Formulating with Naturals—Hair Care

By: Art Georgalas, Georgalas Endeavors LLC

Posted: April 5, 2011, from the April 2011 issue of Cosmetics & Toiletries.

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NaTrue: NaTrue, another European natural products certifier, recently announced² it will form a harmonized natural standard in collaboration with NSF International, brokered by the Quality Assurance International (QAI) organization.³ QAI has taken a lead in promoting the NSF/ANSI 305 standards that it administers and is proactive in providing education for these standards. NaTrue’s standard states that any detergent surfactants used must be completely biodegradable in accordance with the European Commission’s Regulation on Detergents; however, other materials were not specifically addressed as recently as early February 2011.⁴

USDA: In the United States, natural product guidance was recently complicated by the addition of the new US Department of Agriculture (USDA) category of “biopreferred,” i.e. biobased fabricated and formulated products. Such products are distinctly different from products certified as organic at one of the four levels by the National Organic Program (NOP). Both of these certifications were promulgated by the USDA. The latter, USDA Organic, was developed to certify agricultural products, clearly the domain of USDA, while the former was initially developed to drive federal procurement practices in a more sustainable direction. This more recent biopreferred standard now anoints a wide variety of consumer products, including personal care items such as hand cleansers, sanitizers, lip products and more recently, hair care, as presumably more sustainable for the environment.

To be designated as biobased, a consumer product must simply meet the requirement for what portion of its content is derived from a biological origin. Percentages for each consumer category varies extensively: carpets 7%, towels 12%, glass cleaners 49%, lip products 82%, shampoos 66%, conditioners 78%, etc.⁵ The jurisdiction here appears to span several agencies including the US Food and Drug Administration (FDA), the US Environmental Protection Agency, and the US Consumer Product Safety Commission. With this new biopreferred standard, the USDA likely does not imagine it could be opening another Pandora’s box as it did with the NOP certification since this standard was developed for farm and derivative food products and is therefore difficult to apply to personal care ingredients and products—hence the promulgation of the aforementioned NSF/ANSI 305 standards for personal care products containing organic ingredients.

The personal care industry is aching for ways to market its products as green—whether they are truly sustainable, milder to the skin, or simply derived from natural origins. Therefore, the new biopreferred standard presents marketers with a unique product positioning especially if there is a government agency that sanctions the claim because even with the continued antigovernment rhetoric in the media, consumers still trust government agencies as a credible arbiter of advertising claims.

At the Bench

From a pragmatic perspective, this column aims to address what materials consumers may accept and product developers can use to formulate natural hair care products. Most hair care products fit into what could be considered a holistic product paradigm, meaning the whole product itself delivers consumer benefits. This is different from the drug delivery paradigm for personal care formulas, wherein a defined set of actives such as sunscreens, antioxidants, anti-acne and anti-aging materials, etc., deliver the desired benefits. Antidandruff shampoos as well as, arguably, permanent waves or hair colorants also fall into this latter category. In this paradigm, the active ingredients perform a function and the surrounding product is an optimized vehicle or package that carries those goods to the “address” on the label—i.e., the skin, scalp or hair shaft—to deliver the desired benefits. The presumed benefits that accrue from the product feature, in this case the feature of being natural, are enhanced safety or mildness.