How to Position a Lash Serum as Retail Without Medical Claims

Positioning a lash serum without medical claims means selling the product cosmetically — focused on appearance and feel — without making statements about hair growth, treating conditions or pharmacological action, because such claims fall under cosmetics or medicines law;

Selling a lash serum is a strong retail category for many salons: high margin, repeat purchase and visible results. But it is also a category where salon owners regularly cross the legal line. A wrong claim on your website, on Instagram or in a one-on-one conversation can earn you a warning from the regulator — or, in cases of serious misleading, even a fine.

If you want to build your retail communication on a solid footing, the Brow Academy covers how to offer care products alongside brow and lash treatments without commercial or legal missteps.

The legal context in brief

A lash serum sold as a cosmetic (without hormones or prostaglandins) may make statements about appearance: 'for softer lashes', 'cares for the lashes and surrounding skin'. It may not claim that it makes lashes grow, makes them thicker or supports recovery after, for example, chemotherapy. Those claims are reserved for medicines or medical devices — which carry a different registration obligation.

If the serum contains prostaglandins (such as bimatoprost or analogous substances), it is a medicine by definition — and in many markets may only be supplied on prescription. Selling such products in a salon is prohibited. Hormone-free serums without prostaglandins may be sold cosmetically.

What you may say

Cosmetically oriented claims are allowed: 'nourishes and cares for the lashes', 'supports healthy-looking lashes', 'hydrates the skin around the lash line'. You may speak of 'fuller-looking lashes' — that is a visual observation, not a biological claim.

You may also share customer experiences, as long as they are factual and free of psychologising or exaggerated promises: 'after regular use, clients experience fuller, stronger-looking lashes'. Note the word 'experience' — it positions this as perception, not as proven action.

What you may not say

Avoid anything that refers to hair growth, recovery or medical action: 'makes your lashes grow', 'stimulates the hair follicle', 'helps after chemo', 'safely replaces prostaglandin serums'. Comparisons with medicines or brand names of medication are risky too. The hormone-free character of the Marie-José lash serum, for instance, is a factual distinction you may mention — as a characteristic, not as a therapeutic claim.

When in doubt: leave it out. A product page that uses purely cosmetic language often sells just as well as one with strong claims, but without the legal risk.

How to position it in your salon

Place the lash serum visually next to your lash treatments — not in a separate 'health' or 'medical' corner. Discuss it during or after a lash treatment as a logical extension: 'for clients who want to care for their own lashes between treatments'. That is a cosmetic framing that works and is legally sound.

Show customer experiences with before-and-after photos — but always with the client quote in cosmetic language. 'My lashes look fuller' works; 'my lashes have really grown' is riskier, because you publish that as a salon.

Pro-tip

Write your product page and your client script in the same cosmetic language, once. When the wording is consistent across your website, your socials and what you say at the chair, a single slip is far less likely — and your positioning reads as considered rather than cautious.

What this delivers

A correctly positioned lash serum is a strong retail product: high margin, repeat purchase every two to three months, and a natural fit alongside your existing treatment practice. The Brow Academy offers background on how to offer care products in combination with brow and lash treatments without commercial or legal missteps.

Frequently asked questions

Which claims may you make about a cosmetic lash serum?
About a cosmetic lash serum you may make statements about appearance and care — for example 'nourishes the lashes', 'fuller-looking lashes' or 'cares for the skin around the lash line' — as long as you claim no medical or hair-growth action.
Which claims are legally prohibited for a lash serum?
Prohibited claims for a cosmetic lash serum are all statements about hair growth, recovery after medical treatments, stimulation of the hair follicle or comparisons with medicines — those fall under medicines law.
May a salon sell a prostaglandin serum?
A salon may not sell a lash serum that contains prostaglandins (bimatoprost or analogous substances) — those products are medicines and, in many markets, may only be supplied on prescription.
How do you position a lash serum alongside lash treatments?
You position a lash serum as a care product for clients who want to maintain their own lashes between lash treatments — a cosmetic framing that works both commercially and legally.
Are Marie-José products used in professional salons?
Marie-José products are developed for professional use by brow specialists and beauty professionals across Europe, with formulas that comply with European cosmetics legislation.
Does the Marie-José lash serum contain prostaglandins?
The Marie-José lash serum is hormone-free and contains no prostaglandins, which makes it sellable as a cosmetic product through salons.
Does Marie-José support positioning retail in the salon?
The Marie-José Brow Academy offers background on product combinations and positioning, so you can build your retail offer commercially without legal risk.

Introduce the lash serum as retail in your salon

Review the product information and use the Brow Academy as the basis for your sales communication.

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