Natural, Organic and Chemical Free: How Cosmetic Claims Are Judged in a Cosmetic Product Safety Report

Natural and organic are the oldest claims in the category and two of the least defined. Neither appears with a definition in Regulation (EC) No 1223/2009 or in the UK regulation enforced through the Cosmetic Products Enforcement Regulations 2013, which means a brand may use them and must then be ready to say exactly what it meant and prove it. The test comes from Regulation (EU) No 655/2013 and its technical document, applied by the safety assessor when the draft artwork reaches the Cosmetic Product Safety Report, and by the Advertising Standards Authority if a complaint follows. This article sets out how each claim in the family is judged and what evidence makes it stand.

It covers what natural can legitimately mean and how ISO 16128 turns it into a number, what organic requires and why certification is the practical route, how plant based and derived from nature differ from both, why chemical free is refused in every case, how the assessor handles a hero botanical at a garnish level, the safety implication brands most often get wrong, the certifications that can be verified and how, a worked example of a range whose claims were rewritten in an afternoon, and how to write natural claims that survive a Cosmetic Product Safety Report and an ASA complaint.

What can natural legitimately mean?

Whatever the brand defines it to mean, provided the definition is stated, the product meets it, and the claim does not mislead. That is a genuine freedom and most brands waste it. The strongest approach is a calculated percentage: ISO 16128 provides a method for determining the natural, natural origin, organic and organic origin content of cosmetic ingredients and products, producing an index a brand can state and an assessor can check against the formula. A claim such as 98 percent of ingredients of natural origin, calculated under ISO 16128, is specific, evidenced and checkable. A claim of simply natural on a product whose first five ingredients include synthetic emulsifiers and silicones is contradicted by its own label. The middle ground, natural inspired or with natural ingredients, is weaker but at least honest, and derived from nature is acceptable where the derivation is real and the phrase is not used to imply superiority.

What does organic require?

More than natural, because organic refers to agricultural production and certification schemes exist for it. In practice an organic claim on a cosmetic needs one of two things: certification of the finished product to a standard such as COSMOS Organic, which sets minimum organic content and processing rules and lists certified products on a public register, or a stated percentage of certified organic ingredients with the certification of those ingredients evidenced in the file. What does not work is calling a product organic because it contains an organic extract at 0.1 percent, or because the brand's philosophy is organic. The assessor checks the claim against the formula and the evidence: if the file shows one certified ingredient near the bottom of the list, the supportable claim is that the product contains an organic ingredient, and even that should name which.

How are the claims in this family ranked?

Why is chemical free always refused?

Because it is factually untrue in every case. Water is a chemical, so is glycerin, so is every plant oil and every botanical extract, and a product genuinely free of chemicals would be an empty container. The claim fails the truthfulness criterion outright and no safety assessor can pass it. Brands reach for it to communicate an absence of synthetics, which is a legitimate thing to want to say, and the honest version is a positive statement: formulated with plant derived emollients and a preservative approved for natural cosmetics, for example, or a natural origin percentage. Free from synthetic chemicals is barely better, because it still implies that synthetic ingredients are inherently unsafe, which fails the fairness criterion and is not supported by the toxicology. These are exactly the kind of cosmetic product claims that the technical document on common claims was written to address, and the six common criteria set out in Regulation (EU) No 655/2013 are the test any claim like this has to pass.

How does the assessor handle a hero botanical at a garnish level?

By checking that the claim is proportionate to the level. A botanical listed after the preservative is present at a fraction of a percent, and the claim it supports is that the product contains it, not that the product is powered by it or that the botanical is doing the work. This is the most common correction we make to natural marketing: the front of pack promises an ingredient that Part A shows at 0.05 percent. The remedy is usually to raise the level if the ingredient is genuinely functional, or to reword. The ingredient list itself is public, so an unsupported hero claim is visible to any consumer who turns the box over, which is also how competitors and journalists find them. This proportionality principle applies just as much to efficacy claims as to ingredient claims, and it's what lets consumers reach informed decisions about cosmetic products rather than being misled by front of pack messaging. Our article on how a CPSR exposes greenwashing covers the wider claims check.

The safety implication brands get wrong

Natural claims may describe origin. They may not imply that the product is safer, gentler or better tolerated because its ingredients are natural, because the assessment does not work that way. A Cosmetic Product Safety Report profiles every ingredient regardless of origin, and several of the most potent skin sensitisers in cosmetics are natural essential oil constituents, which is why fragrance allergen labelling exists and why the expanded EU list from July 2026 includes essential oils in their own right. The Scientific Committee on Consumer Safety evaluates natural and synthetic materials by identical methods. A brand that says natural and therefore gentle has made a safety claim it cannot evidence, and one that an assessor will strike. The level of evidence required for a claim like this is the same as for any other safety related statement under the cosmetics regulation, and it is ultimately the Responsible Person who carries the risk if product safety is misrepresented through an unsupported claim. Our article on clean beauty and the CPSR sets out the margin of safety reasoning behind this.

Do natural claims travel between markets?

