Efficacy Claims on Product Detail Pages: Wording That Can Easily Cause Problems
Expressions that make cosmetics ads look like they’re for medicines can easily cause problems. I’ve put together some common examples.
Examples of Rephrasing
- Treats acne
- Alternative Wording
- Sebum and dead skin cell care, for acne-prone skin (within the scope of recognized functional claims)
- Reduces inflammation
- Alternative Wording
- Helps soothe the skin
- Removes wrinkles
- Alternative Wording
- Helps improve the appearance of wrinkles (when recognized as a functional cosmetic)
- 100% effective
- Alternative Wording
- Usage experience and satisfaction survey results (with supporting evidence specified)
| Wording to Avoid | Alternative Wording |
|---|---|
| Treats acne | Sebum and dead skin cell care, for acne-prone skin (within the scope of recognized functional claims) |
| Reduces inflammation | Helps soothe the skin |
| Removes wrinkles | Helps improve the appearance of wrinkles (when recognized as a functional cosmetic) |
| 100% effective | Usage experience and satisfaction survey results (with supporting evidence specified) |
0
The key question is whether the wording could be read as saying that the product changes the skin’s structure or function, or cures a disease. Rather than looking at a single phrase in isolation, consider the impression consumers get from the detail page as a whole, including photos, before-and-after comparisons, user reviews, and footnotes.
For example, “treats acne,” “reduces inflammation,” “improves atopic dermatitis,” “cell regeneration,” and “removes pores” could be misunderstood as claims about medicinal effects. It’s safer to narrow the subject and effect to what has actually been substantiated, using wording such as “helps keep skin hydrated,” “smooths the look of skin texture,” or “temporarily covers redness.” However, simply switching to milder wording doesn’t automatically make it acceptable; you also need to check the test data and the product’s functional classification and labeling requirements.
In practice, just as important as searching for prohibited words is whether the supporting evidence precisely matches the sentence. For instance, it may be risky to extend moisturizing test results into a claim of “barrier recovery,” or to present research results on an ingredient as if they were efficacy results for the finished product. Enforcement standards can change, so it’s best to check the latest MFDS guidelines and consult your internal review team before posting.