Short answer

A claim is a compliance statement, not a marketing adjective. Before you print vegan, cruelty-free or clean on an eye product, ask the manufacturer for the ingredient origin declaration and the animal-testing statement in writing, and check them against the rules in each market you sell into.

Vegan means no animal-derived inputs — in eye care the usual watch items are collagen, beeswax, lanolin and certain colourants. Cruelty-free concerns whether the finished product or its ingredients were tested on animals, which is regulated differently in the EU, the US, the UK and China. Clean has no legal definition at all, so if you use it, define it on-pack or on-site.

The practical approach: decide the claim set first, then develop the formula to it. Retrofitting a vegan claim onto an existing formula often means replacing the hero active, which restarts sampling.

Side-by-side comparison

ClaimWhat it meansWhat to ask forRisk to watch
VeganNo animal-derived inputsIngredient origin declarationCollagen, beeswax, lanolin
Cruelty-freeNo animal testingWritten animal-testing statementRules differ by market
CleanNo legal definitionYour own on-pack definitionUndefined claims get challenged
Fragrance-freeNo added fragranceFragrance declarationMasking fragrances
Dermatologically testedTesting was performedTest report and protocolClaim must match the test

When to choose which (and when not to)

If your market isCheck first
EUClaims must be substantiable and not misleading
USMoCRA substantiation and labelling rules
Multi-marketUse the strictest market as the baseline
Marketplace onlyRetailer claim policies are often stricter than law

Frequently asked questions

Can any formula be made vegan?

Many can, but replacing an animal-derived active changes performance and usually requires re-sampling. Decide the claim before development starts.

Is 'cruelty-free' the same in every market?

No. Testing requirements and recognition schemes differ between the EU, the US, the UK and China, so the same wording is not automatically valid everywhere.

Who is responsible if a claim is challenged?

The brand placing the product on the market. That is why the supporting documents should be in your hands, not only in the factory's.

Formulating an eye-care product?

Send your target market, dosage form and estimated quantity — we reply with formulation advice, MOQ tiers, compliance notes and samples.

Request a Quotation Free Samples

Related: EU CPNP vs US MoCRA  ·  private label vs custom formula  ·  discuss a claim set

EyeOEM · Eye-Care OEM/ODM R&D & Manufacturing · 2026-09-11 · sales@eyeoem.com