"It cleared my skin in two weeks." The sentence is true: the creator lived it and says it in her own words. Ordered by a brand and paid for, it changes nature: it becomes a claim, a message that attributes a property to a product and that somebody has to be able to prove.
This guide covers foods, food supplements and cosmetics. It leaves aside medicines and medical devices, which fall under a separate regime covered by UGC in pharmacy and dermocosmetics, along with videos shot with a healthcare professional, whose own professional body adds its rules.
It is organised by kind of sentence, never by kind of product: in front of a script, the question is not "cosmetic or supplement", but "what does this sentence assert, and which text decides". With one French particularity: on top of the European framework sits a national layer that targets not the sentence, but the person saying it.
A claim is not an opinion
The line runs between what describes an experience and what attributes a result to the product. "I like the smell" stays an appreciation; "my skin stopped feeling tight once I started using it" attributes an effect, and the first person changes nothing.
"For me" softens the tone, not the regime: as soon as the video is ordered and paid for, the sentence is examined as if the brand had written it. Our guide on answering objections on video shows how to stay convincing without tipping into a promise.
A product simply given for free changes nothing: the absence of payment removes neither the commercial character nor the regime of the sentence, a question dealt with by the commercial collaboration disclosure.
The before and after
A claim does not need words. Two photos side by side say "this is what the product did", and the regime is the same as for a sentence: the pair has to be supported by an element of proof. The ARPP recommendation on cosmetic products (ARPP is the French advertising self-regulation body) frames the presentation of results.
The question to put to the creator is therefore not "do you have a before and after" but "what changed between the two shots". If the answer is the light or the angle, the pair is not proof.
The sentence that describes
A nutrition claim states, suggests or implies that a food has particular nutritional properties, because of what it contains, contains less of, or does not contain. Regulation (EC) No 1924/2006 closed the category: it lists the wordings that may be used and attaches a composition condition to each one. "Source of", "high in", "with no added sugars" are not adjectives, they are labels with a threshold.
A creator never says "source of fibre", they say "it is packed with fibre". Ordinary language does not take you off the list: a formula that means the same thing to the listener is the same claim. An adjective dropped on set therefore commits as much as a label wording, when nothing on the packaging ever authorised it.
A food supplement is a food, and that is what constrains it
Legally, a food supplement is a foodstuff, and that qualification decides the rest: it inherits the food regime for claims, and cannot be presented as preventing, treating or curing anything.
In France, it is declared to the DGCCRF (the French authority that polices commercial practices) before it is first placed on the market, and the declaration covers its presentation among other things. The ANSES runs nutrivigilance, which collects reported adverse effects. This is the category where the prohibited sentence comes out most spontaneously: the promise of the product is the effect.
The sentence that promises an effect
A health claim states, suggests or implies that a relationship exists between a food, or one of its components, and health. The definition is broad, and it catches sentences nobody thought were concerned. Europe authorises them one by one: only the claims entered on the European list of authorised health claims may be used, each tied to a substance, with a condition of use and a wording.
Three consequences for a script. The wording is constrained: a rewording only holds if it means the same thing to whoever hears it. The accompanying statements follow the claim to wherever it is spoken: a varied diet, the quantity to be consumed to obtain the effect, a warning for those who should avoid the product. And a vague reference, "good for immunity", is only used backed by an authorised claim.
The Nutri-Score spoken to camera
The logo is a voluntary display, and filming packaging that carries it raises no difficulty. The trouble comes from the added commentary: "it is rated A, so you can eat it every day". The score ranks comparable products against each other; it says nothing about how often to eat them. Turning a letter into a health benefit means formulating an unauthorised claim.
The sentences prohibited even when true
Some sentences are retrieved by no file at all, where intuition assumes a true statement is defensible.
Regulation (EC) No 1924/2006 rules out any claim referring to the rate or amount of weight loss. A creator who announces a number of kilos or a time frame leaves the framework even when telling the truth, photos to back it up. The same regulation rules out claims resting on the recommendation of an individual doctor: a video in which a named practitioner asserts that the product works is not a sturdier claim, it is a claim with no authorisation possible.
Unlike those two rules, which target the sentence, France has added one that targets the person publishing. Loi n° 2023-451 prohibits a creator from promoting acts of aesthetic surgery and medicine, along with products, processes, techniques or methods presented as comparable, preferable or substitutable for therapeutic acts, protocols or prescriptions. It applies whatever the category: a supplement presented as a replacement for treatment falls into it like an aesthetic injection.
