Claim Substantiation
Product Rose Water and Neroli FACE TONER
Qualitative research analysis based on
evidence, statistic and research.



Rosa Damascena water - 99%
Preservative K (Benzyl alcohol, Phenoxyethanol, Potassium sorbate, Tocopherol) – Combined 1%


Product Claims to be Substantiated:

1) This multi-purpose natural toner hydrates, calms and nourishes skin. Perfect for people with sensitive and dry skin. It can help to get rid of any inflamed skin, eczema, breakouts and even acne. Its also extra healing and great for scars, cuts and wounds. Cleanses skin making it less prone to Spots, Pimples and Blemishes

A more subtle skin enhancement can be achieved with rose water. Extracted from roses, it contains antioxidants and antibacterial properties that can improve skin barrier function. Due to the lower content of active components present in contrast to essential oils, it strengthens the skin in a very gentle manner.
Scardelli, L. (2018, February 16). The Uplifting, Hydrating Power of Rose Water Mists. Retrieved September 29, 2018

2) Balances skins PH and controls excess oils with Anti-oxidants and Anti-microbial qualities. Gently protects against pollution and UV exposure.

Rose water has been found to have Anti-microbial qualities in a lab study, that is linked to the skin’s balance of bacteria (its microbiome). It’s now understood that a good balance of bacteria is vital for healthy skin. The key is to combat pathogens while preserving a balance of microbes that support functions such as healthy immune response to allergens, or controlling inflammation. Acne and other skin disruptions, such as dermatitis, are now understood to be connected to the skin’s microbiome.  Anti-oxident qualities of rose water are help to protect cells from stress, for example from UV exposure or environmental pollutants. Anti-inflammatory qualities are linked to helping relieve signs of inflammation, such as redness.
Eman M. Halawani (2014) Antimicrobial activity of Rosa damascena petals extracts and chemical composition by gas chromatography-mass spectrometry

3) Has anti-inflammatory properties so it helps to kill bacteria so can be used to target Breakouts, Oily Skin, Spots and pollutants.

A study also had another exciting discovery. Along with its anti-inflammatory effect, the topical application of rose oil to the skin reduced the immune system chemicals called neutrophils. Neutrophils, a type of white blood cell, while they mean well, can be a cause behind the development of acne. Rose oil was also found to be very effective at killing bacteria, although P. Acnes were not included in the study.
Eman M. Halawani (2014) Antimicrobial activity of Rosa damascena petals extracts and chemical composition by gas chromatography-mass spectrometry


4) Can be used as part of Spa Treatments, Promotes the feeling of wellbeing and calmness.

One of the effects of R. damascena on central nervous system is its hypnotic effect. The ethanolic, aqueous and chloroformic extracts from R. damascena were used for hypnotic effect in mice. The ethanolic and aqueous extracts in doses of 500 and 1000 mg/kg significantly increased the pentobarbital induced sleeping time in mice which was comparable to diazepam. However, the chloroformic extract has not shown to have hypnotic effect. Rakhshandah H, Hosseini M, Dolati K. Hypnotic effect of Rosa damascena in Mice. Iran J Pharmac Res. 2004;3:181–185.
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Rakhshandah H. Comparative hypnotic effect of Rosa damascena fractions and Diazepam in Mice. Iran J Pharm Res

Two studies above were on mice however there are many historical and traditional practices which use rose water to calm and heal the mind particularly in a therapeutic context. The Rose scent and rose water concentrate has been shown to relax and calm the mind which does have a beneficial effect on stressed minds.
Momeni T, Shahrokhi N. Essential oils and their therapeutic actions. Tehran, Iran: Tehran University. Press; 1991

Rose oil heals depression, grief, nervous stress and tension. It helps in the reduction of thirst, healing old caugh, special complaints of women, wound healing, and skin health. Vapor therapy of rose oil is helpful for some allergies, headaches, and migraine.
Pharmacological Effects of Rosa Damascena

Mohammad Hossein Boskabady,1,* Mohammad Naser Shafei,1 Zahra Saberi,1 and Somayeh Amini2
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Zargari A. Medicinal plants. 5th ed. Tehran: Tehran University Press; 1992
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Momeni T, Shahrokhi N. Essential oils and their therapeutic actions. Tehran, Iran: Tehran University. Press; 1991


After significant research, case studies, trials and appropriate scientific scalable studies we think that the claims made by us regarding retinol and Rose Water are well within the bounds of accuracy and are in no way inflated, presumptuous or misleading. Rose Water  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.

 ‘’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

11.7.2013

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.

Halal


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