Natural, Vegan and Palm Free Soap Claims: What You Can Say and What You Must Prove

A handmade soap's marketing usually rests on three words: natural, vegan and palm free. All three are legitimate. All three sell. And all three are claims in the legal sense — which means each one has to meet the six common criteria in Regulation (EU) No 655/2013 on cosmetic claims (assimilated law in Great Britain): legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making.

Those criteria cover the wrapper, the website, the product page, the email, the Instagram caption and the video an influencer posts about the bar you sent them. In the UK they are enforced through Trading Standards and the Advertising Standards Authority, and increasingly through the Competition and Markets Authority's work on environmental claims. From 6 April 2025 the Digital Markets, Competition and Consumers Act 2024 has let the CMA decide consumer-law breaches itself and fine businesses up to 10% of global turnover.

This guide walks each claim in turn. You will get the six criteria in soap-specific terms; what natural can and cannot mean; the vegan claim and the ingredients that break it; palm free and the derivative chain; organic and why certification is effectively necessary; free-from claims and the denigration rule; the claims that are never defensible; handmade, small-batch, cruelty-free and zero-waste wording; the evidence file to assemble; a worked example of a brand that had to withdraw a claim; and a checklist to run your own range against.

The six criteria in soap terms

Two criteria do most of the heavy lifting in soap marketing. Evidential support means a document exists and can be produced — and that is the test most small brands fail, not because the claim is false, but because nobody wrote anything down. Fairness is the one that catches the free-from genre: a claim that implies a permitted ingredient is dangerous denigrates it, and a great deal of natural-soap marketing is built on exactly that implication.

Natural: define it or lose it

There is no legal definition of natural in cosmetics. That is not a loophole. It transfers the burden to the brand, because a claim that is not misleading has to mean something the average consumer would recognise — and you have to be able to say what it means.

Three defensible approaches exist. First, certify to a scheme with published criteria, such as COSMOS or Soil Association standards: you get a definition, an audit and a logo a stockist understands. Second, use ISO 16128, which provides definitions and calculation rules for natural and natural-origin content so you can state a percentage on a defined basis. It is a calculation framework, not a certification, and — importantly — ISO 16128 itself does not address claims or labelling. Stating the basis still matters under Reg 655/2013. Third, drop the word natural and describe the product precisely: made with olive, coconut and shea oils, scented with essential oils, coloured with clays and iron oxides.

We recommend the third approach most often. It is almost impossible to challenge, it is more informative than the adjective, and you do not have to defend a word you cannot define. A soap is also, inconveniently, the product of a chemical reaction between a fat and a strong alkali — so natural soap is a phrase worth using with some care.

Vegan: the invisible ingredients

The vegan claim is straightforward in principle and fails on specifics. The obvious animal ingredients are easy to avoid: tallow, lard, beeswax, honey, lanolin, silk, milk, yoghurt, carmine. The ones that break vegan claims are materials whose origin is invisible on an ingredient list.

Glycerin can be animal, vegetable or synthetic. Stearic acid is most often palm- or tallow-derived. Lactic acid can be dairy-derived; sodium lactate likewise. Some vitamin E, lecithin and emulsifier grades are animal-derived. Processing aids and filtration media used upstream can involve animal materials — bone char in some sugar refining is the classic example if sugar is in the formula.

The way to hold a vegan claim is a declaration from every supplier for every material, stating that the material and its processing aids are free of animal origin, kept with the batch records and refreshed when a supplier changes. Certification by the Vegan Society or a comparable scheme does that work for you and gives you a mark retailers accept.

One more distinction: vegan and cruelty-free are different claims. Animal testing of finished cosmetic products and of ingredients for cosmetics purposes is already prohibited under Article 18 of Regulation (EC) No 1223/2009 in the UK and EU, so marketing not tested on animals as a distinguishing benefit can fall foul of the legal compliance criterion. Ingredients may still have animal data generated for other regulatory frameworks (for example REACH). A Leaping Bunny certification addresses supply-chain testing policy and is a meaningful claim; bare legal compliance is not.

