• Claim Substantiation
    Product Seaweed, Bakuchiol Serum
    Qualitative research analysis based on
    evidence, statistic and research.

Product Claims to be Substantiated:

1) Rejuvenates Skin, Detoxifies the skin, Helps reduce the appearance of wrinkles, Improves skins texture and replenishes the skin with vitamins.

Vitamin C acts as a co-factor for the proline and lysine hydroxylases that stabilise the collagen molecule tertiary structure, and it also promotes collagen gene expression
T Pihlajaniemi, R Myllylä (1991) Prolyl 4-hydroxylase and its role in collagen synthesis

Vitamin C promotes collagen formation and reduces negative impact of free radicals and helps to maintain strong and youthful skin (Goldfaden, 2009), promotes tissue regeneration and renewal
(Fan et al. 2012, p. 4112).

Vitamin C positively act on the skin creating nitrogen oxides protection against their harmful effects of free radicals, rejuvenates and purifies skin, stimulates cell regeneration, improves capillary patency and strengthens their walls, promotes tissue regeneration, collagen synthesis, amino acids, carbohydrates, fat and other materials metabolism
(Telang et al. 2013, p. 144; Shai et al., 2009, p. 33; Gianea et al. 2012, p. 2219; Oresajo et al. 2012, p. 253; Fracassetti et al. 2013, p. 579).

Most studies have been based on terrestrial sources; however, it has been shown that natural compounds isolated from marine sources show higher biological activity than those isolated from terrestrial sources, and as a result, there is a lot of interest in the studies of ingredients using natural marine sources. In particular, oceans account for about 70% of the earth’s surface and their biodiversity makes them an excellent reservoir of sources for natural products [5]. Among various natural organisms, marine algae, which grow much faster than terrestrial plants, are considered to be abundant and essential sources of numerous constituents beneficial for human skin health
Kim, J.H.; Lee, J.-E.; Kim, K.H.; Kang, N.J. Beneficial Effects of Marine Algae-Derived Carbohydrates for Skin Health. Mar. Drugs 2018,

Marine algae are composed of various substances including carbohydrates, lipids, proteins, amino acids, minerals and flavonoids.
Hamed, I.; Ozogul, F.; Ozogul, Y.; Regenstein, J.M. Marine bioactive compounds and their health benefits: A Review. Compr. Rev. Food Sci. Food Saf. 2015.

2) Vitamin C helps to protect against UV Damage. (photodamage).

Topical vitamins C and E, as well as topical selenium, protect skin against sunburn, suntan and skin cancer and also reverse the mottled pigmentation and wrinkles of photo-ageing. However, only certain forms of these labile antioxidants are stable and active after percutaneous absorption. For effective topical application, vitamin C must be non‐esterified, acidic and optimally at 20% concentration.’’
‘’ There are two great advantages in applying an active formulation of topical antioxidants to the skin. Vitamin C is a potent antioxidant that can neutralise and remove oxidants, such as those found in environmental pollutants and after exposure to ultraviolet radiation. This activity appears to be of particular importance in the epidermis, where vitamin C is concentrated in the skin.
Juliet M. Pullar, et al (2017) The Roles of Vitamin C in Skin Health


First, the skin attains far higher levels of each antioxidant than can be achieved by only taking these vitamins orally. The level of vitamin C attained in the skin by topical application is 20–40 times that achievable with oral vitamin C.’’

K E Burke (2004) Photodamage of the skin: protection and reversal with topical antioxidants

Vitamin C derivatives, including the magnesium phosophate ascorbyl derivative, have been shown to decrease melanin synthesis both in cultured melanocytes and in vivo.
Matsuda, S.; Shibayama, H.; Hisama, M.; Ohtsuki, M.; Iwaki, M. Inhibitory effects of a novel ascorbic derivative, disodium isostearyl 2-O-l-ascorbyl phosphate on melanogenesis. Chem. Pharm. Bull. 2008, 56, 292–297

‘’Cosmeceuticals containing antioxidants are among the most popular antiaging remedies. Topically applied antioxidants exert their benefits by offering protection from damaging free radicals produced when skin is exposed to ultraviolet light or allowed to age naturally. Vitamin C is a naturally occurring potent water‐soluble antioxidant. Accordingly, it has been incorporated into a variety of cosmeceuticals designed to protect and rejuvenate photoaged skin. Their article reviewed the scientific data and clinical studies supporting the use of topically applied vitamin C for treating photoaged skin. Other innovative uses for vitamin C cosmeceuticals [were] also discussed.

