Beauty Supplements & Compliance
What brands need to know when launching food supplements in the EU and GB
The concept of ‘Beauty from within’ has been around for a few years now and it seems that it is well and truly here to stay. Consumers are becoming increasingly aware of the connection between their overall health and their physical appearance and are looking beyond their beauty cabinets for solutions to their everyday skin and hair concerns. As a result, nutritional supplements targeting skin, hair, and nails have become a booming market, with consumers seeking ingestible solutions to complement their topical skincare and haircare routines. This has created space in the marketplace for beauty brands to expand their portfolio over to the food supplement aisle. However, for cosmetics brands entering the food supplement space, transitioning to new compliance considerations brings new challenges with the landscape for food supplements being very tightly regulated.
Understanding the regulatory divide between cosmetics and food
Cosmetics are defined under the Cosmetic Regulation in the EU/GB respectively and are strictly for external use, with their purpose being to cleanse, perfume, change appearance, protect, or keep in good condition the external parts of skin, hair, and nails. In contrast, food supplements fall under various Food Regulations and are classified as food products intended to supplement the diet with vitamins, minerals, or other substances to have a nutritional or physiological effect. This means the full set of food legislation applies in addition to the specific Food Supplement law.
Understanding the definitions and boundaries is essential because the formulations, safety substantiation, labelling and claims for food supplements are each the subject of different legal instruments. Coming from the cosmetic industry, one surprising aspect may be that while cosmetics cannot make claims about physiological or systemic effects, food supplements can although they must comply with health claim regulations under the Nutrition and Health Claims Regulation (NHCR) and so still only make ‘health’ claims and not medicinal claims.
Launching a food supplement
For cosmetics companies venturing into the food supplement space, several regulatory aspects must be considered:
Product Classification: Ensuring that the supplement is correctly classified as a food product rather than a medicinal product is essential. Claims implying treatment or prevention of disease such as hair loss or certain skin conditions, could reclassify a supplement as a medicine.
Ingredient Compliance: Certain Ingredients used in food supplements such as vitamins, minerals and additives must be permitted for use in foods via positive lists in the laws. Some botanical extracts commonly used in cosmetics may be banned or restricted in these products or have medicinal properties which would classify the product as a medicine.
Health and Nutrition Claims: Food supplement claims is a complex area. Beauty claims (e.g. glossy looking hair) must be backed by product-specific scientific evidence but structural claims must be pre-authorised claims connected to the inclusion of certain vitamins and minerals which must be present above certain levels in the product to support their claims. There is strict wording attached to these authorised claims and you will often see lots of food supplements on the shelf having very similar claims because of this!
Labelling and Advertising: Food supplements must comply with food labelling regulations, including clear ingredient listings, allergen information, and appropriate warning statements.
Cross-Market Consistency: Many beauty brands operate internationally, meaning they must navigate differing regulations in markets such as the GB, EU, and US and desire to have cross-market compliant labels. For food supplements, what is required in one market may not be allowed in another, requiring tailored compliance strategies. It can even be challenging for brands to have a single compliant food supplement label across the EU due to the amount of translation required for each member state.
Where to start
For cosmetics companies looking to move into the food supplement market, understanding and adhering to the regulatory landscape is critical. While the crossover between beauty and nutrition offers significant commercial potential, brands must approach this transition strategically, ensuring their products meet the necessary safety, labelling, and health claim requirements. By doing so, they can build trust with consumers while leveraging the beauty-from-within trend to its full potential.
We offer full support for brands looking to enter the food supplement space or can tailor our services to fit your needs. We are also offering our ready to buy report on our Bloom recommendations for choosing a food supplement partner. Get in touch today if you’re thinking about transitioning over to this exciting space!
Laila Manshi