Case Study: Evaluating the Use of Raw Material Supplier Data for Cosmetic Claims Substantiation

Introduction

In the competitive cosmetics industry, substantiating product claims with robust evidence is a

necessity for regulatory compliance and consumer trust. With increasing emphasis on

transparency and efficacy, brands often encounter questions about whether raw material

supplier data is sufficient to support claims. This case study explores a recent scenario in which

a client inquired about using supplier data for claim substantiation, leading to an in-depth

analysis of the implications, limitations, and risks associated with relying solely on such data.

Part 1: The Risks of Relying on Raw Material Supplier Data for Claims

The Supplier’s Interest and “Grading Their Own Homework”

Raw material suppliers are, understandably, focused on promoting their ingredients’

effectiveness. Consequently, they may present data with inherent bias, as their primary goal is

to encourage product purchases rather than to substantiate claims for end-use consumers. This

potential conflict of interest, combined with the selective presentation of data, often means that

supplier-provided documentation—commonly in the form of “Sell Sheets”—may showcase

limited or favorable evidence. The concept of "grading their own homework" refers to the supplier essentially evaluating their own ingredient’s efficacy, which can lead to overly optimistic or incomplete conclusions.

A Case Example: Misleading Claims in Supplier Documentation

In one example, a supplier’s Sell Sheet for apple extract claimed benefits such as "anti-aging"

and "increased cell proliferation by 16% after 6 days." On further inspection, however, there was

no relevant study provided to substantiate these specific claims, and the limited studies

referenced did not meet statistical or cosmetic relevance standards. Furthermore, the extract’s

benefit as a biostimulant was related primarily to agricultural applications, underscoring the risk

of misinterpreting such data for cosmetic purposes.

Best Practices for Using Supplier Data

Given the limitations, it is prudent to regard raw material supplier data as preliminary

information only. Suppliers often provide these data to illustrate potential benefits, which can

be useful as a starting point for exploring claims but are insufficient for final substantiation.

Independent, product-specific testing remains the gold standard for claims validation, ensuring

that claims are accurate, relevant, and scientifically grounded.

Part 2: Ingredient-Specific Claims and the Complexities of Finished

Formulas

Understanding Claim Implications: Ingredient Benefits vs. Finished Product Efficacy

A recurring issue is the assumption that an ingredient’s benefits, as demonstrated in supplier

data, can be directly translated to the finished cosmetic product. For example, if a supplier’s

study shows that watermelon extract contains vitamins A, B, and C, this does not automatically

mean that these vitamins will be available or active in the final product formulation. There are

several factors that influence the efficacy of an ingredient once incorporated into a final product,

including the formulation matrix, concentration levels, and potential interactions with other

ingredients.

Importance of Ingredient Concentration and Formulation Context

Claims based on an ingredient’s benefits hinge on the actual concentration of the active

ingredient within the finished product. Consider a hypothetical ingredient, "Super Watermelon Extract," which is advertised as effective at 2% concentration. If this extract is only 10%

watermelon extract and the brand uses the ingredient at 2% in the final formula, the actual

concentration of watermelon extract in the product is only 0.2%, which is likely insufficient to

yield any meaningful effect. This discrepancy can lead to regulatory scrutiny and reputational

risk if consumers feel misled by the implied claims.

Direct vs. Implied Claims: Legal and Regulatory Implications

The line between factual and implied claims can be delicate. Even if a brand only states that a

product "contains vitamins," consumers may reasonably expect these vitamins to deliver a

specific benefit, such as skin nourishment or hydration. Regulatory bodies scrutinize claims that

may imply efficacy beyond the ingredient’s true contribution to the finished product, meaning

brands must ensure their statements are not only technically accurate but also contextually

clear to consumers.

Conclusion: Ensuring Validity in Cosmetic Claims Substantiation

This case highlights the critical importance of substantiating claims through independent,

formula-specific testing rather than relying on raw material supplier data alone. Supplier data,

while potentially insightful, is often insufficient due to its potential bias, lack of comprehensive

testing, and inability to account for the final product formulation. Brands are encouraged to use

such data as a preliminary guide but should pursue independent substantiation methods to

verify each claim’s validity. Ultimately, by adopting best practices in claim substantiation, brands can bolster consumer trust, mitigate regulatory risks, and differentiate themselves in an

increasingly transparent market.