Their Conclusion was that a significant body of scientific research supports the use of cosmeceuticals containing vitamin C. Cutaneous benefits include promoting collagen synthesis, photoprotection from ultraviolet A and B, lightening hyperpigmentation, and improvement of a variety of inflammatory dermatoses. Because of the diverse biologic effects of this compound, topical vitamin C has become a useful part of the dermatologist's armamentarium.
Patricia K. Farris MD (2016) Topical Vitamin C: A Useful Agent for Treating Photoaging and Other Dermatologic Conditions

‘’In addition to alterations of DNA, signal transduction pathways, immunology, UVR, and pollution activate cell surface receptors of keratinocytes and fibroblasts in the skin. This action leads to a breakdown of collagen in the extracellular matrix and a shutdown of new collagen synthesis. Therefore, an efficient antioxidants strategy is of major importance in dermis and epidermis layers. Marine resources have been recognised for their biologically active substances. Among these, marine algae are rich-sources of metabolites, which can be used to fight against oxidative stress and hence skin aging. These metabolites include, among others, mycosporine-like amino acids (MAAs), polysaccharides, sulphated polysaccharides, glucosyl glycerols, pigments, and polyphenols. This paper reviews the role of oxidative processes in skin damage and the action of the compounds from algae on the physiological processes to maintain skin health.’’
Berthon JY1, Nachat-Kappes R1, Bey M1, Cadoret JP1, Renimel I1, Filaire E2,3,4. (2017) Marine algae as attractive source to skin care.

Another clinical study demonstrated the skin anti-aging effects of Spirulina maxima (blue algae), […] with other compounds. Marine algal mixtures enhanced the skin hydrating and skin firming effects on human skin, suggesting the utilization of marine algae in cosmeceuticals.
Xhauflaire-Uhoda, E.; Fontaine, K.; Pierard, G.E. Kinetics of moisturizing and firming effects of cosmetic formulations. Int. J. Cosmet. Sci. 2008

Skin anti-aging and skin barrier functions of microalgae extracts were assessed in vitro and in vivo. Green-blue microalgae, Blue Lagoon coccoid Filamentous, were extracted with phosphate-buffered saline (PBS) without magnesium (Mg) and calcium (Ca). In human epidermal keratinocytes (HEKs), green-blue microalgae extracts increased the expression genes of the transcriptional level of involucrin (INV), loricrin (LOR), transglutaminase-1 (TGM-1) and filaggrin (FLG) which are major markers for skin barrier function.
Rinnerthaler, M.; Streubel, M.K.; Bischof, J.; Richter, K. Skin aging, gene expression and calcium. Exp. Gerontol. 2015

‘’Polysaccharide of Spirulina platensis (PSP) is a kind of water-soluble polysaccharide extracted from Spirulina platensis. It has been proved to have antitumor, antioxidation, antiaging, and antivirus properties.’’ And it has a promising prospect for wide application.
This study by Wang et aimed to identify an extraction process for high-purity polysaccharide in Spirulina (PSP) through a series of optimization methods and then evaluates its initial antiaging activities. The performed Scratch experiments to compare the skin-damage-repairing effects between the ’Polysaccharide of Spirulina platensis (PSP)  and the growth factor. The effects were found to be almost comparable, suggesting that the ’Polysaccharide of Spirulina platensis (PSP) exerts good effect on skin repair.
Bingyue Wang, Qian Liu,2Yinghong Huang, Yueling Yuan, Qianqian Ma, Manling Du, Tiange Cai, and Yu Cai (2018) Extraction of Polysaccharide from Spirulina and Evaluation of Its Activities

3) Firms and Smooths the skin which is great for those with an uneven texture.

