Building a cosmetic claims evidence file

Start the claims file with the exact words

A claims file is easier to review when every row identifies what the customer will actually see. Record the precise wording, the product and formula revision, the channel, the surrounding image or explanation and the proposed audience. A headline on a product page and a longer sentence on a carton can create different impressions even when they share a phrase.

The HPRA claims guidance covers packaging and promotional material, including websites and social media. It sets out common criteria and explains that stated or implied claims need evidence and should not exceed it. Use the linked requirements and current legal text for the specialist review; this register does not determine which claims your product may make.

Capture the claim in context

Give each proposed claim an identifier. Save the artwork, page copy or campaign version that contains it. Include nearby qualifiers and imagery in the review bundle. If the words are translated or shortened, record the resulting version rather than assuming an earlier decision covers it.

Separate a product statement from an ingredient statement. Evidence concerning one supplied ingredient may raise a useful research question, but its relationship to the finished formulation and the proposed wording needs to be established. A supplier brochure copied into a folder is not that explanation.

Synthetic claim CL-01: a duration claim with no matching study

Fictional cream SAMPLE-CREAM, formula 3, has proposed website wording: Moisturises for 24 hours. The only evidence listed in the sample register is a fictional ingredient brochure. No finished-product study, protocol, results or participant information has been supplied. The row therefore keeps the evidence review and specialist finding unresolved.

The sample owner must obtain the relevant evidence or put alternative wording forward for review. The guide does not approve a softened version automatically. Changing 24 hours to long lasting still creates wording that needs its own assessment in context.

Link evidence to what it can support

For each evidence item, record its author or issuer, product or material studied, method, population or test conditions where relevant, measured outcome, date and limitations. Use the actual report. Do not fill missing method or result fields from a marketing summary.

Ask the reviewer to record how the evidence relates to the proposed statement and which limitations need to remain visible. Keep consumer-perception material, instrumental results, literature and ingredient information distinguishable. A large number of files does not answer whether the particular wording is supported.

The blank register gives space for those relationships and a separate decision. Its synthetic companion demonstrates an incomplete case with no study results. Neither file is an approved list of cosmetic claims.

Keep decisions tied to versions and channels

Record the reviewer, scope, decision date and exact claim revision when review occurs. A finding about carton copy does not automatically settle a new before-and-after image or a social caption. If the formula, evidence or presentation changes, identify which earlier findings need reconsideration and preserve the old context.

Ireland/EU, GB and NI need separate applicability checks. The HPRA source is the Ireland/EU starting point; this worked example makes no GB or NI legal determination. Claims that raise a product-boundary or medical question need their own specialist route.

Use the evidence workspace to retain the actual files and an owned action to obtain what is missing. The claims hub and claim-register resource become linked next steps when reviewed and released. The useful output today is a clear evidence question with its wording and context intact.

Sources and legal dates