We have carried out a qualitative analysis from our customers by open ended questionnaire and sampled 250 people of varying age, sex and lifestyles over 4 years. These are the results we have collated:

99% of customers reported softer, smoother skin after using a coffee scrub from us
95% of users found their skin complaints (if any) had improved and or cleared up

76% of people used less moisturiser as their need decreased from using the scrubs

79% liked or loved the scent of their chosen purchase

73% of customers liked and or loved the plastic free Kraft bags

89% of people fed back to us that they have recommended the product to other people and 80% of people have repurchased a Grounded Body Scrub since their first purchased with 63% of people trying another grounded product.

Claim Substantiation
Qualitative research analysis based on
evidence, statistic and research.

basis of scrubs and actives

Coffea Robusta Seed Powder / Extra fine Coffee powder Sucrose / Brown Sugar Sodium Chloride / Sea Salt Prunus Amygdalus Dulcis oil / Sweet Almond Oil Tocopheryl Acetate / Vitamin E Cocos Nucifera / Coconut Oil

Product Claims to be Substantiated:

1) Smooths/Exfoliates Skin

Evaluation of the antioxidant and physical properties of an exfoliating cream developed from coffee grounds

Stefany Delgado‐Arias, Stephany Zapata‐Valencia , Yuliana, Cano‐Agudelo , Juan Osorio‐Arias, Oscar Vega‐Castro


‘’In this study, an exfoliating body cream was developed from the SCGs, which is an agro‐industrial waste generated by the coffee processing industry. It was determined that the hot air‐drying process is a suitable method for the processing of coffee grounds since a stable product with low moisture is obtained. In addition, it was also possible to obtain an exfoliating cream for the body with antioxidant and polyphenol content, with textural and exfoliation properties similar to that of a commercial cream. The main application of this research is that it gives full use to the waste of coffee to obtain a cosmetic product with sensory, textural, and exfoliating properties of this type of products, being a processing alternative for agro‐industrial waste generated in the coffee processing industry.’’

Evolution of caffein from drink to exfoliant agent

  1. S. Sharmiwati, S. Fazidah, A.B. Noorhelinahani
  2. Roshanizah, UniKL MSI

    The aim of the present study was to compare the effectiveness and the safety of the coffee as the exfoliating agent for body and facial scrubs. Caffeine is being increasingly used in cosmetics due to its high biological activity and ability to penetrate the skin barrier. This alkaloid is frequently used as a hydrophilic model substance in human and animal skin penetration. The encapsulation efficiency of caffeine was found to be very low due to the instability of the liposome structure and the water solubility of caffeine. However, the amount of absorbed caffeine was nearly independent of the encapsulation of efficiency and the vesicle size, but increased with the increase of concentration. Finally, our results suggest that the methodologies and protocols used in this study may help in choosing the most appropriate evidence for coffee as agents for skin exfoliating treatments.


Salt sorbet facial and body scrub – Jacob Revivo

The present invention is a salt sorbet facial and body scrub which has enhanced properties to deep clean skin, exfoliate dead skin cells in an efficient manner, and at the same time not damage sensitive skin, especially on a woman's face. It is an object of the present invention to provide an improved facial and body scrub which will provide deep cleaning action to cleanse skin pores in an efficient manner and also to exfoliate skin in an efficient manner. It is a further object of the present invention to provide an improved exfoliating facial and body scrub which although effective for cleaning and exfoliating skin, is not so abrasive as to create any damage to sensitive skin areas, especially on a woman's face. It is a further object of the present invention to provide a cost efficient combination of elements and process for creating an improved facial and body scrub.

2) Moisturises Skin

The uses and properties of almond oil

Zeeshan Ahmad
Historically, almond oil had been used in Ancient Chinese, Ayurvedic and Greco–Persian schools of Medicine to treat dry skin conditions such as psoriasis and eczema. Further, it is through anecdotal evidence and clinical experiences that almond oil seemingly reduces hypertrophic scarring post-operatively, smoothes and rejuvenates skin. Almond oil has emollient and sclerosant properties and, therefore, has been used to improve complexion and skin tone. Further studies looking into the use of almond oil post-operatively for the reduction of scarring are suggested.


A Randomized Double-Blind Controlled Trial Comparing Extra Virgin Coconut Oil with Mineral Oil as a Moisturizer for Mild to Moderate Xerosis

Anna Liza C. Agero, Vermén M. Verallo-Rowell.

Coconut oil consists of triglycerides (made up of glycerol), combined with stable saturated medium-chain fatty acids (49% C12 lauric acid, 7% C10 capric acid, and 8% C8 caprylic acid). Coconut oil has the same occlusive and hydrophobic characteristics that mineral oil has. Unlike with mineral oil, fatty acids found in the coconut are found naturally in the skin, and the breakdown products, particularly of coconut's lauric acid, have been found to have antiseptic properties.

In vitro anti-inflammatory and skin protective properties of Virgin coconut oil

Author links open overlay panel
Sandeep R.Varma  Thiyagarajan O.Sivaprakasama

Virgin coconut oil (VCO) has been traditionally used as moisturizer since centuries by people in the tropical region. Clinical studies have revealed that VCO improves the symptoms of skin disorders by moisturizing and soothing the skin. 

Virgin coconut oil (VCO) is processed natural oil obtained from fresh, mature coconut kernel.19 It displays several biological activities like anticancer, antimicrobial, analgesic, antipyretic, and anti-inflammatory properties in vivo.202122 Traditionally, coconut oil is used to moisturize and treat skin infections. The emollient effect of coconut oil has been successfully demonstrated in atopic dermatitis patients, thereby showing that coconut oil is a potent natural emollient to be used in treatment of xerosis.23 The effectiveness and safe use of VCO for its application as a therapeutic moisturizer has been reported earlier for mild to moderate xerosis.24 However, there is no report available on anti-inflammatory and skin barrier function of VCO in vitro.

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 (exfoliating & moisturising) 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 Retinol 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 on the products ingredients.

(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.