Free From Labelling New Rules
Updated: Jan 24
An additional annex - Annex III, ‘Free from’ claims, was recently added to EC Regulation No. 655/2013. Effective July 2019, claims highlighting the absence of substances will be regulated and restricted. Here are some examples: Ingredients This means free from claims such as free from preservatives, parabens, synthetic ingredients or palm oil will no longer be allowed. Such claims denigrate competitors and denigrate ingredients legally used. These changes are set to reduce misleading information, fear based marketing tactics and create an equal selling field for all cosmetic companies. However, at Nudge we think the new rules are problematic for two reasons: 1. Informed Decision Making Under the updated regulations, stating that a product 'does not contain ingredient X, which is known to be irritating’ is no longer allowed. However, Part 6 of the Regulations refers to Informed Decision Making "a cosmetic company can make 'free from’ claims so that an informed choice by a specific target group or groups of end users can be made.” An example of this would be Vegan or alcohol free. But what about people with allergies? Are they not a specifice group of end users who need to make an informed choice about what product they use on their skin? 2. Environmental Concerns Continuing on with Part 6 of the Regulations, what about the specific group of people that care about the over use of pesticides, GMO crops, overharvesting, deforestation, soil degradation and the threat of extinction to species? What about the group of people who are against *child labour, poor working conditions and abuse of workers in the farming and harvesting of ingredients used in the cosmetic industry? Whether you are a concerned citizen or not, you have the right to live your moral and ethical values and choose which cosmetic company you want to purchase from and continue to support. Conclusion The updated free from rules have the potential to reduce fear based free from claims and exagerated effectiveness of a cosmetic ingredient, which is welcomed. However, at Nudge we disagree with the concept that 'free from x' is immediately denigrating. Customers rely on us to inform them of skin effectiveness, which includes being open and honest about possible irritation and allergies experienced by customers with other **sensitivities outside of fragrance allergens. At Nudge, we believe we are all connected and have a responsiblity to care for each other and our planet. Being able to state free from claims that match the eco values of our customers helps them make informed decisions. Where Do We Go From Here? The new free from label rules doesn't just apply to labels, it applies to digital marketing and any type of advertising. The main concern for us is knowing we can no longer help you make quick and informed decisions by using the term 'free from'. The quickest way to know what we use and don't use is to read our labels. Our labels have always been up to code and we have included an 'in plain English' list of ingredients along side the INCI one on our online store. Hopefully this will help you make an informed decision about the ingredients in our products. However, the changes in the law does not stop you from contacting us directly and asking about our ingredients etc, so please contact Jo at firstname.lastname@example.org who will be able to give you straight answers :) We will use our blog to discuss our ingredients, and we will not shy away from discussing the ones that are gaining controversy and why. We will also let you know if we use these controversial ingredients, or what we are doing positively different. What are your thoughts on this? Please share! * (.i.e.there has been an increasing amount of pressure on cosmetic companties to stop purchasing from manufacturers who use child labour in the mining of mica. Lush made the right choice by switching to synthetic mica as they were unable to source or guarantee their mica was not being mined by children). **It is well documented and we have many accounts from customers, friends, family and from Jo the founder of Nudge who find SLS surfactant brings them out in rash. In this example, stating free from SLS is not deginerating, but informing people with sensitive skin that x product contains it.