Jociene carried out a qualitative analysis of all research into the effects of vitamin c on mature skin. They analysed data and studies and concluded that ‘’Cosmetics enriched with vitamin C, are effective solving problems of mature skin. Vitamin C ensures better resistance of skin, it`s elasticity, moisture, firmness, colour uniformity, strengthens capillaries, reduces face skin irritations, brightens pigment spots.’’

Vitamin C is required for facial skin in order to maintain beautiful, youthful skin, improve its regeneration, enhance tissue recovery options, to stop aging process, and improve skin tone.
(Shai et al., 2009, p. 32; Telang 2013, p. 144)

Clinical studies showed, that cosmetics containing vitamin C improve skin situation, slow down aging process, refreshes and purifies skin, stimulate collagen synthesis, accelerate tissue regeneration, and strengthen blood vessels.
Gianeti et al. 2012, p. 2220

Shivhare, S C; Malviya, K G; Malviya, K K Shivhare; Jain, Vijay. Research Journal of Topical and Cosmetic Sciences; (2013) A Review: Natural skin lighting and nourishing agents

4) High in fatty acids and anti-oxidants to help protect skin from harsh natural aggressors that damage and compromise the  skins barrier such as pollution.

A Study by Chan looked at Vitamin E and Vitamin C work together to prevent and reverse cellular damage (mutinagenic and carcinogenic) and oxidative stress this can be caused by ageing and environmental factors such as pollution. They found that both together in a water soluble solution constitute a strong line of defense in retarding free radical induced cellular damage using kinetic analysis.
Alvin C. Chan (1993) Partners in defense, vitamin E and vitamin C

Vitamin C is strong reducing agent, which carries significant role in the fight against oxidative processes. Vitamin C creates stabilizing impact, what has positive effect on facial skin reducing wrinkles, protecting skin from adverse environmental effects
 (Lauer et al. 2013, p. 148)

Clinical studies showed that vitamin C promotes collagen formation and reduces negative impact of free radicals and helps to maintain strong and youthful skin
(Goldfaden, 2009)

Background: Virtually all plants and animals protect themselves from the sun using vitamins C and E. Objective: The purpose of this study was to see if a combination of topical vitamins C and E is better for UV protection to skin than an equivalent concentration of topical vitamin C or E alone. Methods: We developed a stable aqueous solution of 15% L-ascorbic acid (vitamin C) and 1% α-tocopherol (vitamin E). We applied antioxidant or vehicle solutions to pig skin daily for 4 days. We irradiated (1-5× minimal erythema dose) control- and antioxidant-treated skin using a solar simulator with a 295-nm band-pass filter. On day 5, we measured antioxidant protection factor, erythema, sunburn cells, and thymine dimers. Results: The combination of 15% L-ascorbic acid and 1% α-tocopherol provided significant protection against erythema and sunburn cell formation; either L-ascorbic acid or 1% α-tocopherol alone also was protective but the combination was superior. Application during 4 days provided progressive protection that yielded an antioxidant protection factor of 4-fold. In addition, the combination of vitamins C and E provided protection against thymine dimer formation. Conclusion: Appreciable photoprotection can be obtained from the combination of topical vitamins C and E. We suggest that these natural products may protect against skin cancer and photoaging.
Jing-YiLin MDa,M.Angelica Selim MDaChristopher R.SheaMDb,James M.GrichnikMD, PhDaMostafa M.OmarPhDcNancy A.Monteiro-Riviere PhD d Sheldon R.PinnellMDa (2002) UV photoprotection by combination topical antioxidants vitamin C and vitamin

From these and other algae and diatom algae may be obtained lipid (or “algal fat”) high in C14 through C22 triglycerides including saturated and unsaturated fatty acid chains. Other lipid and oil producing algae include blue algae, green algae, blue-green algae, and golden brown algae, often collectively referred to as micro-algae. This lipid constitution is similar to fresh water fish oils. Brown algae and red algae produce longer chain triglycerides, for example with carbon chains greater than 24-carbons.
Mengtao Pete HePaul A. PappalardoRichard F. Theiler  (2018) Consumer products comprising algae derived ingredients.