Palm free: the hardest of the three

Palm free is the claim most likely to be inadvertently false, because palm oil derivatives appear in materials with no palm in the name. Sodium palmate and sodium palm kernelate are obvious. Stearic acid is usually palm-derived unless specified otherwise. Glycerin is frequently palm-derived. Vegetable oil and vegetable stearic acid on a supplier sheet very often means palm. Sodium lauryl sulfate and most surfactants built on lauric chemistry begin with palm kernel oil. Cetearyl alcohol, caprylic/capric triglyceride and a long list of fatty alcohols and esters commonly originate from palm or palm kernel too. Sodium cocoyl isethionate is usually coconut-derived (the cocoyl tip in the name), but confirm it in writing — supplier sheets still get misread. Sodium hydroxide itself is made from salt by electrolysis and is not a palm derivative, but additives, emulsifiers and fragrance components can be, and brands making an absolute claim should ask.

You have three practical options. Make the claim and do the work — written origin confirmation for every single material, including additives and fragrance. Make a narrower, accurate claim such as made without palm oil, which addresses the oil rather than every derivative, and say so plainly. Or use certified sustainable palm oil and explain why, which is a defensible position many brands take once they discover the alternative involves replacing inputs whose own supply chains carry their own issues. All three are honest. The one to avoid is a blanket palm free based only on the absence of palm oil from the oil blend.

Organic, and why certification is effectively necessary

Organic is different from natural: organic agriculture is a regulated concept with legal standards for food and farming, and cosmetic use of the word borrows that credibility. A brand saying organic soap with no certification faces an immediate evidential problem, and the ASA has upheld complaints about cosmetic organic claims where the proportion of certified organic material was small or unverified.

Three honest routes. Certify the product through a scheme such as COSMOS Organic (offered by certifiers including the Soil Association), which audits the formula, the percentage of organic content and the supply chain, and permits a logo. Make an ingredient-level claim that is precise and verifiable: made with certified organic olive oil, with the certificate on file. Or do not use the word. What does not work is describing a soap as organic because the oils came from a health-food shop, or because the brand feels organic in spirit.

The same applies to related words. Ecological, eco, sustainable and climate-neutral claims now attract specific scrutiny under green-claims guidance, and a vague environmental claim with no substantiation is one of the clearest enforcement targets in current consumer-protection work. The CMA Green Claims Code is the practical UK reference.

Free from claims and the denigration rule

Free-from claims are specifically addressed in the Technical Document on Cosmetic Claims agreed by the Sub-Working Group on Claims (version of 3 July 2017), and that guidance is less permissive than most brands assume. A free-from claim is not acceptable where it denigrates a legally permitted ingredient — and much of the natural-soap genre does precisely that: free from harsh chemicals, no nasties, free from toxins. Each of those implies that products containing the ingredient in question are harmful, which is unfair to competitors and misleading to consumers, because an ingredient permitted under the Cosmetics Regulation has been assessed as safe at its permitted level.

A free-from claim is also unacceptable where it refers to an ingredient that could not be in the product anyway, since claiming to be free of a prohibited substance presents a legal requirement as a benefit. The claims that do survive are narrow and informative: fragrance free, useful to someone with a fragrance allergy; free from a named allergen for the same reason; and declarations of absence that help a consumer make a genuine ethical or sensitivity choice rather than implying danger. Palm free and vegan sit in that category — which is why they are defensible where the evidence exists.

Claims that are never defensible

• Chemical free. Everything is a chemical, including water and soap. The claim is factually false and routinely challenged.
• Toxin free and no nasties. Undefined, denigratory and unsupportable.
• Hypoallergenic. Not prohibited, but it implies a reduced allergy risk that needs substantial evidence most small brands do not hold.
• Safe for everyone or safe for babies. Absolute safety claims cannot be supported; specific age suitability needs its own assessment.
• Cures eczema, treats acne, heals. Medicinal claims that would require a marketing authorisation.
• Antibacterial on a cosmetic soap. A borderline claim: unless cleansing stays the main purpose and the claim is substantiated, it can pull the product under biocides law.
• Detoxifying. Implies a physiological process the product does not perform; appearance and cleansing wording is the supportable version.
• Non-comedogenic without testing. Needs evidence — a study, not an assumption about the oils used.

Handmade, small batch, cruelty free and zero waste

These softer claims still have to be true, and each has a specific trap. Handmade should mean made by hand; a brand buying melt-and-pour base, or moving to a contract manufacturer while keeping the word, has a truthfulness problem that competitors notice first. Small batch is relative and rarely exciting to challenge, but it becomes misleading once production is industrial. Cruelty free interacts with the legal compliance criterion as described above; certification is the clean route. Zero waste, plastic free and compostable are environmental claims and now carry a real evidential burden: compostable means certified to a recognised standard with a route to industrial or home composting; plastic free must account for the film on a sticker and the tape on a box; carbon-neutral or climate-positive claims need a methodology you can produce.

