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Claim Placer: The Scalp Serum Substantiation Ladder
Write the sentence you want on the front of the bottle, choose the closest match below, and the placer tells you which rung it sits on, what evidence that rung asks for, and what it does to the schedule. Placing the claim before development starts is what stops the evidence work becoming a surprise at the end.
It describes how the scalp or hair feels or looks after use — refreshed, less tight, lighter roots.
It says the product supports a balanced scalp environment, without putting a number on it.
It states a measured change as a figure — a percentage, a count, a time to result.
It promises hair growth or regrowth, of the kind made for serums built on a drug active.
Before you take this to a regulator or a retailer
This placer describes where the evidence burden sits in a manufacturing programme. It is not regulatory advice, and the rules that apply to your claim depend on the market you are selling into. Your regulatory adviser makes that call, and we supply the manufacturing-side records they ask for.
Facility registration, product listing, safety substantiation and adverse event duties for cosmetics marketed in the United States sit at 21 U.S.C. §§ 364a–364e (Office of the Law Revision Counsel, U.S. Code).
