How Does a Cosmetic Product Safety Report Expose Greenwashing? The CPSR Claims Check Consumers Never See

There is a moment in almost every assessment when the formula and the marketing meet. The ingredient list arrives with water, a synthetic emollient and a silicone at the top and a botanical extract at position eleven, and the draft label says plant powered, clean and free from nasties. The safety assessor is the only person in the chain who sees both documents at once, and that is why the Cosmetic Product Safety Report is the place greenwashing tends to die. Regulation (EC) No 1223/2009 requires the safety report and the Product Information File; Regulation (EU) No 655/2013 sets six common criteria every cosmetic claim must meet; the Green Claims Code and the Advertising Standards Authority govern environmental claims on top of that; and the Cosmetic Products Enforcement Regulations 2013 give Trading Standards the power to ask for the evidence.

This article opens the report. It explains where claims actually sit inside a Cosmetic Product Safety Report and what the assessor does with them, sets out the six common criteria in the words an assessor uses, walks through the green claims that are refused most often and why, explains the claims table that the Product Information File must hold, shows how the ingredient list is used as the truth test, covers the certifications that can be verified and the ones that cannot, gives consumers a ten question version of the same check, works through one product page taken apart in the order an assessor would take it, and tells brands how to make green claims that survive both the CPSR and a Trading Standards request. If you sell cosmetics, this is the conversation you will have with your assessor. Better to have it before the labels are printed.

Where do claims sit inside a Cosmetic Product Safety Report?

In three places, and they reinforce each other. Part A section 1 records the full quantitative composition, so the assessor knows exactly what is in the product and at what level, which no consumer and few retailers ever see. Part A section 10 covers information on the finished product, including the claims made for it and any data supporting them, so the marketing enters the safety file rather than sitting beside it. Part B then draws the conclusion and sets conditions and warnings, and an assessor who finds a claim inconsistent with the assessment says so there. Around the report, the Product Information File must contain proof of the effect claimed where the nature of the claim justifies it, which in practice means a claims table with a row for every statement and a reference to the evidence. Together these turn marketing from an opinion into a documented position.

What are the six criteria every claim must meet?

These criteria are not guidance; they are the legal test applied to every claim on a cosmetic in the UK and EU, and the technical document behind them addresses free from and hypoallergenic claims specifically. An assessor preparing a Cosmetic Product Safety Report applies them to the draft artwork as a matter of routine.

Which green claims does an assessor refuse most often?

• Chemical free. Fails truthfulness. Every ingredient is a chemical, water included.
• Non toxic. Fails fairness and informed decision making. Every lawful cosmetic ingredient is assessed as safe at its level of use, so the claim describes all of them and slanders the rest.
• Free from parabens, sulfates, silicones or nasties. Fails fairness where it implies a lawful ingredient is unsafe. Fragrance free for a sensitive skin product is the acceptable kind of absence claim, because it gives useful information.
• Natural or 100 percent natural where the formula is not. Fails truthfulness. A percentage calculated by a stated method is the compliant form.
• Organic without certification or a stated percentage. Fails evidential support.
• Biodegradable or recyclable with no conditions. Fails honesty and informed decision making, and sits under the Green Claims Code as well.
• Sustainable, eco, green or conscious with no definition. Fails informed decision making.Comparatives without a comparator. Greener, cleaner, better; fails evidential support.

What is the claims table, and why does it decide everything?

The claims table is a simple document with one row per claim and columns for the claim as worded, the type of claim, the evidence relied on, where that evidence is held and the date it was reviewed. It is kept in the Product Information File, which the Responsible Person must make available to the authorities at the address on the label. Its discipline is brutal and useful: a claim with no evidence has an empty row, and an empty row is a claim to delete. Spectra builds a claims table as part of every Product Information File, and the table is the first thing we ask for when a brand comes to us after a Trading Standards letter, because it is the first thing an officer asks for. A brand with a complete table answers an enquiry in an afternoon; a brand without one spends a month assembling evidence for claims it may not be able to keep.

How does the assessor use the ingredient list as a truth test?

The label ingredient list is built from the formula in descending order of weight down to one percent, so the first five or six names are most of the product and cannot be argued with. When the front of a pack says plant powered and the list opens with Aqua, Cetearyl Alcohol, Dimethicone and Isopropyl Myristate with the first botanical at position eleven, the claim is contradicted by the brand's own label. When a pack says organic and no ingredient carries an organic marker, the same is true. When a pack says gentle and fragrance free and the list contains Parfum followed by four declared allergens, the claim is false. The assessor does not need to test anything to reach these conclusions; the two documents are enough. This is also why a consumer can reach the same conclusions with nothing but the box in their hand.

Which certifications can actually be verified?