Rewording, which turns a permitted sentence into a prohibited one
The slide does not happen in the brief but on set, when a written sentence becomes a spoken one, and it takes three forms. The intensifier: "contributes to" becomes "it repairs". The generalisation: the "for me" disappears in the edit and the effect becomes a rule. The chaining, the hardest to spot because its pieces are permitted separately: "it is high in this substance", then "this substance is good for that organ", build a cause and effect link nobody authorised.
Hence a rule: the brand writes the spoken version, not only the label version, and the brief for food brands sets out how to frame it.
The sentence to be proved
Cosmetics, for their part, do not work from a closed list, and that absence reads as a freedom when it is a reversal of the burden.
Regulation (EU) No 1223/2009 requires a product information file to be held by the responsible person, and every claim made about the product has to find its justification there. Regulation (EU) No 655/2013 sets the common criteria those claims answer to: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision making by the consumer. Three formulas pass for neutral and are not. "Dermatologically tested" says a test took place under supervision, nothing about its result: the brand has to be able to say which one, and the creator must not turn it into a medical guarantee. "Free from" claims are appraised against fairness: a formula suggesting that a legally authorised ingredient would be dangerous does not pass that filter. "Hypoallergenic", finally, presupposes that the risk of an allergic reaction has genuinely been reduced to a minimum, and never means zero risk.
Who enforces, and what it costs
In France a single authority covers both grounds, the DGCCRF, where several European neighbours entrust food and cosmetics to separate agencies: a brand selling both therefore has only one counterpart. It does not examine the label alone: the communication around the product is part of it, online posts included, and it can ask for the elements supporting a claim. The ANSES does not sanction: it assesses, and its opinions move the boundary of what may be said.
The penalty rarely comes through the claim alone: an unverifiable statement is qualified as a misleading commercial practice within the meaning of the code de la consommation (the French consumer code), and it is that qualification which carries it, with a fine that can be calculated on the campaign spend.
That leaves who answers. The creator is exposed as soon as they publish, the brand always is, because it ordered the message and holds, or does not hold, the file.
The two-column brief
The brief has two columns that do not obey the same rule. The first gathers the sentences that commit the product, each with two pieces of information: where it comes from, and who signed it. A sentence with no origin and no signatory is not approved, it is a sentence nobody refused.
The second gathers what the creator says in their own name: the texture, the gesture, what they did not like. It is free, and it is what converts. A customer review is picked up there only for what it describes of an experience: as soon as the review asserts a property of the product, it moves back into the first column, and our guide on customer reviews and UGC says where the line runs.
For every sentence in the first column, three moves.
- Qualify the sentence: does it describe a composition, promise an effect, is it excluded in principle, or does it call for a document?
- Trace it back to the text or the file that authorises it, and write the reference beside it.
- Name who signs it and date the approval, because an inspection asks for it.
| Kind of sentence | What is heard in the video | Governing text | What lets it through, or not |
|---|---|---|---|
| A description of composition | "It is packed with fibre" | Regulation (EC) No 1924/2006 | The composition condition attached to the wording |
| A promise of an effect | "It helps your defences" | European list of authorised health claims | The authorised wording and its accompanying statements |
| A sentence excluded in principle | "I lost weight very fast" | Regulation (EC) No 1924/2006 and loi n° 2023-451 | Nothing, an exclusion is not retrieved |
| A cosmetic property | "Dermatologically tested" | Regulations (EU) No 1223/2009 and 655/2013 | The product information file and its evidential support |
The objection is easy to guess: this framing would switch creators off. The constraint bears on a handful of sentences, the ones that speak about the product in place of the viewer; the gesture, the surprise, the honest disappointment stay free.
Sources
- Règlement (CE) n° 1924/2006 sur les allégations nutritionnelles et de santé
- Règlement (UE) n° 1223/2009 relatif aux produits cosmétiques
- Règlement (UE) n° 655/2013 sur les critères communs des allégations cosmétiques
- DGCCRF, « Allégations nutritionnelles et de santé »
- ANSES, « Les allégations »
- ANSES, « Les compléments alimentaires »
- ARPP, Recommandation « Produits cosmétiques » v8
- Loi n° 2023-451 du 9 juin 2023 encadrant l'influence commerciale
Checked on 19 September 2026. This guide is not legal advice. Where this guide and the official source disagree, the official source prevails.