The rule of thumb is to claim the narrow verifiable thing rather than the broad impressive one. Wrapped in paper, printed with vegetable inks, no plastic tape beats zero waste — and it is immune to challenge.

The evidence file

• A claims matrix listing every claim you make and the document that supports it.
• Supplier declarations of animal origin for every ingredient, for vegan claims.
• Written origin statements for stearic acid, glycerin, surfactants and fatty alcohols, for palm claims.
• Certification documents and current scope, where you hold any.
• Organic certificates for any ingredient described as organic, with the percentage calculation.
• Your written definition of natural and the basis of any percentage you state (including whether you used ISO 16128).
• Study reports for any performance, sensitivity or non-comedogenic claim.
• Screenshots of your own website and social claims, dated, so the matrix matches reality.
• A note of who approves new marketing copy before it is published.

That file belongs in the Product Information File alongside the CPSR, because claims evidence is part of what an authority can ask to see. Our CPSR document checklist covers how it fits with the rest of the dossier, and the OPSS guidance sets out the official position.

A worked example: the claim that had to be withdrawn

A brand builds its identity on palm free — printed on every wrapper and repeated across a well-followed social account. A competitor complaint prompts a stockist to ask for substantiation. The brand holds origin statements for its olive, coconut, shea and castor oils, all genuinely palm-free, and has never used sodium palmate. The review finds two problems. The stearic acid used in its shaving soap and two facial bars is described by the supplier as vegetable stearic acid and is confirmed on enquiry to be palm-derived. And the glycerin added to three bars for extra humectancy is also palm-derived.

The brand has two routes: reformulate — sourcing shea- or kokum-based stearic acid at roughly three times the cost, plus synthetic or rapeseed glycerin — or narrow the claim. It does both, reformulating the three bars where the cost is bearable and changing the range-wide wrapper claim to made without palm oil, with a page on the website explaining exactly which derivatives it has eliminated and which it has not. Sales do not fall. The brand's own conclusion is that the specific explanation converted better than the slogan, because customers who care about palm know how hard the derivative chain is and respect a brand that says so.

Related reading

• The six common criteria for cosmetic claims
• Cosmetic claims that are not allowed
• What is greenwashing?
• Clean beauty claims and evidence
• CPSR for handmade soap
• Claim substantiation explained
• How to prepare for a CPSR: document checklist
• All regulatory compliance articles

Myths we hear

• Natural has no definition so I can use it freely. The absence of a definition shifts the burden onto you; the claim still must not mislead the average consumer.
• No animal ingredients on the INCI means I can say vegan. Only with supplier declarations covering origin and processing aids for every material.
• No palm oil in the oil blend means palm free. Derivatives in stearic acid, glycerin and many surfactants break an absolute palm-free claim.
• Free-from claims are always safe to make. They fail where they denigrate a permitted ingredient or claim absence of something that is already prohibited.
• Nobody checks small brands' marketing. Competitors, stockists and the ASA do — and a withdrawn claim means reprinting everything.

What to do this week

1. List every claim on your packaging, website and social bio in one place.
2. Name the supporting document for each and flag the ones with nothing behind them.
3. Email your stearic acid, glycerin and surfactant suppliers for written origin statements.
4. Replace chemical free, toxin free and no nasties with specific, accurate wording.
5. Decide whether natural is worth defining — or better replaced with a precise ingredient description.

Frequently asked questions

Official sources and legislation

• Regulation (EU) No 655/2013: common criteria for cosmetic claims
• Regulation 655/2013 (GB assimilated version)
• Technical Document on Cosmetic Claims (Sub-Working Group on Claims, 3 July 2017) — free-from guidance
• Regulation (EC) No 1223/2009 on cosmetic products
• OPSS guidance: Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (GB)
• CMA Green Claims Code
• ASA CAP Code (non-broadcast)
• Digital Markets, Competition and Consumers Act 2024
• ISO 16128-1/-2: natural and organic cosmetic ingredient definitions and calculation criteria (does not itself authorise claims)
• The Vegan Society Vegan Trademark
• COSMOS standard
• Leaping Bunny (Cruelty Free International)