Neither word is defined, and that is the problem
Founders frequently ask what the legal definition of clean beauty is. There is not one, in the sense they mean. Cosmetic products are regulated on the basis of safety, composition, labelling and the claims made about them, not on the basis of marketing categories the industry invents.
The absence of a definition is often read as permission. It is closer to the opposite. Where a term has no fixed meaning, the assessment falls back on how consumers are likely to interpret it in context, and consumers interpret these words expansively.
An undefined word does not mean nothing. It means whatever your customer reasonably takes it to mean, and that is the claim you own.
What consumers actually hear
The risk with clean is that it is heard as a safety claim: this product is safe and, by implication, others are not. That implication is the difficulty. Cosmetic products placed on the market are required to be safe, and a claim that positions your product as the safe option can imply that compliant competitor products are unsafe.
The risk with natural is different. It is usually heard as a composition claim, meaning made of things that grew rather than things that were synthesised. Where a product contains preservatives, emulsifiers or synthetic actives, as most stable cosmetic products do, an unqualified natural claim can mislead about what is actually in the pack.
Free-from claims carry a third risk. A statement that a product is free from a particular ingredient can imply that the ingredient is harmful. Where that ingredient is lawful and assessed as safe, the claim can denigrate it without evidence. This is a well-recognised problem area in cosmetic claims and it is worth checking current guidance before using the format.
| Format | How consumers read it | Risk |
|---|---|---|
| Clean | Safer than other products | Implies competitor products are unsafe |
| Natural | Not synthetic, at all | Misleads where the formulation contains synthetics |
| Free from X | X is harmful | Denigrates a lawful, assessed ingredient |
| Ninety per cent natural origin | A measured proportion | Manageable, if the method is stated and evidenced |
| Made to our published standard | A defined, checkable position | Lowest, because you defined the term |
Source: Framework is this paper's own; the underlying obligations sit in cosmetics, advertising and consumer protection rules.
Orientation only, not legal advice. Claim assessment turns on the specific wording, the product and the context in which consumers see it.
The framework that does apply
Although clean and natural are undefined, the framework around them is not.
- Cosmetic products must be safe and are subject to a safety assessment and a product information file, with a designated responsible person. The regime is enforced through trading standards and overseen by the Office for Product Safety and Standards.
- Claims are advertising, on pack and off it, and are assessed under the advertising codes as consumers would understand them.
- Misleading commercial practices are addressed by consumer protection law, which covers misleading actions and omissions.
- Environmental claims made alongside natural positioning are subject to the Competition and Markets Authority's Green Claims Code.
- Any claim that a product prevents or treats a condition can move it out of the cosmetic category entirely, which is a classification question rather than a marketing one.
The Cosmetic, Toiletry and Perfumery Association publishes accessible material on how cosmetic claims work in practice, and it is a sensible starting point before a brand commits to a positioning built on these words.
Using the words without creating an unfunded claim
Brands that use this language well share four habits.
They define the term themselves, visibly. A published standard, on the site, saying exactly what the brand means: which ingredient groups it excludes, what sourcing standard it applies, what testing it does. A self-defined term with a published definition is a much stronger position than an undefined adjective.
They keep the claim about composition, not safety. Saying what is in a product and where it came from is factual. Saying that this makes it safer is a claim about other products as well as your own.
They qualify percentages precisely. Where a proportion of natural origin content is claimed, it should be calculable and evidenced by a defined method, and the basis should be stated.
They avoid implied comparisons. Language positioning the product against an unnamed category of nasty alternatives is the fastest route to a problem, because the comparison is unsubstantiated and denigratory.
| Claim relies on | Evidence to hold |
|---|---|
| Ingredient origin | Specification and documentation from the supplier |
| A percentage | The calculation and the stated method |
| A performance effect | Testing appropriate to the claim as consumers read it |
| An environmental benefit | Substantiation covering the whole life of the product |
| A comparison | Evidence about the products being compared |
Source: Working model used by this paper, not a measurement.
Supplier-provided claim wording is about the raw material. Check that it holds for your finished formulation at your inclusion level.
What substantiation looks like
Whatever you claim, you should be able to evidence it in the form a consumer would read it. That means holding, before publication:
- The specification and origin documentation for every ingredient the claim relies on.
- The calculation behind any percentage, with the method stated.
- Any testing you rely on, with enough detail to know what was tested and how.
- A record of the claim wording that was approved and when.
Suppliers frequently provide claim wording. Check it applies to your finished product, in your context, at your inclusion level. A claim that is accurate about a raw material is not automatically accurate about a formulation that contains a small percentage of it.
Where natural meets environmental claims
Natural positioning tends to attract environmental language, and environmental claims are subject to specific expectations. The Green Claims Code sets out principles including that claims should be truthful and accurate, clear and unambiguous, should not omit or hide important information, and should be substantiated.
Two frequent errors: claiming a benefit for the whole product on the basis of one component, and using a general term such as eco-friendly where a specific claim could be made instead. Specific claims are both safer and more persuasive. That is covered in green claims and sustainability language that survives scrutiny.
The strategic question underneath
Worth asking before building a brand on these words at all: is clean or natural a position, or is it a category convention? In a market where a large proportion of new independent brands use the same language, the words are close to a category default, which means they do not distinguish you and they do carry risk.
A brand with a specific, published standard has something to say. A brand with an unqualified adjective has adopted a convention and inherited its liabilities. This is the same argument made in why so many beauty brands look the same, applied to language rather than to design.
A practical position for a small brand
If you want to use this language, the defensible version looks like this. Publish your own standard and hold to it. Make composition claims, not safety claims. Qualify every percentage and hold the calculation. Avoid free-from claims about lawful, safe ingredients. Keep environmental claims specific and evidenced. And review the wording whenever you reformulate, because a claim that was accurate about the previous batch is not automatically accurate about this one.