The European cosmetics industry is dedicated to maintaining the highest standards for end users, both in the production of cosmetic and personal care products and in the advertising and marketing of these. The National Council for Self-Regulation (NCSR) actively collaborates with the Bulgarian National Association of Essential Oils, Perfumery and Cosmetics (BNAEOPC) to promote the best practice model for effective advertising self-regulation adopted in Europe1.

These guidelines are a specific framework document for cosmetic products, developed at European level by Cosmetics Europe and adopted by BNAEOPC. They consolidate existing principles and best practice in Europe, defining a common basis for cosmetic advertising and marketing communication in Bulgaria.

1Cf. European Commission 2006 Report on Self-regulation in the EU Advertising Sector

 Scope of application

The Guiding Principles aim to set a common basis for the responsible advertising of cosmetic products in Bulgaria.

These Guiding Principles are an integral part of the National Code of Ethics for Advertising and Commercial Communication (Code of Ethics). The Principles specify the applicability to cosmetic and personal care products of some of the general rules of the Code of Ethics and should be interpreted and applied in conjunction with the Code.


For the purposes of these Guiding Principles, the term:

(a) “Cosmetic product” means any substance or mixture intended to come into contact with any external part of the human body (epidermis, hair and hair parts, nails, lips and external genital organs) or with the teeth and mucous membranes of the oral cavity, exclusively or primarily for the purpose of cleaning them, changing their appearance, protecting them, keeping them in good condition or correcting body odour;

(b) “Cosmetic product claims” refers to text, names, trademarks, images, pictures, figures or other signs used in the labelling, marketing and advertising of cosmetic products;

(c) “Advertising activity” or “advertising” means any form of marketing communication made in  any medium, usually in exchange for payment or any other consideration. This includes digital marketing communications;

(d) “Marketing communication” includes advertising as well as other techniques such as promotions, sponsorships and direct marketing and should be broadly construed to mean all communications produced directly by or on behalf of marketers intended primarily to promote products or influence consumer behaviour;

(e) “Misleading advertising”’ means ‘any advertising which, by any means, including in its presentation, deceives or is likely to deceive the persons to whom it is addressed or reaches and is therefore likely to influence their economic behaviour or, for those reasons, to cause or be likely to cause damage to a competitor’ (Directive 2006/114/EC).

(f) “Average consumer” means any person “who is reasonably well informed and reasonably observant and cautious, taking into account societal, cultural and linguistic factors” (Interpretation 18, Directive 2005/29/EC).


2.1. Sincerity of advertising

The European cosmetics industry is committed to providing sincere advertising and marketing communication that does not mislead or deceive the consumer about the characteristics of products. Sincerity is the basic and most essential part of a responsible approach to advertising all products.

2.1.1. Justification of product claims

Any cosmetic product claim, whether direct or indirect, must be supported by adequate or appropriate evidence demonstrating the characteristics and qualities of the product. The specific context and circumstances in which the claim is made (including societal and cultural factors) must be taken into account.

Claims must fall under:

  • the list of common criteria developed by the European Commission2 being:

– legality;

– truthfulness;

– evidentiary support;

– integrity;

– honesty;

– intended to allow informed decisions.

(b) Best Practice for Claim Substantiation3 as applied to:

– experimental studies;

– user perception tests;

– the use of published information.

2 List of Common Criteria for Claims that may be used in relation to cosmetic products pursuant to Article 20 of Regulation (EC) No 1223/2009

3 Annex ‘Best practice for the substantiation of claims’ in the List of Common Criteria for Claims that may be used for cosmetic products, pursuant to Article 20 of Regulation (EC) No 1223/2009

2.1.2. Image correctness

Digital technologies can be used to enhance the beauty of images to convey brand personality and positioning or any specific product’s ease of use.

