Good practices and common pitfalls on advertising of cosmetics in Italy
Within the beauty and cosmetics sector, information and advertising campaigns relating to the various products play a primary role, as they are fundamental for building (and, at a later stage, consolidating) consumer trust. This importance has been acquired above all as a result of the expansion of the market through the phenomenon of social media and the growing attention of consumers to goods produced using so-called green or organic components and, above all, cruelty-free products, i.e. products for the realization of which no tests on animals have been carried out. Moreover, these elements not only have an impact on the formulation of advertising claims, as they aim to convey the identity, values and ethics of the brand - rather than promising miraculous effects through their use - but also significantly influence production requirements. Yet, when large manufacturers promote certain specific features of their products, such as sustainability and absence of animal testing, certain risks arise: the claim must be truthful and based on rigorous scientific testing, the entire supply chain must be taken into account to verify whether the claim is misleading, and the absence of animal testing cannot be presented as an added value at the European level, as it is a requirement by law. After all, the cosmetics industry is a highly innovative sector and large companies need to reflect that in their advertising. However, attention must be paid to certain pitfalls: for example, it is necessary to prevent advertising from creating the impression that a cosmetic product has curative effects or effects that transcend the real characteristics and performance of its composition. And, indeed, although the cosmetics industry tends to have a generally responsible approach to claims and advertising in general, there are still some caveats that need to be carefully considered and some limits that should not be crossed.
Good practices and common pitfalls on advertising of cosmetics in Italy
Within the beauty and cosmetics sector, information and advertising campaigns relating to the various products play a primary role, as they are fundamental for building (and, at a later stage, consolidating) consumer trust. This importance has been acquired above all as a result of the expansion of the market through the phenomenon of social media and the growing attention of consumers to goods produced using so-called green or organic components and, above all, cruelty-free products, i.e. products for the realization of which no tests on animals have been carried out. Moreover, these elements not only have an impact on the formulation of advertising claims, as they aim to convey the identity, values and ethics of the brand - rather than promising miraculous effects through their use - but also significantly influence production requirements. Yet, when large manufacturers promote certain specific features of their products, such as sustainability and absence of animal testing, certain risks arise: the claim must be truthful and based on rigorous scientific testing, the entire supply chain must be taken into account to verify whether the claim is misleading, and the absence of animal testing cannot be presented as an added value at the European level, as it is a requirement by law. After all, the cosmetics industry is a highly innovative sector and large companies need to reflect that in their advertising. However, attention must be paid to certain pitfalls: for example, it is necessary to prevent advertising from creating the impression that a cosmetic product has curative effects or effects that transcend the real characteristics and performance of its composition. And, indeed, although the cosmetics industry tends to have a generally responsible approach to claims and advertising in general, there are still some caveats that need to be carefully considered and some limits that should not be crossed.
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Good practices and common pitfalls on advertising of cosmetics in Italy
- 2. It is preferable to use nuanced wording, presenting the product as meant to 'encourage’, 'contribute to' or 'facilitate' the achievement of the result It is preferable to associate the term ‘effect’ with the goal of the product and not to present it as an objective and certain result (e.g. slimming effect) The results of scientific tests shall be cited with accuracy and displayed in a clear and readable font Explain clearly the nature of the tests conducted (e.g. self-assessment or in vivo instrumental test) Efficacy Claims
- 3. Proof of the effectiveness of the product shall involve the final product, not a single component Use only claims that can be proven Extreme caution when using comparative images (before/after) as they do not reflect the variability of individual response Efficacy Claims
- 4. Efficacy Claims Avoid claims that associate a cosmetic product with activities/results that the product cannot cause (e.g. do not imply that the product causes weight loss) Do not use expressions implying a 100% efficacy (e.g. ‘100% protection’, ‘Total shield’, ‘100% wrinkles reduction’) Do not use expressions such as ‘revolutionary’ Avoid conveying the message that the product has quick and certain effects Do not use of too many asterisks next to claims
- 5. Fine to use the Leaping Bunny Logo if the certification has been granted to the company If the certification has not been granted, avoid using unofficial or invented bunny logos, as well as logos or symbols that have a national reach only (e.g. 'Not tested on animals' bunny, Australia-based only) No boasting about the absence of animal testing if required by law Avoid expressions such as 'cruelty-free', if not supported by scientific evidence: although cosmetics cannot be tested on animals as per EU Regulation 1223/2009, such expression shall not be used if a single substance and/or raw material was tested on animals Animal testing and natural products
- 6. Animal testing and natural products Avoid expressions such ‘natural’ and ‘vegan’ if not supported by scientific evidence No generic claims as ‘sustainable’ if it is not clear which aspect of the advertised product positively impacts the environment Avoid associating the presence of natural substances with the concept of safety
- 7. Convey a level of efficacy that is compatible with that of a cosmetic product Clearly explain that the product’s main purpose is to clean/perfume/improve the aesthetic appearance of the surfaces of the human body When clinical tests are cited, verify their reliability and accuracy: e.g. the questionnaire shall concern the effectiveness and not only the pleasantness of the product e.g. the questions shall be consistent with the self-assessment (e.g. brightness, hydration, wrinkle reduction, etc.) Ambiguities with medical products
- 8. Do not use expressions such as ‘sold only on pharmacy’ or images of people in white coats to reassure the customer and suggest that the product has a scientific-pharmaceutical nature Avoid references to medical treatments (e.g. ‘micro botox injections’) Do not use expressions that are generally associated with medical treatments (e.g. ‘no contraindications’) Avoid exaggerations (e.g. ‘Found the secret for eternal youth’) Do not show pictures of people completely recovered if the product causes only improvements Do not make improper reference to pathological conditions, for which cosmetic products cannot claim any specific action. Ambiguities with medical products