Only those with a public register. COSMOS, operated through Soil Association, Ecocert, BDIH, Cosmebio and ICEA, certifies natural and organic cosmetics against a published standard and lists certified products. Soil Association and Ecocert publish searchable databases. Leaping Bunny maintains a list of approved cruelty free brands. B Corp publishes every certified company with its score. The Vegan Society and similar marks have registers. An assessor accepts a certification logo as evidence when the product or brand appears on the relevant register, and rejects it when the logo is a graphic the brand designed or the scheme has no register to search. Certified natural with no scheme named is not a certification; it is a claim with no evidence, and it belongs in the empty row of the claims table.

The ten question version for buyers

1. Does the claim say exactly what it means, with a number or a definition? 
2. Can it be traced to a certification, a study, a method or a supplier statement? 
3. Do the first six ingredients support the front of the pack? 
4. Is any free from claim about an ingredient that would even be in this product type? 
5. Does any certification logo appear on its scheme's public register? 
6. Do packaging claims state where and how, for example widely recycled or industrially compostable? 
7. Does the brand address formula, packaging, sourcing and manufacturing, or only whichever one flatters it? 
8. Is any comparative claim compared with something named? 
9. Do the website, the pack and the adverts say the same thing? 
10. Does the brand answer a specific question about evidence within a working day? 

Two or three failures on an otherwise sound product is ordinary marketing. Six or more means the pack is selling a feeling. The check takes about ten minutes and requires no chemistry.

A worked example, in the order an assessor takes it

A body lotion arrives for assessment with draft artwork reading clean, green, plant powered, free from parabens and sulfates, in eco packaging, from a sustainable brand. The assessor opens Part A section 1: Aqua, Glycerin, Cetearyl Alcohol, Dimethicone, Isopropyl Myristate, Phenoxyethanol, with Aloe Barbadensis Leaf Juice ninth and Helianthus Annuus Seed Oil eleventh. Plant powered is contradicted. Section 10 asks for the evidence: there is no certification, no percentage, no method, so clean, green and sustainable have empty rows. Paraben free and sulfate free are struck under the fairness criterion, and sulfate free is additionally meaningless on a leave on lotion. Eco packaging names no material and states no recyclability, so it fails honesty and falls under the Green Claims Code as well. Part B concludes the product is safe, because it is, and records that the draft claims are not supported by the file. The brand revises the artwork to a fragrance free body lotion with five percent glycerin, in a bottle described as widely recycled in the UK, and adds a claims table with four rows and four pieces of evidence. The formula never changed. The pack became lawful.

How should a brand make green claims that survive a CPSR?

• Define every green word with a number or a method. Naturally derived percentage by weight calculated under a stated standard.
• Certify where a scheme exists, and use the logo only for listed products. 
• Describe packaging with conditions. Widely recycled in the UK; refill available; industrially compostable.
• Replace free from claims with positive statements. Formulated without fragrance for sensitive skin, rather than free from nasties.
• Compare only with something named. 
• Be honest about what has not been addressed. A conventional bottle beside a good formula earns more trust than silence.
• Keep the claims table current and in the Product Information File. 
• Send the draft artwork to the assessor before print, not after. 

What about claims the CPSR does not cover?

The safety report covers claims in the safety context; it is not an advertising clearance. Environmental claims about carbon, supply chains and packaging waste sit under the Green Claims Code and the advertising rules, and claims about efficacy sit under the common criteria with their own evidence requirements. A good assessor flags all of them, because a brand does not care which regulator writes the letter, but the formal boundary matters: the CPSR states that the product is safe under the conditions given and that its claims are consistent with the assessment. Substantiating a carbon neutral claim is a separate exercise the brand must carry out, and the evidence still belongs in the claims table.

Myths we hear

• A CPSR only covers safety, so claims are not its business. Claims enter Part A section 10 and Part B, and the PIF must hold the evidence.
• Paraben free shows a brand cares. It fails the fairness criterion and tells you nothing about the formula.
• A leaf on the pack is harmless. Imagery is part of the overall impression the criteria judge.
• Small brands are not checked. Market stalls and online listings are the easiest to test purchase.
• We can add the evidence if someone asks. The evidence must exist when the claim is made.

What to do this week

• List every claim on your packs, website and social media. 
• Build the claims table and mark the empty rows. 
• Delete or reword every empty row. 
• Search the register for any certification logo you use. 
• Send the revised artwork to your assessor before the next print run. 

Greenwashing survives where nobody reconciles the marketing with the formula. The Cosmetic Product Safety Report is where that reconciliation happens, and a brand that welcomes it ends up with claims it can defend to a customer, a marketplace and a Trading Standards officer alike. You can verify any report Spectra signs and talk to our assessors before you commit to artwork.

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
• EU CPNP Product Notification
• Contact Spectra

Official sources and legislation

• Regulation (EU) No 655/2013 on cosmetic claims
• CMA Green Claims Code
• Advertising Standards Authority
• Regulation (EC) No 1223/2009 on cosmetic products
• Cosmetic Products Enforcement Regulations 2013