The objective of the study was to investigate the influence of a food supplement rich in antioxidants on the antioxidant status of the skin. For this reason, the blue-green algae Spirulina platensis powder was used for oral application during eight weeks. The effect of oral application of the antioxidant-containing Spirulina platensis on characteristic skin aging parameters, e.g., concentration of cutaneous carotenoids and the collagen/elastin index (SAAID), was investigated in vivo. A significant average increase from 2.67 ± 0.86 arb. units to 3.25 ± 0.93 arb. units (p < 0.001) in the cutaneous carotenoid concentration was detected subsequent to oral application of the carotenoid-containing Spirulina platensis powder, showing a significant improvement of the antioxidant status of the skin. A slight but not significant increase (p = 0.33) in the dermal SAAID mean values was measured from −0.54 ± 0.11 to −0.51 ± 0.11 subsequent to oral intake of Spirulina platensis powder.
Darvin et al (2015) Influence of the Systemic Application of Blue–Green Spirulina platensis Algae on the Cutaneous Carotenoids and Elastic Fibers in Vivo

‘’Analyses of the lipids in five species of blue-green algae show that the fatty acids are largely the C16 and C18 acids. The only alga that could be grown heterotrophically, Chlorogloea, formed the triply unsaturated C18 acid in the light but only the doubly unsaturated C18 acid in the dark. Examination of these results and the results of others suggest that, except for one species, the more highly unsaturated acids are found in the morphologically more complex algae. The fatty acid compositions of blue-green algae are different from the fatty acid composition of the other prokaryotic organisms, the bacteria. It is speculated that the diversity of the patterns of fatty acid composition among the blue-green algae could be of phylogenetic significance.’’
Raymond W. Holton1, Harry H. Blecker (1968), Timothy S. Stevens2Fatty Acids in Blue-Green Algae: Possible Relation to Phylogenetic Position

Many algae-derived secondary metabolites are known for their skin benefits, which include protection from UV radiations and prevention of rough texture, wrinkles, and skin flaccidity. It also avoids skin aging due to the presence of antioxidant compounds. The variety of cosmetic formulations using biocompounds or algae extracts is increasing since they also provide the desired safe materials from environmental resources.
Maíra BuenoAriedeaThalita MarcílioCandidoaAna Lucia MorochoJacomeaMaria Valéria RoblesVelascoaJoão Carlos M.de CarvalhobAndré RolimBabya (2017) Cosmetic attributes of algae

‘’Spirulina is a unicellular blue-green alga rich in vitamins, minerals, pigments, proteins, polysaccharides, which indicates a high potential use in anti-aging cosmetic products as well as for skin protection. Preliminary studies showed antioxidant potential, immediate benefits on the skin microrelief and hydration and skin compatibility of formulations containing Spirulina extract. Thus, the objective of this study is to evaluate the long term clinical efficacy of dermocosmetic formulations containing Spirulina extract on young and mature skin using biophysical and skin imaging techniques.Methods: 40 healthy female volunteers participated in the clinical efficacy study, aged between 18- 39 (Young group) and 40- 65 (Mature group). The gel-cream formulation, supplemented, or not (vehicle - FGV) with 0.1% (w/w) of Spirulina extract (FGA) was applied twice daily on the volunteers face region. The effects were evaluated in terms of skin hydration, transepidermal water loss - TEWL, skin microrelief, sebum content and morphological and structural epidermal features before and after a 28-day-period of application of the formulations. Results: The formulation containing Spirulina extract increased stratum corneum water content and reduced the TEWL in both groups. However, a significant reduction in the older group, that received the formulation with Spirulina extract, was observed when compared to the younger group and to the vehicle formulation. Only the formulation containing the active ingredient under study reduced significantly the sebum content on the volunteer’s skin. It was also noted an improvement of the skin microrelief by the reduction of the surface roughness and after the treatment the keratinocytes were more uniformly distributed and homogeneous. Conclusion: The formulation containing Spirulina extract improved skin conditions and provided long term skin benefits such as hydration, protection of the skin barrier function and oil control. Finally, Spirulina extract stands out as a unique active ingredient for effective multifunctional dermocosmetic formulations for the care of young and mature skin.
Delsin SD, Mercurio DG, Fossa MM and Maia Campos PMBGClinical Efficacy of Dermocosmetic Formulations Containing Spirulina Extract on Young and Mature Skin: Effects on the Skin Hydrolipidic Barrier and Structural Properties

6) Formulated to plump, hydrate and revive dull and dry skin. Smooths Skin.

