence has to exist before it is published. This guide explains what these claims mean within cosmetic scope and how each is proven.

The evidence must be proportionate to the claim

The framework is Article 20 of Regulation (EC) No 1223/2009, the six Common Criteria of Commission Regulation (EU) No 655/2013, and the European Commission Technical Document on Cosmetic Claims. The same Common Criteria apply in Great Britain through the UK Cosmetic Products Enforcement Regulations 2013, with advertising overseen by the Advertising Standards Authority and broadcast claims pre-cleared by Clearcast.

The governing principle is proportionality. A precise, quantified claim such as a percentage reduction in wrinkle depth requires instrumental measurement on a panel. A softer “appearance of” claim can often rest on expert grading or validated self-assessment. The stronger and more specific the claim, the stronger the evidence it needs.

Staying on the cosmetic side of the line

Both claim areas must stay within cosmetic function, the improvement of appearance. Wording that implies treating a medical condition, acting as a medicinal depigmenting agent, or permanently altering skin physiology can reclassify the product as a medicine, a different and far stricter regime. “Reduces the appearance of dark spots” is a cosmetic claim; “treats hyperpigmentation” is not.

Measuring anti-ageing claims

Anti-ageing is an umbrella that breaks into separately measurable strands. Wrinkles and fine lines are measured by three-dimensional skin topography, profilometry of silicone replicas, standardised photography with image analysis, and expert grading on validated scales. Firmness and elasticity are measured by Cutometer suction-deformation. Texture, pores and skin density are measured by imaging and high-frequency ultrasound. Hydration, which plumps fine lines, is measured by corneometer and the barrier by tewameter. Each strand carries its own claims, and the method follows the wording.

Measuring brightening claims

Brightening splits into two strands that are often confused. Reducing the appearance of dark spots and uneven tone is measured by reflectance spectrophotometry (the Melanin Index), tristimulus colorimetry, polarised and ultraviolet photography, and expert grading. Radiance and luminosity, the “glow” of reduced dullness, are measured by colorimetry through the L* value and the Individual Typology Angle, and by expert assessment. A consumer self-assessment questionnaire can support “users agreed” claims alongside the instrumental data.

Turning this into evidence

Most brands start by establishing which of their intended claims are reasonably substantiable, then build the evidence around those. Where the claim is softer, a documentary claims review against the Common Criteria may be enough. Where it is quantified or destined for advertising, it needs a clinical efficacy study on a powered panel. The starting point is always the exact wording of the claim and where it will appear.