Beauty Claims on Dietary Supplements: What Regulation Says
Le 13 January 2025
Case Study: Dietary Supplement for Skin Beauty
Regulatory Context
Promises related to beauty and skin health on dietary supplements must comply with Regulation (EC) No 1924/2006.
📌 Only authorized or tolerated claims can be used.
📌 Scientific evidence is essential to justify any claim about skin elasticity or wrinkle reduction.
Case Study: Claims “Improves Skin Elasticity” and “Reduces Wrinkles”
Problem
A company wishes to promote a dietary supplement with the following claims:
✔️ « Improves skin elasticity »
✔️ « Reduces wrinkles »
Conforming Elements
✔️ Réflexion pendant 32 secondes
Beauty Claims on Dietary Supplements: What Regulation Says
Case Study: Dietary Supplement for Skin Beauty
Regulatory Context
Promises related to beauty and skin health on dietary supplements must comply with Regulation (EC) No 1924/2006. 📌 Only authorized or tolerated claims can be used. 📌 Scientific evidence is essential to justify any claim about skin elasticity or wrinkle reduction.
Case Study: Claims “Improves Skin Elasticity” and “Reduces Wrinkles”
Problem
A company wishes to promote a dietary supplement with the following claims: ✔️ “Improves skin elasticity” ✔️ “Reduces wrinkles”
Conforming Elements
✔️ If the supplement contains ingredients with validated claims, such as:
- Vitamin C : « Contributes to the normal formation of collagen to ensure normal skin function.»
- Zinc : « Contributes to maintaining normal skin. »
- Hydrolyzed collagen : requires specific scientific evidence validated by authorities.
Potential Problems
❌ If no solid scientific evidence accompanies the claims, they may be deemed misleading.
❌ The mention “reduces wrinkles” is a strong claim that requires clinical studies to be acceptable.
Recommended Correction
✔️ Modify the claim to align with EFSA-validated formulation (e.g., “contributes to maintaining skin” instead of “reduces wrinkles”).
✔️ Have a scientific dossier proving the product’s efficacy in case of inspection.
✔️ Associate claims with specific ingredients, specifying the doses used.
Why This Correction ?
In the absence of compliance :
- The product may be reclassified as a medicine, requiring marketing authorization (MA).
- The company risks sanctions for misleading advertising.
- The labeling may be refused in case of inspection by authorities.
Conclusion
Beauty claims on dietary supplements must be rigorously justified and comply with regulatory texts. Ensure you have solid scientific evidence to avoid any legal risk.
Frequently Asked Questions about Beauty Claims on Dietary Supplements
What type of communication do the requirements of Regulation 1924/2006 relating to nutritional and health claims apply to?
Regulation 1924/2006 specifies that it applies to claims made in commercial communications, whether they appear on labeling or the presentation/advertising of food products (including dietary supplements) as long as the product is intended to be provided as such to the end consumer.
Thus, any communication around a brand or a food product is subject to the requirements of Regulation 1924/2006, whether it is intended for the end consumer (labeling, advertising, catalog, mailing, posters…) or for a health professional.
Is it possible to authorize a new health claim?
Yes, a manufacturer wishing to use a health claim to communicate on the beneficial effect of its product or one of its ingredients on health can request authorization for a new health claim if it is not included in the list of authorized or tolerated claims. In this case, they must submit a claim application dossier to the European Commission for a scientific evaluation of the provided evidence, which will be carried out by EFSA (European Food Safety Authority) within a minimum period of 5 months. If the evaluation is favorable, a European regulation is published to authorize this new health claim.
Is there a list of usable claims?
Yes, there is a list of authorized nutritional claims as well as a list of authorized health claims to be used on labeling or any other communication medium associated with a food product or a dietary supplement. Additionally, there is also a list of unauthorized health claims, as well as a list of so-called “tolerated” health claims, which concerns almost exclusively plants.