Cosmetics Advertising Rules in the UK: A Guide for Beauty Brand Websites

Cosmetics advertising rules in the UK come from two places. The UK Cosmetics Regulation, enforced by OPSS and Trading Standards, controls product safety, labelling and claims. The CAP Code, enforced by the ASA, controls your marketing, including your own website and social media. Claims need evidence, and before-and-after images must show results customers can really expect.

For a beauty brand, the website is where those rules meet. Your product page is a label, an advert and a search listing all at once. This guide covers what the law requires before you sell, what the ASA expects from your claims and images, and how to build product pages that are compliant and still rank.

This is a practical overview, not legal advice. For new formulations or bold efficacy claims, speak to a cosmetic regulatory specialist.

The UK Cosmetics Regulation in brief

In Great Britain, cosmetics are governed by the retained version of Regulation 1223/2009, known as the UK Cosmetics Regulation. GOV.UK publishes a summary of how it applies in Great Britain. The essentials:

• A Responsible Person. Each product needs a UK-based Responsible Person who makes sure it complies. If you import products and there's no UK manufacturer or appointed representative, the importer is the Responsible Person by default.
• A safety assessment. Before a product is made available it must be assessed by a qualified professional to confirm it's safe.
• A Product Information File kept at the Responsible Person's address.
• Notification to OPSS. Every cosmetic sold to consumers in Great Britain must be notified through the Submit Cosmetic Product Notifications (SCPN) service before it's placed on the market. Products containing nanomaterials generally need notifying six months in advance.
• Labelling. OPSS's consumer guidance lists what packaging must show, including the Responsible Person's name and address, a batch number, precautions, the weight or volume, a use-by indication where required and the list of ingredients.

GOV.UK warns that failing to notify OPSS can lead to a fine and a prison term of up to three months. Northern Ireland uses the EU's notification portal instead, so check both if you sell across the UK.

Your website doesn't replace any of this, but it should never contradict it. If the label lists a precaution, the product page should show it too.

Cosmetic claims: what the law expects

The UK Cosmetics Regulation says labelling, marketing and advertising must not imply characteristics a product doesn't have. The detail sits in Commission Regulation 655/2013, retained in GB law, which sets six common criteria for cosmetic claims:

The "free from" claims that fill beauty websites fall under these criteria. "Free from" a substance that's banned in cosmetics anyway breaks the legal compliance criterion, and using "free from" to imply a legal ingredient is harmful breaks the fairness criterion.

Cosmetics advertising rules in the CAP Code

The ASA's remit covers your own website and social media as well as paid ads and influencer posts you pay for or control. Its general advice on beauty and cosmetics sets out what it looks for.

Efficacy claims need evidence on people

Marketers must hold evidence for any efficacy claim. The ASA has often judged in-vitro lab tests inadequate on their own, so human testing is generally expected. New or breakthrough claims usually need at least one controlled study on people.

The ASA also draws a line between two kinds of claim:

• Perception claims, such as "skin feels smoother" or "9 out of 10 said their skin felt hydrated", are based on consumer panels. They're lower risk if the panel is real and the claim is clearly worded as perception.
• Objective claims, such as "reduces wrinkles by 30%" or "fades dark spots", need measurement in a clinical setting. Using survey responses to support an objective claim is a common reason for complaints being upheld.

Medicinal claims

A cosmetic presented as treating or preventing a disease, or changing how the body functions, risks being classed as a medicine by the MHRA, which would need a marketing authorisation. On a product page that means care with words such as "treats acne", "heals eczema" or "stimulates collagen production". Talking about the appearance of skin ("helps reduce the appearance of blemishes") is the usual safe ground, provided you can support it.

Filters and production techniques

In February 2021 the ASA upheld complaints about Instagram stories from influencers promoting tanning products for Skinny Tan and Tanologist, because filters made the tan look darker than the product would achieve. The principle is simple: filters, retouching and lighting must not exaggerate the effect of the product being advertised. The ASA's guidance on production techniques explains where the line sits.

Retouching that has nothing to do with the product's effect, such as tidying a stray hair in a lipstick ad, is a different matter from smoothing skin in an ad for a wrinkle cream.

Before-and-after images on beauty websites

Before-and-after photos are among the most persuasive things a beauty brand can publish, and among the riskiest. The ASA's advice on before-and-after photos says:

• They're likely to be treated as implied efficacy claims, even without the words "before" and "after".
• You should hold signed and dated proof that the photos are genuine and haven't been manipulated.
• They must not exaggerate the product's efficacy, and you need evidence that the result shown is what consumers can generally expect.
• Retouching is acceptable only if it doesn't affect how well the product appears to work, and you should keep material showing whether retouching took place.
• A disclaimer won't rescue an image that's misleading in itself.

