There is no separate legal category
A pack marked for children is not a different class of product from one that is not. It is a cosmetic product, governed by the same regulation, tested by the same methods, labelled with the same protection factor and the same protection categories, and subject to the same claims criteria.
That surprises people, and it should be said plainly before anything else, because the assumption that a children's designation carries a formulation standard behind it is widespread and it is not correct.
What the designation does carry is real, and it sits in the safety assessment rather than in the claim.
What does change: the safety assessment
Every cosmetic product placed on the market must have a safety assessment, prepared by a suitably qualified person and held in the product information file. The assessment considers the composition, the exposure, the intended use and the population using it.
Where a product is intended for children, and particularly for children under three years of age, the assessment must take that specifically into account. Exposure per unit of body weight is different, skin surface area relative to weight is different, and the pattern of use is different. The assessment has to address those differences rather than assume an adult user.
So the meaningful thing behind a children's designation is a document. It is a document the reader will never see, held by the responsible person, available to enforcement authorities on request. That arrangement is explained in the responsible person and the product information file.
The claims that travel with it
Around the word children, a familiar cluster appears: gentle, kind to skin, suitable from six months, tear free, mild, extra care. None has a defined threshold. All are governed by the common criteria for cosmetic claims, which require a claim to be truthful, supported by adequate and verifiable evidence, and not to attribute characteristics the product does not have.
Two of them deserve separate treatment.
Suitable from a stated age. This is a specific claim and it interacts with the safety assessment directly. A stated minimum age is a statement that the assessment covers that use, and it should be consistent with what the file supports.
Tear free and its variants. A claim about ocular tolerance requires evidence about ocular tolerance. It is a claim of the same character as any other tolerance claim, and the evidence has to match it.
None of this is a criticism of products designed for children. Formulating for a smaller user is a real discipline. The point is that the word on the pack is not the discipline; the file is.
Where public health guidance sits, and where we stop
The question that most readers actually have is not what the word is allowed to mean. It is what to do about a small child in the sun.
That question is answered by the NHS, by the British Association of Dermatologists and by Cancer Research UK, all of whom publish guidance on sun protection for babies and young children. It is not answered here, because it is a health question and this is a labelling publication.
What we will say, because it is about how a label is read rather than about what to do, is that the guidance from those bodies places sun protection products alongside shade and clothing rather than in place of them, and that the emphasis on shade and covering is greater for young children than for adults. A pack cannot carry that context, and a reader who takes the designation on the pack as the complete answer has been given less than the guidance would give them.
| Element | Changes | Stays the same |
|---|---|---|
| Safety assessment | Must address the intended user specifically | |
| Protection factor testing | Identical method, identical application quantity | |
| Protection categories | The same four categories and printed figures | |
| UVA criteria | The same recommended relationship and mark | |
| Claims criteria | The same common criteria apply to every claim | |
| Legal product class | A cosmetic product, as with any other sunscreen |
Framework of this publication. It describes how published rules and guidance fit together and is not a measurement, a survey or a study.
Sensitive skin
Sensitive is undefined in the cosmetics regime. It is a description of an intended user rather than of a measured property of the product, and it is a description of a population that is itself not defined.
What sits behind a credible use of the word is a tolerance testing programme and a formulation approach: filter selection, exclusion of particular categories of ingredient, and assessment under dermatological control. What sits behind a weak use is the word alone.
Because there is no threshold, a reader cannot compare two products on the strength of the word. They can compare ingredient lists, which are on the pack and are the only comparable technical information the label carries. And where a person has a diagnosed sensitivity or has reacted to a product before, the question is one for a pharmacist or a GP, not for a front of pack adjective.
Filter vocabulary on a children's pack
Packs aimed at children often carry vocabulary about the type of ultraviolet filter used, and it is worth noting how that sits alongside the words already discussed.
The permitted ultraviolet filters are listed in an annex to the cosmetics regulation, with their permitted concentrations and any conditions of use. A filter that is not on that list may not be used at all. This is one of the few areas of a sun protection pack where the underlying control is a positive list rather than a claims test, and it means that every filter in every legally sold product has been through an assessment process.
Descriptive vocabulary about filter type is not part of that control. Words describing a filter class are trade shorthand rather than regulated terms, and where they are used in a way that implies a safety comparison between permitted filters, they run into the same difficulty as free from claims: a comparison that denigrates permitted, assessed ingredients requires evidence for the comparison actually being made.
The neutral construction states the filters used, which the ingredient list does in any case, and leaves the comparison unmade. A publication elsewhere in this field covers formulation categories in depth; our interest is only in what the pack is permitted to say about them.
If you are drafting it
State what is true and specific rather than what is warm and general. A statement that a formulation excludes a named category of ingredient is checkable. A statement that it was assessed under dermatological control on a stated panel is assessable. A statement that it is gentle is neither, and it invites the reader to infer a comparison with products that have not been named.
Where an age is stated, make sure the safety assessment covers it. Where a tolerance is claimed, make sure the evidence relates to that tolerance. And where the pack is aimed at parents, remember that the reader is making a decision under mild anxiety, which is the condition in which implied claims do the most work.
The reader this pack is written for
It is worth being explicit about the position a parent is in when they read one of these packs, because it explains why the claims criteria matter more here than almost anywhere else in the category.
The decision is made quickly, usually in a shop, usually with the child present, and under a low grade anxiety that the wrong choice matters. That is the condition in which implied claims do the most work: a reassuring adjective is absorbed as a finding, a designation is absorbed as a standard, and the absence of a comparison is filled in by the reader.
None of that changes what the rules require. It does change what a careful drafter should think about, because the common criteria for cosmetic claims ask whether a claim allows a consumer to make an informed decision, and informed is a property of the reader's understanding rather than of the drafter's intention. Wording that is technically supportable and predictably over-read does not meet the standard the criteria set.
What to take from this
Children's sunscreen is not a legal category. What changes is the safety assessment, which must address the intended user. Sensitive is undefined and rests on evidence held. Both words describe intent and documentation rather than a threshold a reader can compare.