A 101 guide to skincare claims
If you want to understand what it all means, this is the place you should start.
Misconception: You’ll be able to see if a product will work by the ingredient list
Reality: ingredient lists really don’t tell consumers that much, outside of e.g. allergen disclosure. Anyone who tells you otherwise probably doesn’t really have a good grasp on what it all means.
1 ingredient name can represent 100s-1000s of ingredients with very different performances. The same ingredient list can represent different concentrations of ingredients, different ingredients in general, different manufacturing techniques - these changes can make 2 very different products (e.g. a thin lotion vs a thick cream), even though the ingredient list is the same. How an ingredient performs in a product is formulation specific - this is not something ingredient disclosure will tell you. When you’re looking for effective products, claims are arguably the most important indicator of performance. However, claims are not created equal.
The strength of a claim depends on how well it is substantiated.
Ingredient Claims
Ingredient-based claims are when brands highlight specific ingredients to imply efficacy, sometimes without testing the full product formulation. While these ingredients may have demonstrated benefits in research, the final formulation is what determines efficacy. Just because an ingredient is present doesn’t mean it will work in the formula. The synergy of ingredints in the formula affects the way the “active” ingredient may work, another reason not to rely on supplier data.
Common Ways Ingredient Claims Are Misleading:
Assuming Ingredient Efficacy in the Final Formula: Just because there’s literature about ingredient efficacy does not mean that evidence will apply to your formula.
Using Supplier Data as Proof of Efficacy: Many ingredient suppliers conduct studies on isolated ingredients, but brands sometimes use this data to claim their entire product has the same effect.
Misleading Percentage Claims: Highlighting "Star Ingredients" That Are Too Low to Work
Why do brands often prefer subjective studies/claims?
More relatable: “98% of women felt their wrinkles were reduced” sounds more appealing than “7% reduction in wrinkle depth”
Easier to obtain: Subjective studies are cheaper and faster than clinical trials using scientific instruments.
Emotional connection: Subjective claims focus on how consumers feel, which makes them more persuasive.
Downsides: influenced by bias, placebo effect, with no scientific measurement. It’s more of an opinion based claim.
Reputable subjective study firms will work to minimize bias in their study design.
Big mistake for these types of claims - brands using their friends and family. There is an inherent bias here!
Deceptive trend related to subjective studies: brands marketing them as clinical studies. E.g. “in a clinical study, 30 women noticed improvements in their fine lines.”
Objective Claims
Objective claims are scientifically validated measurements of a product’s efficacy using instrumental testing or clinical assessments. These claims are based on data rather than perception.
Strengths: Scientifically verifiable, repeatable, higher credibility.
Weakness: Higher cost, longer turnaround.
The strongest claims combine both objective & subjective studies.
Objective claims provide scientific validation of effectiveness. But just because you are able to measure something doesn’t mean the user will be able to notice a change. Subjective claims show real-world consumer satisfaction and experience. Can the user actually notice the benefits that were demonstrated in the clinical study?
Cosmetics vs Drug Claims
In the USA, the FDA defines products based on how they (claim) to affect the body.
Cosmetic Definition: A product intended to cleanse, beautify, promote attractiveness, or alter appearance without affecting biological function. Key Rule: Cosmetic claims must be about “appearance,” not internal biological changes. Examples of Cosmetic Claims: "Hydrates skin for 24 hours." "Improves the appearance of fine lines." "Visibly brightens skin tone." “Softens and smooths rough texture."
Drug Definition: A product that treats, prevents, or affects the structure or function of the body (including the skin). Rule of Thumb: If a product claims to treat a medical condition or change skin structure, it is considered a drug. Examples of Drug Claims: "Stimulates collagen production." "Treats acne and eliminates breakouts." "Reverses sun damage and repairs DNA."
Key Difference: Cosmetic claims use soft, appearance-based language, while drug claims imply biological change or treatment.
Topical skincare can either be regulated as a cosmetic, Over-The-Counter (OTC)(which is a drug product that doesn’t require prescription), or a drug (that generally does require a prescription. As you go towards drug, the level of evidence needed is higher due to, largely, the higher potential risk due to higher e.g. potency ingredients. For both OTC and Drug claims, products must be following the monograph or it becomes a new drug that requires a New Drug Application (NDA) with the FDA.
Misconception: there’s an extra category for “medical grade skincare”. These products generally fall under cosmetics regulations.
What Happens If a Brand Crosses the Line? The FDA &/or NAD issues a warning letter. The FTC may investigate for false advertising. The product may be forced off the market or reclassified as a drug.
Fraud and Misconduct in Testing Labs
Fraud in skincare testing occurs when a lab manipulates data, falsifies results, or skips actual testing to provide favorable outcomes for brands. Some brands actively seek out such labs to ensure their marketing claims look strong. Fraud like this isn’t common... but it happens...
Steps for Brands to Ensure a Clinical Testing Lab Is Legitimate:
Ask for Raw Data: Ethical labs should provide detailed datasets, not just summary results.
Verify Study Design: Check if the is study design is scientifically sound.
Audit the Lab: Brands should visit and inspect labs before hiring them.
Avoid Labs That Guarantee Positive Results: No ethical clinical study can promise 100% positive claims.
Check for Regulatory Compliance: Ensure the lab follows FDA, EU, or ISO guidelines and has Good Clinical Practice (GCP) certification.
Key Challenges Brands Face
Ballpark Costs of Claims Testing:
Consumer Perception Study (subjective) → $10,000 – $20,000
Instrument-Based Clinical Study (objective) → $30,000 – $100,000
Large-Scale Dermatological Study → $100,000+
Brands Expect "Guaranteed" Positive Results:
Some brands enter testing with unrealistic expectations, assuming that because they paid for a study, it will prove their claims. But science doesn’t work that way.
Suggestions for smaller brands:
Brands should prepare for negative or neutral results.They should conduct small pilot studies before committing to expensive trials. If you’re bootstrapping, start with consumer perception studies. If you’re going to do a clinical study, do it the right way,
How Consumers Can Find Effective Products?
Consumers should prioritize looking for
high-level proven ingredients - e.g. the tried and tested ingredients with a lot of proof behind them, such as retinol, vitamin C, niacinamide, AHAs, etc.
substantiation on the finished formula - whether that’s from subjective &/or objective studies, you now know what the claims look like for both, as well as what is stronger in terms of evidence. Here, you can also ask yourself, how important is that evidence for the specific product/cost? More evidence will generally translate to a higher price tag (this is especially true for smaller brands who can’t absorb the costs like the big guys)
credible reviews - find people you trust who try lots of products and see what they have to say.
Misconception: you’ll be able to tell whether a product will work based on the ingredients list. One INCI can represent many different ingredients, and the same ingredient list can generate very different end products.
