Guides / Natural and chemical-free claims

Can I say "natural" or "chemical-free" on a soap label?

Published 22 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.

"Natural" is allowed when it is true, supported by evidence and not misleading; "chemical-free" is not, because it is not true of any soap. Article 20(1) of the cosmetics regulation forbids text, names, pictures and signs that "imply that these products have characteristics or functions which they do not have", and Regulation (EU) 655/2013 sets six common criteria that every claim on a cosmetic, "explicit or implicit", must meet. Neither text defines "natural", so the word is judged against the criteria. A bar of soap is a chemical, sodium salts of fatty acids, so a label that says it contains no chemicals fails criterion 2 of the six: truthfulness.

The six criteria, in the regulation's words

Regulation 655/2013 applies to "claims in the form of texts, names, trademarks, pictures and figurative or other signs that convey explicitly or implicitly product characteristics or functions" (Article 1), and makes the responsible person answerable for meeting them (Article 2). The Annex lists:

1. Legal compliance. No claim that the product has been authorised or approved by an authority, and no claim "which convey[s] the idea that a product has a specific benefit when this benefit is mere compliance with minimum legal requirements". Acceptability is judged by "the average end user ... who is reasonably well-informed and reasonably observant and circumspect".
2. Truthfulness. "If it is claimed on the product that it contains a specific ingredient, the ingredient shall be deliberately present", and ingredient claims must not imply the finished product has properties it does not have.
3. Evidential support. Claims "shall be supported by adequate and verifiable evidence", proportionate to the type of claim; hyperbole that no one takes literally needs none.
4. Honesty. Presentations of performance "shall not go beyond the available supporting evidence", and a claim may not attribute unique characteristics to a product when similar products share them.
5. Fairness. Claims "shall be objective and shall not denigrate the competitors, nor shall they denigrate ingredients legally used".
6. Informed decision-making. Claims "shall be clear and understandable to the average end user".

"Natural"

The word is undefined, so the questions are the criteria's questions. Is it true of this product, as the average end user would read it, and can you show evidence for it? A soap made from plant oils, water and lye, with an essential oil, is a stronger case than one coloured with a synthetic pigment and scented with a fragrance oil, and "made with natural oils" is a narrower and more defensible statement than "100 % natural", because the first describes ingredients that are deliberately present and the second describes the whole product. Under criterion 4, a claim that every handmade soap could make is not a unique characteristic of yours. Keep the evidence for the claim in the product information file, where Article 2 of the claims regulation expects it.

"Chemical-free", "no chemicals", "non-toxic"

Everything in a soap is a chemical, including the water, so "chemical-free" cannot be true and fails criterion 2 before any other question arises. "Non-toxic" and "safe" make a claim about the product's safety that, read by the average end user, implies a benefit over other cosmetics; every cosmetic placed on the market must be safe under Article 3 of the cosmetics regulation, so the claim presents "mere compliance with minimum legal requirements" as a benefit, which criterion 1 rules out. (For candles and other CLP-labelled products the same words are banned outright by Article 25(4) of CLP; the rule for cosmetics is the criteria, not a list of words.)

"Free from" and "without"

A "free from X" claim about an ingredient that is banned in cosmetics presents compliance as a benefit and fails criterion 1. A "free from X" claim about an ingredient that is lawfully used in other products runs into criterion 5, which forbids denigrating ingredients legally used, and the average-end-user test in criterion 1, since the claim implies the ingredient is something to avoid. The claims regulation does not list which words are acceptable; it gives the tests. The wording that passes them most easily says what the product contains rather than what it does not.

Where the line sits on a soap label

• The ingredient list is not a claim; it is the Article 19 particular, and it stays factual however the front of the label is worded.
• A product name is a claim if it conveys a characteristic ("Pure", "Gentle", "Detox"), because Article 1 of the claims regulation includes names and trademarks.
• Pictures count too: a leaf, a botanical drawing or a "no chemicals" badge conveys the same implicit claim as the words.
• The responsible person, which for a maker selling their own soap is the maker, is the one who must be able to substantiate each claim.

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