Using statements like these on a website to promote a soap can be problematic from a regulatory standpoint, especially in Canada.
1. Testimonials Are Still Considered Advertising
Regulators generally treat customer testimonials the same as direct marketing claims. Even if the company is quoting a customer, the business is still responsible for the message being communicated. If the testimonial suggests the product treats or improves a medical condition, it can be interpreted as the company making that claim.
2. Eczema Is a Medical Condition
Eczema is a recognized medical skin disorder.
A testimonial stating that a soap cleared up eczema implies the product can treat or relieve a disease. That can move the product from being a cosmetic into the category of a drug or therapeutic product, which would normally require regulatory approval and supporting evidence.
3. Claims About Chapped Skin
Statements about chapped or dry skin are generally less problematic because they relate to cosmetic benefits such as moisturizing or soothing. However, wording like “they're perfect now” could still be seen as exaggerated performance claims if used as marketing.
4. Health Canada and Cosmetic Advertising
Under Canadian cosmetic rules administered by Health Canada, cosmetics like soap can generally claim to:
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cleanse the skin
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moisturize or soften
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leave skin feeling smooth
But they should not claim to treat or relieve diseases or medical conditions.
5. Risk of Using These Testimonials
Including such testimonials on a website can create several risks:
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Regulatory scrutiny if the product appears to make therapeutic claims
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Misleading advertising concerns if the benefits are not scientifically supported
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Reclassification risk, where the product could be considered a drug rather than a cosmetic.
Summary
Testimonials suggesting a soap clears eczema or treats medical skin conditions are generally not appropriate for cosmetic marketing, even if they come from customers. Claims about dry or chapped skin are safer but should still be presented carefully to avoid implying medical treatment.
