In short: A “claim” is anything a video says or implies about what a cosmetic product does. In the EU, every claim has to meet six common criteria — legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making — and be backed by evidence before it is posted. In the US, the line is between appearance and disease: claims to treat, prevent or change how the body works turn a cosmetic into a drug. The safe path for UGC is to describe your genuine experience and to stick to the claims the brand has supplied and can support.
What counts as a claim
Words, images and even symbols can make a claim, spoken or shown. “This clears my skin”, a before-and-after split screen, a “dermatologist approved” badge and “free from” on the packaging are all claims. So are implied ones: a video that shows a blemish disappearing over a few seconds may be claiming something even if nobody says a word. The rules apply on every platform and in every format — on the pack, on the product page, in adverts and on social media.
The EU: six common criteria
EU cosmetics law prohibits claims that give a product characteristics or functions it does not have (Article 20 of Regulation (EC) No 1223/2009). Commission Regulation (EU) No 655/2013 sets out six common criteria that a claim has to satisfy at the same time:
| Criterion | What it means in plain words | What it looks like in a video |
|---|---|---|
| 1. Legal compliance | The claim cannot imply an approval the product does not have, or present something legally required of every product as a special benefit. | Avoid “approved by authorities” wording, and be careful with “free from” a substance that is banned anyway. |
| 2. Truthfulness | What is said must be true — an ingredient has to actually be present for the stated purpose. | Do not credit a product with an effect of one ingredient unless the finished product is shown to have it. |
| 3. Evidential support | Every claim, stated or implied, must be supported by adequate and verifiable evidence. | “Reduces the look of fine lines after four weeks” needs test data behind it. |
| 4. Honesty | Effects cannot be overstated, and conditions have to be stated. | If a result needs weeks of daily use, do not show it as instant. |
| 5. Fairness | Objective, not denigrating competitors or lawful ingredients. | Avoid “chemical-free” and attacks on other products or ingredients. |
| 6. Informed decisions | Clear and understandable to the average consumer. | Plain language over jargon that hides what is really being said. |
A useful guide describes examples of problem claims: “hypoallergenic” without supporting scientific data, “prevents allergic reactions”, “chemical-free” (every cosmetic contains chemicals), “free from” an ingredient that was already banned, and “not tested on animals” (redundant in the EU, where animal testing for cosmetics has been banned since 2013). A claim backed by documented consumer or clinical testing, such as “reduces visible wrinkles after 4 weeks”, can be acceptable.
Who is responsible
The manufacturer or importer named on the label is normally the responsible person for the product and its claims, including their wording and substantiation. The documentation must exist before a claim is used — it cannot be assembled after the video is posted. There is an important twist for UGC: if a distributor or an influencer partner itself changes or adds a claim, it can become responsible for that new claim, and a brand that asks creators for effects it cannot document takes on independent liability of its own.
The US: appearance versus disease
US law defines cosmetics by what they are intended to do — cleanse, beautify, promote attractiveness or alter appearance. A claim about treating disease or affecting the body’s structure or function can turn the same product into a drug, and the classification depends on the claims made, not only on the formula. Examples given in a legal commentary of claims that are drug claims include “combat eczema”, “treats blemishes”, “stimulates new skin cell production; increases collagen” and “anti-inflammatory and anti-bacterial”. On top of that, the FTC tells influencers not to make unsubstantiated health or scientific claims, and not to endorse products they have not tried.
Safer ways to say what you saw
| Avoid | Say instead (only if true) |
|---|---|
| “This cured my acne.” | “I used it every evening for three weeks. This is how my skin looked and felt to me.” |
| “Clears breakouts in 24 hours.” | “This is my routine, and this is how it went for me.” |
| “100% natural and chemical-free.” | Read out the ingredient list the brand supplied, without adding benefits. |
| “Works on everyone.” | “I have combination skin, and this is what I noticed.” |
One caution: describing something as “my experience” does not by itself make an unsupported claim safe if a viewer would take it as a promise about the product. Keep it to what you genuinely saw, and do not go beyond the claims the brand has given you.
Before-and-after footage
A before-and-after can be legitimate, but it is where most problems arise. Use footage that is genuine, unfiltered and shot in the same light, angle and distance. Do not edit the result to look better than it was, and do not present it as what every viewer will get. Guides also recommend keeping before-and-after formats natural rather than contrived, and stating realistic timelines — which for skincare are usually weeks, not seconds.
Checklist for brands
- Give creators the list of claims they may make — and the ones they may not.
- Keep the supporting evidence on file before the video goes live.
- Do not ask a creator for a claim your product page does not make.
- Put the do’s and don’ts in the brief.
- Review each submission against those claims before you approve it.
Checklist for creators
- Say only what you experienced and what the brand supplied.
- Avoid cure, treat, clear, prevent, detox and other medical-sounding words.
- Do not add benefits or ingredients that are not on the pack.
- Keep before-and-after footage genuine and unfiltered.
- Label paid or gifted posts as advertising (UGC disclosure rules).
On Usicri
Under section 4 of the Terms of Service, brands must give creators accurate, lawful product information and must not ask for claims that are false or not allowed for the product — for example, health or medical claims for cosmetics and personal-care products — and creators must not add claims the brand has not supplied. Usicri does not check videos or campaigns for compliance with advertising law before they are approved or published, so each side has to do that check itself. More ideas for what to show instead are in UGC video ideas and hooks for beauty and fashion.