Hair loss claims – consumers and a borderline dilemma


*Corresponding author
1. Ayton Global Research, Somerset, United Kingdom
2. Callaghan Consulting International, Hamburg, Germany


Hair growth products in the EU are classified as borderline cosmetics, whereby claims are restricted, and from the regulatory perspective, taken on a ‘case by case’ basis. Such a position leaves many cosmetic products with applications in hair growth and hair loss in a dilemma — will their claims be challenged? The aim of the study was to establish the trends and patterns when consumers search for non-medicinal hair loss/hair growth products via online search engines, and to provide an understanding of the search terms they use when seeking non-medicinal hair loss/hair growth treatments. This commissioned consumer study demonstrates not only a gap between regulatory requirements and consumer understanding, but a real need for a better educational dialogue between the consumer, industry and regulatory bodies.

The distressing phenomenon of premature hair loss, is a multi-complex disorder affecting both men and women (1). It causes emotional stress, stress on self-perception and image, and on the quality of life. Nowadays there is an increasing demand for natural products to treat hair loss. However the lack of scientific data and information makes developments difficult. Moreover, despite the number of products and ingredients available, it is still poorly addressed by the cosmetic industry, due in part to legislation classifying cosmetic hair loss products as ‘borderline’, whereby each product is assessed individually on a case-by-case basis, with few cut-and-dry guidelines. In fact, the more scientific data available may actually render a product a medicine rather than a cosmetic.


Differences and definitions between cosmetics, medicines, and some medical devices, can often be unclear and even confusing at times, thus requiring interpretation and input from the regulatory authorities. A cosmetic product might have similar ‘activities’ to other products yet may be regulated and classified by different regulatory defin ...