A practical before-and-after policy

1. Shoot both images with the same lighting, camera, angle, distance and expression.
2. Record the date, product, usage period and the model's consent.
3. Keep the unedited originals with your claim evidence.
4. Don't apply filters or skin smoothing to either image.
5. Use images that represent typical results from your testing, not your best case.
6. Apply the same rules to creator and customer photos you repost.

Product pages that comply and rank

A compliant product page and a well-optimised one want the same things: clear, accurate, specific information in real text.

Ingredient lists as text

Publish the full ingredient list, using INCI names, as HTML text on each product page, not only as a photo of the carton. Shoppers with allergies search for specific ingredients, screen readers can read text but not images, and search engines can match your page to ingredient searches.

Variant and shade pages

Shade ranges create SEO problems. If every shade has its own URL, use canonical tags so Google knows which version is the main page, or handle shades as variants of one page. Our guide to canonical tags explains the options. Check each page's title and description with the free meta tag checker, and make sure meta descriptions don't contain claims you couldn't make in the body copy.

Product schema

Add Product structured data with name, image, brand, price in GBP and availability for each shade or size. Only include review ratings that come from genuine reviews shown on the page. Validate the markup with the schema markup validator after every theme or app update.

Fast, accurate images

Swatch galleries and texture close-ups make beauty pages heavy. The free image compressor re-encodes photos in your browser, so unreleased launch images never leave your device. Check critical shades on a phone afterwards, because very aggressive compression can shift subtle skin tones. Our WebP and AVIF guide covers format choices, and the product image size guide covers dimensions.

Share previews for launches

Launch links travel through Instagram bios, WhatsApp and Pinterest. Run each launch URL through the Open Graph checker so the preview shows the right image and title.

Influencers and affiliate content

Influencer posts you pay for or control are your marketing. They must be clearly labelled as ads, and they can't make claims your own website couldn't. Give creators a short brief listing the claims you can support, the words to avoid, and a firm rule against beauty filters on content showing the product's effect.

A pre-launch checklist for cosmetics websites

1. Confirm the product is notified on SCPN and the Responsible Person details are correct.
2. List every claim on the product page, in images, FAQs, emails and social captions.
3. Match each claim to evidence: perception claims to a consumer panel, objective claims to clinical testing.
4. Remove or rewrite anything that implies treating a disease or changing body function.
5. Check "free from" claims against the common criteria.
6. Verify before-and-after images against your records and originals.
7. Publish the INCI ingredient list, directions and warnings as text.
8. Validate Product schema and check canonical tags on shade URLs.
9. Compress images and test the page speed on mobile.
10. Test the launch URL's share preview.

Our free tools for beauty and cosmetics brands page brings together the image, schema, Open Graph and email tools that fit this workflow.

FAQ

What are the main cosmetics advertising rules in the UK?

Cosmetic marketing must follow the UK Cosmetics Regulation, which bans implying characteristics a product doesn't have and sets common criteria for claims, and the CAP Code, which the ASA enforces across ads, websites and social media. In practice, every claim needs evidence, medicinal claims should be avoided and images must not exaggerate results.

Do I need to notify my cosmetic products before selling online?

Yes. Every cosmetic product sold to consumers in Great Britain must be notified to the Office for Product Safety and Standards through the SCPN service before it goes on sale, by a UK-based Responsible Person. Products containing nanomaterials generally need notifying six months ahead. Northern Ireland uses the EU's portal instead.

Can I use before-and-after photos to sell skincare?

You can, but the ASA treats them as efficacy claims. Keep signed and dated proof the photos are genuine, don't retouch or filter anything that affects how well the product appears to work, and only show results consumers can generally expect. A small-print disclaimer won't make a misleading image acceptable.

Can I use filters on beauty product images?

Not where they exaggerate the effect of the product. In 2021 the ASA ruled that influencer posts for tanning products were misleading because filters made the tan look darker than the product would achieve. Filters unrelated to the product's effect are lower risk, but the safest policy is no filters on product results.

Do I have to list ingredients on my website?

The law requires an ingredient list on the packaging. Online, customers expect to see it before buying, and publishing it as text on each product page helps people with allergies, screen reader users and search engines. Use INCI names and keep the list identical to the label.

What evidence do I need for an anti-ageing claim?

Objective claims such as reducing wrinkles generally need measurement in a clinical setting on people, not just lab tests or customer surveys. Perception claims such as "skin feels firmer" can rest on a properly run consumer panel if they're clearly worded as perception. Keep the study reports ready in case of a complaint.