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How to label sulfate-free
I would like to ask, if the shampoo does not contain sulfate, the by-product in the raw material Sodium C13-14 Olefin Sulfonate contains 0.2% sulfate, so when the finished product is released, can it be claimed sulfate-free? I have searched many documents but there is no information that clearly states this issue. Thank you.
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2 Replies
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What Phil said, free from claims are being phased out worldwide. It’s taking a while but in general we cannot say something is “free from”.
Like most countries, here in Australia “Free from” claims must be substantiated and not misleading under the Australian Consumer Law (ACL). TGA intervenes if claims imply therapeutic benefits or risk, e.g. “free from chemicals” could imply other products are harmful.NZ follows similar rules via the Fair Trading Act 1986 enforced by the Commerce Commission.
In Canada “Free from” claims are discouraged when they imply a hazard that does not exist (e.g., “preservative-free” on a product that doesn’t need preservatives). If used, claims must be truthful, not misleading, and supported by evidence. Oh and if the ingredient is on the hotlist you can’t say it’s free from them. so, ingredients already prohibited cannot be referenced in “free from” claims.
If you read the document/regulations that Phil linked in the previous comment, you will see that “Free from” claims may render a product misbranded if they misrepresent safety or composition. e.g., claiming “free from parabens” can be misleading if implying that parabens are unsafe, given FDA has not banned them.
The EU rules basically say claims must be truthful, honest, fair, and supported by evidence; “free from [ingredient]” is not allowed if the ingredient is already banned; they must not denigrate legally allowed ingredients (aka, sulphate free is a HUGE no-no) and they must be relevant to the product (e.g., “alcohol-free” on water-based products is irrelevant).
ASEAN countries follow similar rules to the EU and the UK, aka, must not mislead consumers, must be substantiated by data and negative claims (e.g., “free from harmful chemicals”) are discouraged as they imply legal products with such ingredients are unsafe.
Mexico accepts “free from” claims if truthful and not misleading, but there’s growing scrutiny. Brazil discourages “free from” claims that imply superiority or safety gaps with approved ingredients. Argentina and Chile align with similar standards, can’t imply that other permitted ingredients are unsafe, must not mislead consumers, etc..
Japan, Korea, China, and most other countries have similar rules, free from is generally discouraged worldwide.
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