Researchers in Greece looked at and studied Hyaluronic Acid in its structural form and explain that in aqueous solutions Hyaluronic Acid forms specific stable tertiary structures which can hold high quantities of water and benefit tissue by aiding its hydration levels. ‘’Youthful skin retains its turgor, resilience and pliability, among others, due to its high content of water.’’. At a molecular level these structures have space filling tendencies and in a cosmetic product would therefore plump the skin at the same time.

They explain in their study that […] Hyaluronic Acid in the dermis […] is in continuity with the lymphatic and vascular systems. HA in the dermis regulates water balance, osmotic pressure and ion flow and functions as a sieve, excluding certain molecules, enhancing the extracellular domain of cell surfaces and stabilizes skin structures by electrostatic interactions.
Eleni Papakonstantinou, Michael Roth & George KarakiulakisDepartment of Pharmacology; School of Medicine; Aristotle University of Thessaloniki; (2012) Hyaluronic acid: A key molecule in skin aging

Researchers studied Hyaluronic Acid as a vehicle for permeability to deliver a ‘’transdermal carrier for active lipophilic ingredient’’ in order to assess the bioavailability of the substance. They used a certain alcohol free, oil/water based nano-emulsion with hyaluronic acid that could permeate into the dermis and successfully found that it worked favourably to deliver the active lipophilic ingredient into the skin. Which shows that Hyaluronic acid not only works inside the skin pt hydrate and plump, but also has the function to penetrate the dermis to deliver skincare ingredients deeper into the skin intercellular and follicular pathways.

.MingKongaXi, GuangChenbDong, KeonKweoncHyun, JinPark (2011) Investigations on skin permeation of hyaluronic acid based nanoemulsion as transdermal carrier.

Other researchers studied hyaluronic acid alongside other ingredients to help soothe some side effects and effectively deliver other ingredients to the skin. Their study which was published in the Journal of Cosmetic Dermatology involved 34 participants taking isotretinoin and a gel-cream containing hyaluronic acid and 33 participants (also taking isotretinoin) a placebo cream. Oral and topical retinoids are infamous for causing dryness and irritation, but after three months, the group that got the HA gel-cream showed improved hydration, less acne, and less trans-epidermal water loss than the placebo group. These results suggest that an HA-containing cream can be useful for mitigating the side effects of retinoids or substances known to cause dryness by drawing water into the molecule which sits in the skin and dermis.

María Isabel Herane MD  Héctor Fuenzalida MD  Emilia Zegpi MD  Carolina De Pablo QF Maria José Espadas MS  Carles Trullás MS  Alfons Mirada MD  Guillermo González Martin QF (2009): Specific gel‐cream as adjuvant to oral isotretinoin improved hydration and prevented TEWL increase – a double‐blind, randomized, placebo‐controlled study


In another study, this one published in 2014 in the Journal of Cosmetic and Laser Therapy, 23 women applied a serum containing HA and human growth factor (proteins found naturally in the body) twice a day for eight weeks. Compared with their original baseline, participants showed an improvement in signs of aging—specifically, wrinkles around the eyes—after eight weeks.
Do Hyun Lee, In Young Oh, Kyo Tan Koo, Jang Mi Suk, Sang Wook Jung, Jin Oh Park (2014): Improvement in skin wrinkles using a preparation containing human growth factors and hyaluronic acid serum.

