MASTERING THE PIP:CLAIM SUPPORT

Presented by:

Lambros Kromidas, Ph.D.

V.P., Product Integrity

Coty Inc.

Disclaimer

“The viewpoints expressed in this presentation are those of the author

and do not necessarily reflect those of EU Competent Authorities or Coty, Inc.”

Ask some simple questions about claims and give some simple answers

My view on what an effective Claim Support section should look like

Presentation: Two Parts

1

2

What Are Claims?

“…effect claimed for the cosmetic product…” (Dir. 76/768/EEC,Article 7a, 1(g).)

What Are Claims?

As per COLIPA:

“a cosmetic claim is any public information – primarily provided for marketing purposes – on the content, nature, the effect, the properties, or

the efficacy of the product.”

(Guidelines for the evaluation of the efficacy of cosmetic products. Second edition, 2001)

What Are Claims?

Claims are statements, not mandatory, made about a product on the package and advertising for the purpose of promoting the sale of that product.

These Are Not Claims.

Stating the function of the product

Cautionary/warning statements

Use instructions

Net content, expiration date, PAO, etc.

Why Are Claims Made?

Inform the Consumer

Stay Competitive

What are Some Types and Examples of Claims?

Obvious claims

“Fire Red” Lipstick

“2 in 1” Hair & Body Wash

Puffery claims

“Perfectly moisturized”

“Deliciously perfumed”

“Luxury/Serious Colour Care”

[Emotive claims]

L’Oreal (hair product) “Because I’m worth it.”

Formula/Ingredient claims

“Contains Aloe” “Contains Aloe, known to hydrate the skin” “Oil free”

Performance claims

Hypoallergenic Dermatologist Tested Ophthalmologist Tested Suitable for contact lens wearers Instantly boosts hydration levels by over X% SPF 15 In 2 weeks, consumers perceive a 74% decrease in fine lines

and wrinkles

What are Some Types and Examples of Claims?

Why Do Claims Need Substantiation?

“…proof of the effect claimed for the cosmetic product, where justified by the nature of the effect or product…” (Dir. 76/768/EEC,Article 7a, 1(g).)

All claims need to be truthful and you need to support that truth

What Types of Claims Need Substantiation and PIP Support?

SubstantiationPIP

Support

Obvious Claims NO NO

Puffery Claims NO NO

[Emotive Claims] NO NO

Formula Claims NO YES/NO

Performance Claims YES YES

What is the Role of Legal/Regulatory in Substantiating Claims?

Determine if cosmetic claims fall within the parameters of the cosmetic definition

Determine if cosmetic claims are truthful

Who is Responsible for Substantiating Claims?

Marketing

Product Development

Product Testing

Two Categories of Claims and How they are Substantiated

Subjective

Based on consumer opinion

“In 2 weeks, consumers perceive a X% decrease in fine lines and wrinkles”

“Long wearing”

Objective

Based on instrumental measurements

“Instantly boosts hydration levels by over X%”

“Biodegradable”

What Type of Claims Need to be Accounted for in the PIP?

Not advertising claims

Only claims found on the product’s packaging

but not Obvious claims,

Puffery claims,

or Emotive claims.

Formula claims

Performance claims

Thank You!