What Are the EU Rules For Vegan Cosmetic Claims and Certification?
Vegan cosmetics are not specifically defined under EU cosmetics legislation and do not require separate registration or certification. However, companies using the term ‘vegan’ must ensure that claims are truthful, substantiated and not misleading, supported by appropriate documentation, supplier information and traceability.
In recent years, the cosmetics industry has witnessed a rapid expansion of products marketed as ‘vegan’, reflecting a broader cultural shift toward ethical consumption and sustainability.
Consumers are paying increasing attention not only to the performance of cosmetic products but also to their origin, composition, and impact on animal welfare. As a result, the term ‘vegan’ has become a powerful marketing tool.
Despite its widespread use, however, ‘vegan cosmetics’ remains a concept without a formal legal definition under European legislation. This absence creates a complex regulatory environment in which voluntary claims, private certifications, and general legal principles must be carefully aligned to avoid misleading consumers.
What Does ‘Vegan’ Mean Under EU Cosmetic Regulations?
From a regulatory perspective, the cornerstone of cosmetic legislation in Europe is Regulation (EC) No 1223/2009, which governs cosmetic product safety, composition and labelling.
However, the Regulation does not define, regulate or provide specific criteria for the use of the term ‘vegan’. As a result, vegan claims are considered voluntary marketing claims rather than regulated legal categories.
In practical terms, a cosmetic product is generally considered vegan when it contains no ingredients of animal origin and no animal-derived substances have been used at any stage of formulation or production.
This includes not only obvious ingredients such as beeswax or collagen, but also less apparent substances, including processing aids, carriers and additives that may be derived from animal sources.
It is also important to clarify the relationship between vegan claims and animal testing. Within the European Union, animal testing for cosmetic purposes is already prohibited, making ‘cruelty-free’ a legal baseline rather than a differentiating claim.
The concept of vegan cosmetics therefore goes beyond testing and focuses primarily on the origin of ingredients and supply chain integrity.
Is There a Specific Registration Process For Vegan Cosmetics?
A frequent misunderstanding among both new market entrants and consumers is the belief that vegan cosmetics require a dedicated registration or approval process. In reality, no such procedure exists within the EU regulatory system.
All cosmetic products, regardless of whether they are marketed as vegan, must follow the same compliance pathway.
This includes notification through the Cosmetic Products Notification Portal (CPNP), the preparation of a Product Information File (PIF), and the completion of a Cosmetic Product Safety Report (CPSR) conducted by a qualified assessor.
Where vegan cosmetics differ is not in their regulatory pathway, but in the substantiation of the claim itself.
The use of the term ‘vegan’ is governed by Commission Regulation (EU) No 655/2013, which sets out the common criteria for cosmetic claims. According to this Regulation, claims must be truthful, supported by evidence, and not misleading to the consumer.
This means that companies must be able to demonstrate, through appropriate documentation, that their products meet the expectations associated with the term ‘vegan’.
In practice, this often requires detailed supplier declarations, traceability of raw materials, and a clear understanding of the entire supply chain.
Why Do Vegan Cosmetic Certifications Have Different Standards?
In the absence of a harmonised legal definition, private certification bodies have developed their own standards for vegan cosmetics.
While these certifications share a common objective — ensuring the absence of animal-derived ingredients — they can differ significantly in scope, rigour and methodology.
Some certification schemes adopt a relatively narrow approach, focusing primarily on ingredient lists and excluding any substances of animal origin.
Others take a more comprehensive view, extending their requirements to manufacturing processes, potential cross-contamination, and even packaging materials.
This diversity reflects the lack of a single regulatory benchmark and can create uncertainty for both companies and consumers.
A product that meets the criteria of one certification may not necessarily qualify for another, depending on how strictly the concept of ‘vegan’ is interpreted.
For companies, selecting a certification is therefore not only a technical decision but also a strategic one, influenced by target markets, brand positioning, and the level of credibility they wish to convey.
What Are the Main Vegan Cosmetic Certifications and How Do They Differ?
Several organisations have established widely recognised vegan certification schemes, each based on its own charter and verification process.
