What "Clean" Means in the EU, US and South Africa: A Retailer's Guide

"Clean" is one of the most useful words on a beauty shelf and one of the least defined. Customers use it as a shorthand for trust. Brands use it to signal a formulation philosophy. Regulators, for the most part, do not use it at all. For an independent retailer stocking brands across borders, that gap matters: the words on your shelf talkers, category pages and social posts are your claims, and you answer for them.

This guide looks at how the European Union, the United States and South Africa treat cosmetic labelling and claims, what has changed recently, and how to talk about "clean" in a way that stays honest and holds up to scrutiny.

The starting point: "clean" has no legal definition

None of the three markets covered here gives "clean" a legal meaning for cosmetics. That does not make the word off limits, but it means the word itself proves nothing. Every market does share one principle: a claim must be truthful, must not mislead, and must be backed by evidence if challenged.

In practice, "clean" tends to bundle together several more specific ideas: ingredient transparency, the absence of certain ingredients, natural origin, or lower environmental impact. Each of those ideas is regulated in its own way, and that is where the real compliance questions sit.

European Union: a tightly built framework

Cosmetics sold in the EU fall under Regulation (EC) No 1223/2009. Every product must be safe, must have a designated Responsible Person in the EU, and must be notified through the Cosmetic Products Notification Portal before it is placed on the market. Labels must carry the ingredient list using INCI names, the Responsible Person's name and address, and the other mandatory particulars set out in the Regulation.

Claims

Claims are judged against six common criteria in Regulation (EU) No 655/2013: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. A Commission technical document, applied since July 2019, adds guidance on "free from" and "hypoallergenic" claims. It is not legally binding, but it is widely followed. Its message is clear: a "free from" claim should not imply that a legally permitted ingredient is unsafe, or that a product is safer than others, because every cosmetic on the EU market must already be safe. Claiming a product is free from an ingredient that is banned anyway is also discouraged.

Two recent changes retailers should know

• Fragrance allergens. Regulation (EU) 2023/1545 adds 56 fragrance allergens that must be named on labels when present above set thresholds (0.001% in leave-on products, 0.01% in rinse-off). Products placed on the EU market from 31 July 2026 must comply. Units already on the market before that date may continue to be sold until 31 July 2028, so older stock can sell through, but check the dates with your supplier if you hold slow-moving lines.
• Green claims. Directive (EU) 2024/825, which applies from 27 September 2026, bans generic environmental claims such as "eco-friendly" or "green" unless they can be backed by recognised excellent environmental performance, and restricts sustainability labels that are not based on a certification scheme or set by public authorities. This reaches retailers directly: category headers such as "Green Beauty", shelf signs, banners and catalogue copy all count as commercial communications.

United States: MoCRA has raised the floor

The US regulates cosmetics under the Federal Food, Drug, and Cosmetic Act, now substantially expanded by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). Since its main obligations took effect at the end of 2023, brands have had to register facilities, list products, keep safety substantiation on file and report serious adverse events. Labels must also include domestic contact details through which adverse events can be reported.

Some pieces remain in progress. MoCRA requires the FDA to propose a rule on fragrance allergen labelling, and the agency's own timetable has slipped more than once; at the time of writing it had not been finalised. A rule on good manufacturing practice has been moved to the FDA's long-term list. Neither changes what you can stock today, but both are worth watching if you sell fragrance-heavy ranges in the US.

On language, the FDA has not defined "natural" or "clean" for cosmetics. Marketing claims are policed mainly by the Federal Trade Commission, which requires advertising to be truthful and substantiated, and "natural" claims have been the subject of enforcement and consumer lawsuits. Equally important is the line between cosmetic and drug: a claim to treat or prevent a condition can turn a cosmetic into a drug in the eyes of the regulator.

South Africa: an Act, an advertising code and the Consumer Protection Act

In South Africa, cosmetics fall under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972, administered by the Department of Health. Cosmetics-specific labelling and advertising regulations have been published in draft form in the past, so check the current position before relying on any one version. The Consumer Protection Act also prohibits false or misleading representations about goods, which applies to retailers as well as brands.

For day-to-day claims, the most practical reference is the Advertising Regulatory Board's cosmetic advertising appendix. It requires every claim, explicit or implied, to be supported by documentary evidence that is available on request. It sets out when a whole product may be called "natural" or "organic", with reference to SANS 16128 or an equivalent international standard, and says natural claims must not imply a product is safer than other cosmetics. "Free from" claims are allowed only if they are not the main selling point, do not disparage other products, and refer to an ingredient that is actually absent. Medicinal claims, such as healing or curing, are not acceptable for cosmetics.

What this means on your shop floor

The common thread across all three markets is simple: be specific, and be able to prove it. A few habits make that easier.

• Swap "clean" for what you actually mean. "Full ingredient list on every label", "fragrance-free" or "certified organic (with the certifier named)" are more useful to customers and easier to stand behind.
• Use the brand's own wording. Base shelf cards and product copy on the claims the brand makes and can substantiate, rather than adding your own. Where a listing on Clean Otter includes an ingredient list or brand-supplied details, use those as your source.
• Audit your category names. If you sell in the EU, review any "green", "eco" or "natural" section headers now that Directive 2024/825 applies.
• Keep claims cosmetic. Talk about how a product looks, feels and smells, and avoid words that suggest treatment.
• Ask for documents. For certified or "free from" claims, it is reasonable to ask the brand for the certificate or supporting information before you promote the claim yourself.
• Check fragrance stock dates. For EU sales, confirm that new fragrance and scented-product deliveries carry updated allergen labelling.

This article is general information for retailers, not legal advice. Rules change and their interpretation varies, so confirm requirements with your national regulator or a qualified regulatory adviser before acting on them.

Stock with confidence

A well-chosen range makes these conversations easier. Browse the Skincare collection to see the brands we carry, and visit our FAQ for answers on ordering, shipping and trade terms. If you are new to Clean Otter, you can apply as a buyer and start ordering at wholesale prices.