Retinol is converted to retinoic acid when applied to the skin when its absorbed. The following stufy looked at the effects of retinoic acid and hyaluronic acid on skin cells by applying both ingredients to cells and harvesting the culture samples for microscopy to analyse changes. They found that ‘’Retinoic acid caused a marked change in the epidermal tissue architecture. The epidermal cells were flattened and contained fewer desmosomes and tonofilaments than control explants. Retinoic acid induced accumulation of fine granular material in the intercellular spaces in the upper, and less dense, flocculent material.’’ Meaning cells were smoother and more refined. It also induces the synthesis of new intercellular material, at least a part of which is hyaluronic acid.’’ Which shows that the ingredients can be used together to improve skin texture and in synthesis.  It also demonstrates that RA leads to an accumulation of HA in the superficial layers of epidermis by stimulating its synthesis in keratinocytes
Raija Tammi  Markku Tammi (1986): Influence of retinoic acid on the ultrastructure and hyaluronic acid synthesis of adult human epidermis in whole skin organ culture

J Clin studied human subjects between 30 and 60 years of age with signs of wrinkles. They were asked to apply various molecular weights of 0.1% HA cream including 50, 130, 300, 800 and 2000 kDa. After one month they found that treatment with 130 kDa HA was the most effective, increasing skin elasticity by 20%. Both the 50 and 130 kDa group had significant improvement in wrinkle depth and skin roughness after 60 days. All the other molecular weights still improved elasticity and skin hydration,.

This graph is a breakdown of the various percentages and molecular weights of HA on skin hydration against the Relative Water content of the skin over time.
J Clin Aesthet Dermatol. (2012) Efficacy and Safety of a Low-Molecular Weight Hyaluronic Acid Topical Gel in the Treatment of Facial Seborrheic Dermatitis

‘’ Skin moisturizing is one of the key aims of the commercially available skin care products. In order to keep the skin in good condition the cosmetic formulations should contain active compounds which are able to bind water and hence are responsible for water retention. One of the most widely applied active ingredient showing such properties is hyaluronic acid. Its physicochemical and biological properties are responsible for proper tissue hydration and transport of ions and nutrients.’’
‘’HA is a highly hygroscopic biopolymer. Each glucuronic acid unit contains a carboxyl group, giving rise to polyanionic character at physiological pH. Therefore, in the presence of water, hyaluronic acid molecules can expand in volume (1000 times) and can form a network stabilized by hydrogen bonds. One HA molecule can bind to approximately 250 water molecules (1 g of HA retains 6 l of water). Hyaluronic acid is nontoxic, non- irritating and non-sensitizing because it occurs naturally in skin.’’

Anna OLEJNIK, Joanna GOŚCIAŃSKA, Izabela NOWAK – Faculty of Chemistry, Adam Mickiewicz University, Poznań (2012): Significance of hyaluronic acid in cosmetic industry and aesthetic medicine

Wang at all explored different algae extracts and found that they ‘’showed a profound moisture retention ability’’. SPs from marine algae, especially fucoidan, have potential as humectants to protect against skin dehydration.

Wang, H.M.D.; Chen, C.C.; Huynh, P.; Chang, J.S. Exploring the potential of using algae in cosmetics. Bioresour. Technol. 2015,

After significant research, case studies, trials and appropriate scientific scalable studies we think that the claims made by us regarding Blue Algae, Collagen, Biotin and Hyaluronic Acid are well within the bounds of accuracy and are in no way inflated, presumptuous or misleading. Hyaluronic Acid and Blue algae has clearly been shown to reduce and improve ageing skin, wrinkles, photodamage. We have stated ‘targets’ rather than ‘will reduce’ so as to not make any specific promises to the consumer, or promise them any timescales for specific results.

The Purpose of this qualitative research was in order to conduct a qualitative and sometimes quantative in-depth study of the product ingredient’s to support their cosmetic claims for the purpose of advertising, marketing and sales purposes in line with the European Regulation 655/2013 as detailed below. We have elaborated where necessary our viewpoint on the specific topics.

 Study Criteria:

In order for us to verify the information researched by us we evaluate studies as per the below methodologies:

In silico studies

In vitro studies

Ex-vivo studies

Instrumental methods

Biochemical methods

Clinical studies (on volunteers)

Sensory evaluations etc.

 ‘’Product claims of cosmetic products serve mainly to inform end users about the characteristics and qualities of the products. Those claims are essential ways of differ­ entiating between products. They also contribute to stimulating innovation and fostering competition.’’

Section One: Legal compliance.

(1) Claims that indicate that the product has been authorised or approved by a competent authority within the Union.

N/A For this product and is compliant.