However, the following principles should be observed when using pre- and post-production techniques such as styling, re-correction, eyelash inserts, hair extensions, etc:

(a) The advertiser must ensure that the illustration of a feature or quality of the advertised product is not misleading (see Justification of product claims);

(b) Digital technologies shall not alter the images of human models in such a way as to render their bodily forms and features unrealistic and misleading with respect to the practical attributes achievable by the product;

(c) Pre- and post-manufacturing techniques are acceptable provided they do not imply that the product has features or functions that it does not actually have.

For example, the following cases will not be considered misleading:

– Use of obvious exaggeration or stylized cosmetic images intended not to be taken literally.

– Using techniques to enhance the beauty of images that are not related to the product or effect being advertised.

2.1.3. Testimonials and recommendations from specialists General provisions

General testimonials and those from professionals can be used to highlight the features of cosmetic products and create a brand image.

Testimonials and recommendations from specialists:

(a) may be used in the form of written or oral statements;

(b) must be genuine, accountable and verifiable.

(c) may not substitute for the substantive facts of a claim (see Product Claim Substantiation).

(d) must avoid any misrepresentation or misinformation as to the nature of the advertised product, its properties and the results to be obtained. Testimonials

Testimonials from celebrities, private individuals, or consumers, etc. may be used, provided that they are presented as a personal evaluation or impression of the product.

Testimonials should not be regarded as evidence of the efficacy of the product, which can be established on the basis of adequate and appropriate evidence (see Justification of product claims). Recommendations from specialists

Testimonials from medical, paramedical or scientific professionals (referred to as ‘professional(s)’ for brevity) on an ingredient, product or general message on hygiene or beauty are acceptable provided they are established by adequate and appropriate evidence (see Justification of product claims).

Such professionals should be selected on the basis of their qualifications, knowledge and experience in the specific field.

2.1.4. Environmental aspects in advertising

Where environmental claims are made, cosmetic companies must respect the principles of truthfulness, clarity, accuracy, adequacy, and scientific substantiation (see Justification of product claims).

In the event that a statement made with respect to the environment is not literally true, is likely to be misinterpreted by the consumer or is misleading by omission of relevant facts, such statement with respect to the environment should not be made.

Special attention should be paid to: Overall presentation

The overall presentation of a cosmetic product (colours, visuals, etc.) and individual claims should not:

(a) be based on false information;

(b) imply an environmental benefit that the product does not provide;

(c) exaggerate the environmental aspect of the product to which the claim relates;

(d) emphasise any environmental benefit while concealing aspects that have a negative impact on the environment. Use of symbols/suggestion for third-party certification:

(a) any supporting information, images or symbols must be justified and understandable to the average user;

(b) any use of symbols or logos must not imply that the product has achieved the necessary third-party approval where this is not appropriate in the particular case. Accuracy and applicability of the environmental claim:

(a) the environmental claim must be presented in a way that makes it clear whether it applies to the whole product, only to one component of the product or to an element of the intended use;

(b) the environmental claim must relate to the product concerned and be used only in an appropriate context;

(c) the claim must be specific as to the environmental benefit or enhancement; therefore, an environmental benefit may be claimed provided that an appropriate assessment of the environmental impact of the product has been carried out. Rationale

(a) environmental claims for cosmetic products, whether direct or indirect, must be supported by adequate and appropriate scientific evidence;

(b) the test methods and studies used as evidence must be relevant to the product and the claimed environmental benefit;

(c) environmental claims should be reassessed and updated as necessary to reflect changes in technology, competing products, or other circumstances that could alter the accuracy of the claim;

(d) In relation to “natural” or “organic” cosmetic products, the International Organization for Standardization (ISO) is currently developing a set of technical criteria and definitions regarding natural and organic ingredients and products. These technical criteria do not apply to claims but can be used as a starting point to substantiate the claims ‘natural’ and ‘organic’ for cosmetic ingredients and products.

2.2. Social responsibility

The cosmetics industry is committed to responsible advertising and marketing communication that respects the human being, body image and human dignity.

