Therapeutic and Medicinal Claims

What makes a claim medicinal?

The Human Medicines Regulations 2012 define a medicinal product in two ways: by its composition (it contains a substance used to treat disease) or by its presentation (it is described as having medicinal properties). It is the second definition that catches most craft sellers, because the way you describe your product determines its legal classification.

A claim is medicinal if it states or implies that the product can:

• Cure, treat, or prevent a disease or medical condition.
• Restore, correct, or modify a physiological function.
• Make a medical diagnosis.

Examples of language that crosses the line:

• "Cures headaches" or "treats migraines"
• "Relieves pain" or "reduces inflammation"
• "Anti-inflammatory" or "antibacterial" (when implying a therapeutic benefit)
• "Helps with anxiety", "eases depression", or "aids insomnia"
• "Boosts the immune system"
• "Heals wounds" or "speeds recovery"
• "Detoxifies the body"

The test is objective: would a reasonable consumer understand the claim to mean the product can treat or prevent a health condition? If yes, it is a medicinal claim. Your intention does not matter; the MHRA looks at how the claim would be understood by the person reading or hearing it.

Products commonly caught at craft fairs

Certain product categories are flagged more often than others because sellers tend to describe them in therapeutic terms. The most common:

• Herbal balms and salves: often marketed as pain relief or muscle rubs.
• Essential oil blends: frequently sold with claims about stress, sleep, or mood.
• CBD products: a particular minefield due to overlapping medicines, food, and cosmetics rules.
• Aromatherapy products: diffuser blends, roller balls, and inhalers described as treating anxiety or headaches.
• Crystal healing products: while crystals themselves are not regulated as medicines, selling them with specific health claims ("this crystal heals inflammation") can trigger medicines law.
• Herbal teas: perfectly legal to sell as a beverage, but adding claims like "relieves bloating" or "cures colds" makes them a medicinal product.
• Handmade soaps and skincare: safe as cosmetics, but claiming they "treat eczema" or "heal psoriasis" reclassifies them.

The common thread is not the product itself but what you say about it. A lavender balm sold as a "soothing skin balm" is a cosmetic. The same balm sold as a "headache remedy" is an unlicensed medicine.

Cosmetic claims vs medicinal claims: where the boundary sits

The distinction comes down to function versus treatment. Cosmetic claims describe what a product does to the surface of the body (skin, hair, nails). Medicinal claims describe what a product does to a disease, condition, or physiological process.

Claims you CAN make (cosmetic):

• "Moisturises dry skin"
• "Cleanses and refreshes"
• "Soothes dry or irritated skin" (note: soothing dryness is cosmetic; soothing eczema is medicinal)
• "Helps skin look smoother"
• "Conditions and softens hair"
• "Leaves skin feeling nourished"
• "Pleasant fragrance for relaxation"

Claims you CANNOT make without a medicines licence:

• "Treats eczema" or "relieves psoriasis"
• "Reduces joint pain" or "anti-inflammatory"
• "Cures acne" or "clears skin conditions"
• "Relieves symptoms of anxiety"
• "Aids digestion" or "settles the stomach"
• "Boosts immunity" or "fights infection"

The grey area sits around words like "soothe" and "calm". Saying a product "soothes dry skin" is generally accepted as cosmetic. Saying it "soothes inflamed joints" is medicinal. Context matters: always ask yourself whether the claim implies treatment of a named condition.

Verbal claims count too. If your product label is clean but you tell a customer at your stall that the balm "works wonders for arthritis", you have made a medicinal claim. The same applies to social media posts, flyers, and any other marketing material.

CBD products: medicines, novel food, and cosmetics

CBD (cannabidiol) products sit at the intersection of three regulatory frameworks, making them one of the most complex areas for craft sellers.

Medicines: if you make any medicinal claim about a CBD product ("reduces anxiety", "helps with chronic pain"), it becomes a medicine and must be licensed by the MHRA. Currently, only one CBD medicine (Epidyolex) holds a UK marketing authorisation. All other CBD products making medicinal claims are unlicensed and illegal to sell.

Novel food: CBD extracts are classified as novel foods by the Food Standards Agency (FSA). If your CBD product is intended to be ingested (oils, gummies, capsules, teas), it must have a validated novel food application with the FSA to remain on the market. The FSA maintains a public list of CBD products that have submitted valid applications. Products not on that list should not be sold.