 (2) The acceptability of a claim shall be based on the perception of the average end user of a cosmetic product, who is reasonably well-informed and reasonably observant and circumspect, taking into account social, cultural and linguistic factors in the market in question.

People who are in the beauty aisle shopping for skincare will be well aware of the products function (hydrating and anti-ageing) based on the information on the front of the packet and its claims. A young teen for example would not be interested in this product and would be extremely unlikely to pick it up. Being a cosmetic cultural, linguistic and social factors are unlikely to be an alter the perspective of the product in any way.

(3) Claims which convey the idea that a product has a specific benefit when this benefit is mere compliance with minimum legal requirements shall not be allowed.

N/A For this product and is compliant.

Section two: Truthfulness

(1) If it is claimed on the product that it contains a specific ingredient, the ingredient shall be deliberately present.

All ingredients mentioned in the marketing claims are key and deliberate ingredients.

(2) Ingredient claims referring to the properties of a specific ingredient shall not imply that the finished product has the same properties when it does not.

The ingredients used in this product and the simple formulation was designed to bring out the benefits of the ingredients and in a way that complements each other and in effect increase the efficacy of the ingredients. For example, the retinol and hyaluronic acid molecules are dissolved in distilled water and made smaller in order for them to penetrate and absorb into the dermis effectively whereas using them on their own would not allow this. Special care has been taken to word the claims in a way that does not insinuate that this is pure retinol or pure hyaluronic acid and does not make any claims to suggest this.

(3) Marketing communications shall not imply that expressions of opinions are verified claims unless the opinion reflects verifiable evidence.

We have taken all research into consideration before marketing any claims and do not make any which has not been backed up by science and studies on human subjects. To do this would be against our companies ethics, standard and practices.

Section Three: Evidential support

(1) Claims for cosmetic products, whether explicit or implicit, shall be supported by adequate and verifiable evidence regardless of the types of evidential support used to substantiate them, including where appropriate expert assessments.

We do not make any product claims without first looking at research on ingredient benefits and only use ingredient formulations which are known to be effective in what they’re aiming to achieve fort the consumer.

(2) Evidence for claim substantiation shall take into account state of the art practices.

All research we look at is carried out by relevant scientists and researchers who use state of the art technology and analysis to test their subjects.     

(3) Where studies are being used as evidence, they shall be relevant to the product and to the benefit claimed, shall follow well-designed, well-conducted methodologies (valid, reliable and reproducible) and shall respect ethical considerations.

All studies we looked at study the Vitamin C, Vitamin E and Hyaluronic in a cosmetic context, using real skin application so its relevant and applicable to our claims.

(4) The level of evidence or substantiation shall be consistent with the type of claim being made, in particular for claims where lack of efficacy may cause a safety problem.

All levels of efficacy needed in the ingredients are well researched and the ingredients in their respective quantities or lack of efficacy do not pose any safety problems.

(5) Statements of clear exaggeration which are not to be taken literally by the average end user (hyperbole) or statements of an abstract nature shall not require substantiation.

N/A to this product or claim made.

(6) A claim extrapolating (explicitly or implicitly) ingredient properties to the finished product shall be supported by adequate and verifiable evidence, such as by demonstrating the presence of the ingredient at an effective concentration.

We look at product efficacy and ingredient percentages before making a claim in all new product development and before highlighting what the product does. We assess the nature of the products usage when generating a formula and decide on acceptable levels per ingredient to make an effective product in line with European Safety standards. If we find that an unsafe amount of ingredient is needed to make the product effective then we do not use it, similarly if a safe percentage of an ingredient is ineffective at what it does then we do not use it and would look for an alternative.



(7) Assessment of the acceptability of a claim shall be based on the weight of evidence of all studies, data and information available depending on the nature of the claim and the prevailing general knowledge the end users.

As per above studies.

Section 4: Honesty

(1) Presentations of a product’s performance shall not go beyond the available supporting evidence.

We have not made any claims which are not supported or go beyond available studies. For example we use the word ‘Target’ as this is not making any specific promises to the consumer other than they it can be used for these issues.

(2) Claims shall not attribute to the product concerned specific (i.e. unique) characteristics if similar products possess the same characteristics.

