Something surprised me when I moved into health and wellness consulting after twenty years in pharma. There is so much room to use evidence well, and it rarely gets used. Consumers in this category genuinely want science. They want to trust what's on the label. And they're happy to pay a premium for a brand that takes them seriously. That's the opportunity sitting in plain sight, and most cosmetic claims in Australia don't make the most of it. There are three routes brand and ingredient owners take to a cosmetic claim. Two of them quietly burn margin you can't afford to lose. The third one builds the brand.
Route 1: The on-trend claim
You look at competitors. You look at what's working on Instagram. You write something to make a claim that sounds like the category. Anti-ageing, clinically proven, dermatologist-approved, natural. Feels safe. Here's the catch. The Australian Industrial Chemicals Introduction Scheme, AICIS, doesn't pre-approve cosmetic claims. The bite doesn't come from AICIS. It comes from the ACCC and the Australian Consumer Law, and they don't care what your competitors said. They care whether you can substantiate it. The ACCC has been surveilling cosmetic labelling in Australia for years and finds 20%-plus non-compliance in some sweeps. When they knock, or a retailer gets nervous, or a competitor lodges a complaint, you're paying for reformulation, repackaging, and lost shelf time you didn't budget for. There's a quieter cost too. Vague claims tell the consumer you don't have anything specific to say. Trust is earned through proof, not creative language.
Route 2: The over-engineered claim
The opposite extreme, and almost as common. A brand owner gets nervous about Route 1, so they swing the other way and decide they need proof. They commission a clinical study they don't really need. They pile on technical jargon. They spend significant money on data that doesn't actually map to the claim they wanted to make. Worse, the claim itself often ends up so cautious it loses the consumer. Hedged language full of "may" and "in some users" sits on the shelf looking apologetic. Here's something pharma taught me. Evidence isn't binary. There's a spectrum, from social proof, to consumer perception studies, to in-vitro work, to randomised trials. The skill is matching the right kind of evidence to the right kind of claim. Defensible isn't the goal. Defensible and commercially useful is.
Route 3: Evidence-led, the route that compounds
The third route is the one most brand and ingredient owners never get shown. It starts with two questions, in this order. First, what is the Product Ambition? What is the claim you actually want to make, and the position you want it to hold in the market? Second, what evidence do you have, and what evidence might you need to build, to legitimately support it? This is the first move in our seven-step process at Parallaxis, and it determines everything downstream. Most founders skip it. They start at the formulation, or worse, at the marketing brief. Ambition first, then evidence, is the order that protects margin. Done well, the evidence and the claim are deliberately matched. Sometimes the evidence is already there in your supplier dossiers and existing studies. Sometimes a piece of new evidence is worth building, like a targeted consumer perception study or a specific in-vivo measure. Either way, you're spending where it counts and not where it doesn't. The claim does commercial work because it's connected to a Product Ambition consumers actually care about. This is where evidence becomes advantage.
A gut check before you go
Three honest questions. Can you point to the specific evidence behind your most prominent cosmetic claim? If a major retailer asked for a substantiation pack, could you produce one promptly? Did you choose your claims based on what your data supports, or what your competitors are saying? If you flinched on any, you're probably on Route 1 or Route 2. Most early-stage brands are. Getting onto Route 3 usually isn't expensive. It just means starting from your Product Ambition. We work with supplements, skincare, functional food, MedTech and more, and the same approach applies across all of them. If you'd like a 15-minute claims health check, get in touch. Send me your top three claims and I'll tell you honestly which route you're on. Building a brand is hard enough without your own label costing you money.
Paul, Co-founder, Parallaxis