2.2.1. General principles

All cosmetic advertising and marketing communication must comply with the general provisions relating to:

(a) Taste and decency: Cosmetic advertising and marketing communication shall not contain statements or audio or visual representations that violate good manners according to the generally accepted norms of the country and culture concerned;

(b) Gender portrayal: Cosmetic advertising and marketing communications must not contain sexually offensive material and must avoid any textual material or verbal statements of a sexual nature that may be derogatory to women or men;

Furthermore, cosmetic advertising and marketing communication should not be hostile to a particular gender.

(c) Offence: any statement or visual representation that is likely to cause deep or widespread offence to those it is likely to reach, whether or not directly addressed to them, is not acceptable. This includes shocking images or shocking statements used solely to attract attention;

(d) Violence: Cosmetic advertising and marketing communication must not condone or incite violent, illegal or anti-social behaviour;

(e) Taking advantage of superstitions: Cosmetic advertising and marketing communication should not take advantage of superstitions;

(f) Taking advantage of fear: Cosmetic advertising and marketing communication should not take advantage of feelings of fear, unhappiness or suffering, without good reason;

(g) Exploiting credulity and inexperience: cosmetic advertising and marketing communication should be designed in such a way that it does not exploit consumers’ trust and lack of experience and knowledge;

(h) Discrimination: cosmetic advertising and marketing communication must respect human dignity and diversity. They must not incite or tolerate any form of discrimination, including discrimination based on ethnic group, national origin, religion, gender, age, disability or sexual orientation;

(i) Defamation: cosmetic advertising and marketing communication shall not defame any person or group of persons, firm, organisation, industry, trade, profession or product, nor attempt to cause public contempt or ridicule of them;

(j) Safety and Health: Cosmetic advertising and marketing communication shall not, without good cause of an educational or public nature, contain any visual representations or descriptions of potentially unsafe practices or situations that show disregard for safety or health. Human models used in advertising and post-production techniques should not be displayed to promote a preferred body image of extreme thinness or frailty.

(k) Humour: Humour may be used in cosmetic advertising and marketing communication in a manner that does not stigmatise, demean, or belittle any person or group of persons.

2.2.2 Specific principles Respect for the human being

Considering the possible impact that cosmetic advertising and marketing communication can have on consumers’ self-esteem, the following should be taken into account when using human models in advertisements:

(a) not to focus on bodies or body parts as objects when not related to the advertised product;

(b) not to present nude models in a manner that is degrading, alienating or sexually offensive. When using nudity, consideration must be given to the media used and the intended audience. Vulnerable population groups – children

The Bulgarian cosmetics industry is committed to providing responsible advertising and marketing communication aimed at children and young people.

Cosmetic products specifically designed for children may be advertised provided that:

(a) advertising emphasizes the beneficial hygiene and sanitary qualities of cosmetic products for children, in particular sunscreens, oral hygiene and cleaning products (including soap, shampoos and acne concealers for adolescents);

(b) advertisements for decorative cosmetics and perfumes should not encourage children to use such products excessively;

(c) the advertising of cosmetic products, including images, must not promote any kind of early sexuality in young people.


These guiding principles adhere to the relevant provisions included in:

(a) Unfair Commercial Practices Directive 2005/39/EC

(b) Directive 2006/114/EC on misleading and comparative advertising.

(c) Article 20 of Regulation (EC) 1223/2009 on cosmetic products (hereinafter referred to as the Cosmetics Regulation), which states that product claims must “not be used to imply that cosmetic products have characteristics or functions that the products do not have” and this requires the establishment of common criteria for all types of claims. Such criteria have been developed by the European Commission, in cooperation with EU Member States and relevant stakeholders.

(d) The Joint International Chamber of Commerce (ICC) Code of Advertising and Marketing Communication Practice.

Adopted by the General Assembly of the NCSR on 01 September 2016.