Cosmetics: CBD can be used in cosmetic products (creams, balms, lip products) provided the product has a Cosmetic Product Safety Report, is notified to the OPSS, and makes only cosmetic claims.

THC limits: all CBD products in the UK must contain no more than 1mg of THC per container (not per dose). This is a controlled substance threshold, and exceeding it is a criminal offence under the Misuse of Drugs Act 1971.

For craft sellers, the safest approach to CBD is to have full traceability for your CBD ingredient (certificate of analysis from the supplier showing cannabinoid content and THC levels), ensure your product fits clearly into either the cosmetics or novel food framework, and never make medicinal claims.

Aromatherapy and essential oils

Essential oils occupy a particularly common grey area at craft fairs. The oils themselves are not medicines, but the way you sell them can make them so.

What is fine:

• Selling essential oils as fragrance products for use in diffusers, burners, or pot pourri.
• Describing scents as "relaxing", "uplifting", or "refreshing" in a general wellbeing sense.
• Selling aromatherapy candles or room sprays for ambience and fragrance.
• Offering aromatherapy massage oils as cosmetic products (with a CPSR and correct labelling).

What crosses the line:

• Claiming an oil "treats headaches" or "relieves sinus congestion".
• Saying a blend "cures insomnia" or "reduces blood pressure".
• Marketing a roller ball as a "migraine remedy" or "anxiety treatment".
• Providing dosage instructions for treating a named condition.

The distinction is between selling a pleasant, fragrant product and selling a treatment. You can say "our lavender blend has a calming scent"; you cannot say "our lavender blend treats anxiety".

If you are a qualified aromatherapist offering one-to-one consultations, the rules around what you can discuss with individual clients differ from what you can print on labels and marketing materials. However, any product you sell over the counter at a craft fair is judged on its labelling and presentation, not on your qualifications.

Practical steps for stall signage and labelling

Before your next craft fair, work through this checklist:

• Review every product label. Read each word and ask: does this claim or imply that the product treats a medical condition? Remove or rephrase anything that does.
• Check your signage and banners. Market stall signs often contain bolder claims than labels. "Natural pain relief" on a banner above your stall is a medicinal claim.
• Audit your printed materials. Flyers, business cards, price lists, and leaflets all count. Remove references to treating, curing, healing, or preventing conditions.
• Review your online presence. Your website, social media, and marketplace listings are covered by the same rules. Trading Standards officers routinely check sellers' websites before or after visiting a fair.
• Brief anyone helping on your stall. If a friend or family member is covering the stall while you take a break, they need to know not to make medicinal claims in conversation with customers. A simple list of "phrases to avoid" can help.
• Prepare a response for customer questions. Customers will ask "does this help with my eczema?" or "will this fix my back pain?". Have a polite, honest answer ready: "I can't make medical claims about this product, but I can tell you about the ingredients and how other customers use it."
• Keep records. If you reformulate a product or change your labelling, keep a dated copy of the old and new versions. This shows Trading Standards that you take compliance seriously.

Enforcement and consequences

Trading Standards is the primary enforcement body for medicinal claims at craft fairs and markets. Officers carry out routine inspections at events, and they look at labels, signage, verbal claims (sometimes via test purchases), and online marketing.

The MHRA can also investigate directly, particularly for products sold online or where a complaint is made. The MHRA has the power to issue warning letters, require product recalls, and refer cases for criminal prosecution.

Consequences of selling products with unlicensed medicinal claims:

• Informal advice or a warning letter, which is the most common first step for a minor or inadvertent breach.
• A formal requirement to remove the product from sale and amend labelling.
• Seizure of products at the event.
• Criminal prosecution under the Human Medicines Regulations 2012, which can result in an unlimited fine and up to two years in prison.

In practice, most enforcement starts with education. Officers would rather help you fix the problem than take you to court. But repeat offenders or sellers making serious claims ("cures cancer", for example) can expect a much harder response.

Event organisers also play a role. Many craft fair hosts now include a clause in their terms requiring sellers to confirm that their products do not carry unlicensed medicinal claims. If you are found in breach, the organiser may ask you to leave the event or decline future bookings.