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Preservative Free Claims
I saw this post on my Facebook feed. Am I being harsh in doubting that this product could be used and the finished product be considered “preservative free.” The Leucidal line ( Leuconostoc/Radish Root Ferment Filtrate & Lactobacillus) has been available for years and is arguably a preservative. They add a moisturizing material (Cocos Nucifera (Coconut) Fruit Extract) with preservative boosting properties. I am missing how they can make the claim.
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15 Replies
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I guess that depends on what the word “preservative” means. Maybe the Leucidal line is not an approved preservative in the EU so the supplier doesn’t consider it a preservative even if that’s what it is.
It sounds unethical to me. The only reason you would add leucidal is to work as a preservative.
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Hi Perry & Mark, I hope you are well.
Regarding the post that was online yesterday (It was retracted) I wanted to provide a response for those who did read it, regarding claiming preservative free cosmetics.
FSS is
issuing this statement to correct a previous post which erroneously suggested
that Active Micro Technologies products can be used to make “preservative-free”
cosmetics. It is FSS’s opinion that all cosmetic producers should at very least
meet the minimum microbiological testing suggested by the PCPC. It is not FSS’s
position to suggest to their customer base which claims to make. It is the
responsibility of the cosmetic producers to insure that their products are
safe, and that any claims they make are valid within the regulations pertinent
to their markets. This includes claims for “preservative-free” products.“Preservative-free”
products are a contentious issue as they tend to confuse the common use of the
word “preservative” with the legal definition of a “preservative” which varies
from country to country. Technically in many markets a “preservative” is a
substance registered with the appropriate governmental authority.Currently in
the US, FSS is not aware of a definition published by the FDA, on what makes
“preservative-free” a viable claim. In CFR 21 part 101 the FDA defines a
preservative for food as follows:
“The term chemical preservative means any
chemical that, when added to food, tends to prevent or retard deterioration
thereof, but does not include common salt, sugars, vinegars, spices, or oils
extracted from spices, substances added to food by direct exposure thereof to
wood smoke, or chemicals applied for their insecticidal or herbicidal
properties.”In truth,
there is no single preservative that insures the microbiological integrity of a
cosmetic product. It is the combination of various components, that together,
can be best described as the “preservative system”, which helps to prevent
in-use microbial contamination of cosmetics. We feel that this should be the
starting point for the conversation on “preservative-free” claims.We further
encourage our customers to take all recommended steps to insure that their products
comply with the FDA guidelines for safety and microbiological integrity. The
FDA fact sheet for small business and homemade cosmetics is great place to
start.Any opinions
presented herein are solely those of FSS.Thank you,
Maggie Ghanem
http://www.FormulatorSampleShop.com -
It is great to see such a responsible response. Many distributors would have stuck to their position regardless or just not responded. I am glad to see FSS step up and show some integrity.
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I am very, very impressed by this. FSS handled this professionally, quickly and correctly.
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They should say Preservative-Free*
* = only using natural ingredients with antimicrobial effects etc.
Or if anhydrous you can explain preservatives aren’t necessary. Ideally also let the customer know what preservative challenge test has been passed.
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No, especially since the product is a preservative. That is not under debate here. Also per AMT, they begrudgingly admit an anti-microbial is treated as a synonym for a preservative.
These claims should be avoided altogether.
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All of these “X Free” claims are so misleading. Saying “preservative free” implies that there is something wrong with having preservatives. There isn’t.
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So what should we call a system such as Kem Nat? Something like, “self preserving”?
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It is benzyl alcohol (an Organic alcohol preservative) combined with preservative boosters.
To demnostrate my assertion, here is what Akema describes the product as “It is a synergistic combination of well established preservatives with
preservative boosters that enhance the antimicrobial effect and add
emolliency.”Reference: http://www.akema.it/preservatives.htm#KEM_NAT
Hence, call it a PRESERVATIVE.
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So does that mean that benzyl alcohol is not permitted in Europe? Or limited to a %? Or -
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No, but if you do an IFRA declaration I believe you have to claim it. Honestly I don’t have the EU limits memorized BUT I know where to find them should I need to. If you really want more details, David Steinberg’s book covers the regs in depth.
https://www.amazon.com/Preservatives-Cosmetics-Third-David-Steinberg/dp/1932633944
The take away is that it is a preservative. I will say at least on my part these preservative free claims make me leary. In most cases they are using something that has preservative properties but hasn’t been formally recognized as such. Also, any reticence with preservatives can generally be overcome by stressing the safety aspects of proper preservation. I think that FSS does a model job of this in their statement.
Lastly, I see more and more Home Crafters with moderate experience attempting to justify “preservative free” wrongly simply to fit their underlying Chemophobia. In almost each case where I stress the need for safety and proper preservation to these “audiences,” invariably someone will cite a commercial product and say “they don’t use a preservative.” In most cases they do, but it is a less common or older preservative and they don’t recognize the INCI names. A great example of this is Biovert (Glucose & Lactoperoxidase & Glucose Oxidase). Once you identify the preservative they will invariably cite another product with a preservation strategy they don’t recognize. In the end, they are simply exploring loopholes in order to meet what they feel is an absolute market trend (my customers don’t like preservatives). This overlooks safety and is really outside of their areas of experience.
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From Colin’s Beauty Page’s. Colin is an outstanding Cosmetic Chemist and a great reference on EU Regulations;
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@Microformulation if you want the chapter and verse in the EU regulations, the relevant Annexes are III/45 and V/34; the former covers its use in fragrances, and the latter covers its use as a preservative
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@Bill_Toge Thank you for the references.
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