Not automatically, and it catches exporting brands. The common criteria apply in the UK and EU and the evidence you hold satisfies both, but other markets treat these words differently. The United States has no federal definition of natural or organic for cosmetics, although the USDA organic programme covers products meeting agricultural standards and the Federal Trade Commission polices deceptive claims, so a claim lawful here may attract a different challenge there. Several ASEAN and Gulf markets follow EU style claim rules, so the same evidence generally serves. Certification schemes are the most portable of all, because a COSMOS or NATRUE listing is recognised internationally and needs no reinterpretation. The practical advice for a brand selling in several markets is to build the claim on a calculation or a certification rather than on a phrase, because a number and a certificate translate and an impression does not.

Which certifications can be verified?

COSMOS, operated through Soil Association, Ecocert, BDIH, Cosmebio and ICEA, certifies natural and organic cosmetics to a published standard and lists certified products. Soil Association and Ecocert publish searchable databases. NATRUE operates its own standard with a register. An assessor accepts a certification as evidence when the product appears on the relevant register, and treats a logo with no scheme or no register as a claim with no evidence. Certified natural, with no scheme named, is the commonest version of this failure. Certification is not obligatory, and plenty of excellent natural brands choose not to certify because of cost or formulation constraints; those brands should use a calculated percentage instead, which is free to produce and equally checkable.

A worked example: a range rewritten in an afternoon

A five product natural skincare range arrives for assessment with artwork claiming 100 percent natural, chemical free, organic and powered by rosehip. Part A shows a phenoxyethanol preserved system, one certified organic rosehip oil at 0.8 percent in two products and absent from the other three, and natural origin content between 82 and 94 percent by ISO 16128. The assessor's corrections take one afternoon. 100 percent natural is refused, because the preservative is synthetic, and becomes a stated natural origin percentage per product. Chemical free is refused and deleted. Organic is refused as a product claim and becomes with certified organic rosehip oil on the two products that contain it. Powered by rosehip becomes with rosehip oil, or, for the product where the brand raises the level to five percent, remains as a fuller claim supported by the new level. The brand ends with claims that are more specific, more credible and fully evidenced, and its ingredient list now agrees with its front of pack. The formula changed in one product only.

What about natural preservation?

This is where natural ranges most often meet the limits of the claim, and it deserves its own note. Annex V is a positive list: only the preservatives it names may be used as preservatives in cosmetics, and the list is the same whatever a product calls itself. Several Annex V entries are acceptable to natural standards such as COSMOS, which is how certified natural products are preserved, but the choice is narrower and many of the options work only within a defined pH range. A brand claiming 100 percent natural on a preserved water based product is usually claiming something its preservative contradicts. Two further traps recur. Ingredients marketed as natural alternatives to preservatives, such as certain ferment filtrates and radish root derivatives, are not listed in Annex V and cannot be relied on as the preservative system, whatever their antimicrobial activity; the assessor will require a challenge test and, if it fails, a listed preservative. And self preserving claims for water based products need the challenge test result to back them, not a formulation theory. Our article on clean beauty and the CPSR covers the underlying safety reasoning.

How to write natural claims that survive

• State a number and a method. 98 percent natural origin, calculated under ISO 16128.
• Certify if you can, and use the logo only for listed products.
• Name the organic ingredient rather than calling the product organic.
• Keep hero claims proportionate to the level in the formula.
• Never write chemical free, and avoid free from synthetics.
• Never imply that natural means safer or gentler.
• Put the calculation, certificates and supplier declarations in the Product Information File claims table.
• Send artwork to the assessor before print.

Myths we hear

•    Natural has a legal definition. It does not; you supply one.
•    Organic extract makes a product organic. It supports contains an organic ingredient, and the ingredient should be named.
•    Chemical free is just shorthand. It is factually untrue and fails the truthfulness criterion.
•    Natural products are gentler. Several natural constituents are among the strongest sensitisers in cosmetics.
•    Certification is the only way to claim natural. A calculated ISO 16128 percentage is free and equally checkable.

What to do this week

•    List every natural, organic and plant based claim across your range. 
•    Calculate a natural origin percentage for each product. 
•    Check any certification logo against its public register. 
•    Delete chemical free and any claim implying natural means safer. 
•    Put the calculations in the claims table before the next print run. 
Natural claims are not the problem; vague natural claims are. A number or a certificate turns a word that invites a complaint into a statement that survives one, and the Cosmetic Product Safety Report is where that conversion should happen.

Related reading on the Spectra blog

•    How a Cosmetic Product Safety Report exposes greenwashing
•    Clean beauty and the Cosmetic Product Safety Report
•    Who should prepare your Cosmetic Product Safety Report?
•    All Spectra articles

Spectra services mentioned in this article

•    The Complete Compliance Pack: CPSR, PIF, SDS and SCPN or CPNP (£295)
•    CPSR services by product type
•    PIF services
•    UK and EU Responsible Person
•    UK SCPN Product Notification (from £15)
•    EU CPNP Product Notification
•    Contact Spectra

Official sources and legislation

•    Regulation (EU) No 655/2013 on cosmetic claims
•    Advertising Standards Authority
•    Scientific Committee on Consumer Safety (SCCS)
•    Regulation (EC) No 1223/2009 on cosmetic products
•    OPSS guidance on cosmetic products regulations

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.