Although the terms “natural” and “organic” are not defined under EU cosmetics legislation, cosmetic products making these claims should follow the principles and calculation methods set out in ISO 16128-1 and ISO 16128-2.
Consumer demand continues to grow
Demand for more sustainable cosmetic products continues to increase. Consumers are paying closer attention to ingredient sourcing, environmental impact, packaging and manufacturing practices. Many actively look for products promoted as natural, organic, plant-based or environmentally friendly.
As a result, cosmetic brands are increasingly incorporating these claims into their product positioning. At the same time, regulators are placing greater emphasis on ensuring that environmental and sustainability claims are accurate, transparent and properly substantiated.
One of the questions we are regularly asked is: When can a cosmetic product legitimately be marketed as natural or organic?
Natural and organic are not legally defined under the EU Cosmetics Regulation
Unlike food, there is currently no specific EU legislation defining when a cosmetic product may be described as natural or organic.
Several certification organisations have developed their own standards and certification schemes. While these schemes can provide useful guidance, they are voluntary and each applies its own criteria. As a result, products carrying similar claims may meet different requirements, which can create confusion for consumers.
The European Commission has previously recognised that differing definitions may result in misleading or unfair information if claims are not sufficiently substantiated.
ISO 16128 provides the recognised framework
To improve consistency, the International Organization for Standardization (ISO) published ISO 16128-1 and ISO 16128-2, providing internationally recognised guidelines for natural and organic cosmetic ingredients and products.
The standards describe methods for calculating natural origin and organic indices for ingredients and finished cosmetic products. Although ISO 16128 is not legally binding, it has become the most widely accepted reference for substantiating natural and organic cosmetic claims.
Companies choosing to communicate these claims should ensure they apply the methodology consistently and retain the necessary supporting documentation.
Claims must always be substantiated
Natural and organic claims are also subject to the general requirements for cosmetic claims under Regulation (EU) No 655/2013, which establishes the common criteria for cosmetic claims. Claims must be truthful, supported by adequate evidence and must not mislead consumers.
More broadly, the EU continues to strengthen the rules governing environmental marketing claims. Cosmetic companies should therefore ensure that any sustainability, natural or organic claims are supported by reliable documentation and remain aligned with current regulatory expectations.
Conclusion
Natural and organic cosmetic claims remain an important way to communicate product characteristics to consumers. However, because these terms are not specifically defined under EU cosmetics legislation, companies should apply them carefully and ensure they are properly substantiated.
Following ISO 16128-1 and ISO 16128-2, together with the cosmetic claims criteria under Regulation (EU) No 655/2013, provides the strongest foundation for making credible natural and organic claims.
If you would like to review your product claims or discuss how to substantiate natural or organic marketing claims, our regulatory specialists are happy to help.
