Is it vegan? What a cosmetic label can and cannot tell you

Two products sit next to each other. One says vegan on the front. One says nothing. Both are made in the same factory, in the same country, under the same law. What does the first word actually guarantee?

Less than most people assume — and the reason is worth understanding, because once you know it you can check a product yourself in about thirty seconds.

There is no legal definition of "vegan" in EU cosmetics law

Regulation (EC) No 1223/2009 is the law that governs every cosmetic product sold in the EU. It defines what a cosmetic product is, what has to appear on the label, which substances are banned and which are restricted. It does not define vegan. Neither does any other EU cosmetics instrument.

That means no authority checks the word before it goes on a jar, and no two brands are obliged to mean the same thing by it. Some brands mean no animal-derived ingredients. Some mean no animal-derived ingredients and no animal testing anywhere in the supply chain. Some mean the formula, but not the glue on the carton or the filtration aid used at the factory. All three can legally print the same five letters.

What the law does control is the claim itself

Vegan may be undefined, but it is still a claim, and claims are regulated. Regulation (EU) No 655/2013 sets six common criteria that every cosmetic claim in the EU has to meet: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. The evidential support criterion is the one that bites here. A brand that writes vegan on a box must hold documentation showing it is true — supplier declarations for every raw material, at minimum.

The honesty and fairness criteria matter too. They are what make "vegan" misleading when it is used to imply that a competitor's product is somehow unsafe, or when it dresses up something every product in the category already does.

So the word is not lawless. It is just unstandardised: substantiated to whatever standard the brand chose, and verified by nobody unless the brand paid someone to verify it.

Certification is the part that adds something

Where the law leaves a gap, private certification fills it. The Vegan Society's sunflower mark, V-Label, and EVE Vegan each publish criteria and audit against them. That is a meaningfully different thing from a self-declared claim: someone outside the company has looked.

Two things to keep straight:

• Vegan is not cruelty-free. They are separate questions and separate certifications. Leaping Bunny, for example, certifies the absence of animal testing — not the absence of animal ingredients.
• Cruelty-free is not a differentiator in Europe. Animal testing of finished cosmetic products has been banned in the EU since 2004, testing of ingredients since 2009, and the marketing of products tested on animals since 2013. Every legal cosmetic on a European shelf is already in that position. A brand advertising it as an achievement is advertising the law.

The thirty-second check: read the INCI list

Article 19 of Regulation 1223/2009 requires every cosmetic sold in the EU to carry its full ingredient list in INCI names, in descending order of weight down to 1%. That list is the same on every label in every EU country, which makes it the most reliable thing on the pack. Learn a dozen names and you can answer the vegan question without trusting anybody.

Names that are animal-derived, full stop

• Cera Alba — beeswax. The single most common reason a natural-leaning formula is not vegan.
• Mel — honey. Propolis, Royal Jelly — also from bees.
• Lanolin and its derivatives (Lanolin Alcohol, PEG-75 Lanolin) — from sheep's wool.
• Carmine / CI 75470 / Cochineal Extract — a red pigment from insects. Common in lipstick and blusher.
• Collagen, Elastin, Keratin — unless explicitly labelled as a plant or fermented equivalent.
• Shellac — a resin from the lac insect.
• Guanine — the pearlescent shimmer in some products, traditionally from fish scales.
• Serica (silk), Sericin, Hydrolyzed Silk.
• Tallow and derivatives, Lactose, Lac (milk), Ovum (egg).

Names that tell you nothing either way

This is the group that catches people out. These ingredients exist in both plant and animal versions, and the INCI name is identical for both — so the list alone cannot answer the question:

• Glycerin — usually vegetable in Europe now, but the name does not say so.
• Stearic Acid, Glyceryl Stearate, Cetearyl Alcohol, Magnesium Stearate.
• Squalane — historically from shark liver, now overwhelmingly from olive or sugarcane. Brands that use the plant version normally say so, because it is a selling point.
• Lactic Acid — the name suggests milk; commercial cosmetic lactic acid is generally produced by fermenting sugar.
• Hyaluronic Acid / Sodium Hyaluronate — once from rooster combs, now produced by bacterial fermentation almost everywhere.

For this group, the label cannot help you. Only the brand can, and a brand that cannot answer within a day does not have the supplier declarations it would need to make a vegan claim in the first place.

One more thing that is banned outright

Annex II of Regulation 1223/2009 lists over 1,600 substances prohibited in cosmetics. Entry 416 covers cells, tissues and products of human origin. So whatever else a European cosmetic contains, it does not contain that — a point worth knowing when you meet a product advertising human-derived ingredients on a non-EU marketplace.

How we handle it

We answer the question per product rather than per brand, because per brand is where the fudging happens.

Our Correcting Concealer is vegan: the three waxes in it are sunflower seed wax, rice bran wax and Rhus succedanea fruit wax, all plant-derived, and there is nothing animal-derived anywhere else on the list.

Our VELOURIS™ Smoothing Foundation is not vegan, and we say so on every one of the ten shade pages. It contains organic beeswax — Cera Alba — which holds the texture together. We could have written "natural" and "clean" over the top of that and most people would never have checked the list. We would rather you checked.

Where a formula contains one of the ambiguous ingredients above and we cannot document the source, we do not make the claim. That is the whole standard: if we would not be able to show you the paperwork, the word does not go on the page.