N/A to these claims.

(3) If the action of a product is linked to specific conditions, such as use in association with other products, this shall be clearly stated.

N/A For this product

Section five: Fairness

(1) Claims for cosmetic products shall be objective and shall not denigrate the competitors, nor shall they denigrate ingredients legally used.

N/A For this product and is compliant.

(2) Claims for cosmetic products shall not create confusion with the product of a competitor.

L 190/34

Official Journal of the European Union


N/A For this product and is compliant.


  Section Six: Informed decision-making

(1) Claims shall be clear and understandable to the average end user.

We do not use complicated Jargon, misleading claims, misrepresented statements or exaggerated adjectives in our claims. We use simple statements to inform the consumer about the products benefits and how it can improve their skin in a clear and concise way.

(2) Claims are an integral part of products and shall contain information allowing the average end user to make an informed choice.

We developed this product in order to improve skin so it’s important to us to highlight this through product claims otherwise the product would have no use or selling points to the end consumer; so we highlight what the product does to the skin based on the scope of available research in order for them to pick a product which they need/want.

(3) Marketing communications shall take into account the capacity of the target audience (population of relevant Member States or segments of the population, e.g. end users of different age and gender) to comprehend the communication. Marketing communications shall be clear, precise, relevant and understandable by the target audience.

As our products are skincare and cosmetics; our marketing communications are appropriate for all consumers and specific people or groups would not be misled into buying the products. We do not coerce or shroud our claims in any mystery.

In line with CAP and ASA Guidelines and rules this product does not use claims such as leading”, “best”, or “cheaper” than any other brands of similar products.

Claims regarding the nature of experimental studies (Annex II of Technical document on cosmetic claims)


  1. ‘‘tolerance tested’’


The claim and 'tolerance tested' means that the product underwent tests under the supervision of a scientifically qualified professional intended to study its tolerance on a target group and that the results of those tests show that the product was well tolerated by this group.”

N/A to this product – we do not claim this.

  1. ‘’tested under medical supervision"


’The claim 'tested under medical supervision' indicates that the product underwent tests conductedunder the supervision of a medically qualified professional, such as a medical doctor or a dentist. Depending on the presentation of the claim, it may, for example, refer to a specific efficacy of the product or skin tolerance.

N/A to this product – we do not claim this.


  1. ‘’dermatologically tested’’


‘’The claim 'dermatologically tested' implies that the product was tested on humans under the supervision of a dermatologist. Depending on the presentation of the claim, it may refer to a specific efficacy or tolerance of the product. Consumer self-perception studies are not appropriate to support such claims. The same logic would apply to a claim referring to any other medical discipline.’’

N/A to this product – we do not claim this.


  1. ‘’clinically tested’’


‘’The claim 'clinically tested' refers to expertise, process or conditions under which the tests were carried out. 'Clinically tested' means that the product was tested on humans under the supervision of a medically qualified professional or another scientifically qualified professional according to a clinical protocol or in a clinical setting.’’

N/A to this product – we do not claim this.

'Free from' Claims
N/A to this product – we do not claim this.

'Natural' and 'organic' Claims

The terms 'natural' and 'organic' are not specifically regulated under the CPR, which controls the safety of cosmetic products. However, the provisions for cosmetic claims in Article 20 of the CPR and the Common Criteria apply equally to these claims as well.

The ISO Standard 16128 provides guidance on the definition of 'natural' and 'organic' (ISO 16128-1), and how to calculate the % of naturalness of ingredients in finished cosmetic products (ISO 16128-2). There is no legal requirement to comply with the ISO guidelines, it is a company decision.

N/A to this product – we do not claim this.

'Hypoallergenic' Claims

N/A to this product – we do not claim this.

'Not Tested on Animals' Claims

N/A as this is common law.

'Vegan' Claims

There is no legal definition of a vegan or vegetarian cosmetic product. Manufacturers may include claims that the product does not contain any animal-derived ingredients at all or is "suitable for vegans". Such claims are acceptable, but it is a legal requirement that all claims can be substantiated and are not misleading to the consumer.
N/A to this product – we do not claim this.


N/A to this product – we do not claim this.