The Vegan Society is one of the oldest and most influential bodies in this field. Its certification requires that products contain no animal ingredients or derivatives and that no animal testing has been carried out or commissioned on behalf of the company.
Particular attention is also given to preventing cross-contamination during manufacturing.
Another important player is Vegan Action, which manages the ‘Certified Vegan’ label. While its core principles are similar, the certification process may differ in terms of documentation and verification procedures.
People for the Ethical Treatment of Animals (PETA) offers a widely recognised programme known as ‘Beauty Without Bunnies’, which includes both cruelty-free and vegan categories. However, its approach is often perceived as less stringent in terms of third-party auditing, relying more heavily on company declarations.
Each of these certifications is built upon a specific set of rules that define what is acceptable and what is not.
For companies, understanding these underlying principles is essential in order to ensure alignment between their formulations, processes, and marketing claims.
Can Cosmetic Brands Use Their Own Internal Vegan Standards Instead of Certification?
While many brands choose to rely on external certification bodies, others prefer to develop their own internal standards for defining and managing vegan products. This approach allows for greater flexibility and control, but it also requires a high level of internal discipline and documentation.
An internal vegan charter must clearly articulate the criteria used to classify ingredients, as well as the procedures for verifying supplier compliance and managing potential risks.
It should also address issues such as cross-contamination and traceability, ensuring that the vegan claim is consistently supported throughout the product lifecycle.
From a regulatory standpoint, the absence of third-party certification does not reduce the company’s responsibility. On the contrary, it places the full burden of proof on the responsible person, who must be able to demonstrate compliance in the event of inspections or challenges by authorities.
While internal standards can be robust and scientifically sound, they may lack the immediate recognition and consumer trust associated with established certification logos, particularly in international markets.
Can the Term “Vegan” Be Used Without Certification?
One of the most relevant practical questions is whether a company must obtain a vegan certification in order to use the term on product labelling. Under EU law, the answer is clearly no.
There is no legal requirement to obtain third-party certification before making a vegan claim. However, this does not mean that the claim can be used freely.
As with all cosmetic claims, it must comply with the principles set out in Regulation (EU) No 655/2013, ensuring that it is accurate, substantiated, and not misleading.
In particular, companies must avoid using the term ‘vegan’ in a way that suggests superior safety or regulatory compliance, as this could be considered misleading under the common criteria.
The claim should instead be presented as an ethical or compositional characteristic, supported by verifiable evidence.
In the absence of certification, this evidence must be maintained and generated internally, making traceability and supplier communication critical elements of compliance.
Conclusions on Vegan Cosmetic Claims and Compliance in the EU
The growing popularity of vegan cosmetics represents a significant evolution in the relationship between consumers and cosmetic products, reflecting broader societal concerns about sustainability and animal welfare.
At the same time, it highlights the limitations of the current regulatory framework, which does not provide a formal definition of the concept.
Within this context, companies must navigate a landscape shaped by general legal principles, voluntary certifications, and increasing scrutiny from both authorities and consumers.
The absence of a specific registration process or mandatory certification does not reduce the importance of compliance; rather, it shifts the focus towards substantiation, transparency, and credibility.
Ultimately, the successful use of the vegan claim depends on a company’s ability to align its formulation practices, supply chain management, and communication strategy with the expectations it creates.
In a market where trust is becoming as important as performance, this alignment is not only a regulatory requirement but also a key competitive advantage.
Do you have questions about vegan cosmetic claims or certification requirements?
Contact us and we will be happy to help ensure your products remain compliant and that all claims are appropriately substantiated.
Key Takeaways: Vegan Cosmetics and Regulatory Compliance in the EU
- The term ‘vegan’ is not defined under EU cosmetics legislation and is treated as a voluntary claim.
- Vegan cosmetics do not require a separate registration or approval process.
- Vegan claims must be truthful, substantiated and not misleading.
- Third-party vegan certification is not legally required to use the term ‘vegan’.
- Vegan certification schemes may differ in their scope, requirements and methodology.
- Companies must be able to demonstrate that their vegan claims are supported by appropriate documentation and traceability.
