Why We Will Never Be Free From “Free-From” Claims


Many of us who work in the industry were shocked when “free-from” ingredient claims appeared more than 10 years ago. It was offensive to our understanding of the safety of cosmetic products. We felt they besmirched the reputation of safe and useful ingredients we had trusted for years.

When paraben bashing became widespread, cosmetic formulators scrambled to find new preservative systems and the seriousness of this trend became truly apparent. Ingredient after ingredient has been attacked, and no amount of communication by the industry or its experts seems to have had an impact. Cosmetic manufacturers have retreated from known and trusted ingredients and have been forced to embrace ingredients we know far less about.

We have sadly been reminded of a fundamental principle in product development: It doesn’t matter what the scientists say. The consumer is in charge, and those who fail to give the consumer what he or she wants will not succeed in the marketplace.

Hope for Change?

For those who feel there remains a faint hope of a turnaround, look no further than the “Free-from Skin Care Awards.” Started in the United Kingdom in 2012, these annual awards are given to brands and products that fulfill the organizer’s beliefs about what cosmetic products should be free from.1 Products that include any of the following ingredients are excluded from the competition:

As is often the case, programs like this often arise out of the genuine health and wellness concerns of the organizers. This is backed by fear and mistrust of the cosmetics industry, which sadly is regarded by many as a simple extension of the chemical industry. And how could we possibly expect to oppose this trend when many members of the industry have themselves embraced it for their own marketing advantage?

We are at the point where even retailers have added their voices, sometimes grouping products and brands by what ingredients products are “free-from.” But for veteran scientists in the industry, products that are “free from” the conventional ingredients that have been trusted for years raise enormous concerns: what is their consumer acceptance? What is their shelf life? How would they perform in preservative challenge testing?2

What Happened?

Over the water cooler, experts have pondered what went wrong. How could we possibly have let the agenda slip from our grasp, for consumer misinformation to become so widespread, and for us to lose control of our laboratories and research and development programs? It’s not possible to attribute this trend to any one factor; however, the advent of social media has given a voice to countless individuals with concerns about their health and wellness.

The availability of endless amounts of online news media creates a dizzying and incomprehensible amount of information about our health, from the foods we eat, the packaging we use and the environmental hazards we face. For even the well-informed, sorting out the truth can be next to impossible. The fundamental issue at the core of this trend is consumer mistrust that we have failed to temper, and have in fact fed.

The reality we are now faced within the cosmetics industry is the lack of trusted preservatives, which could lead to far greater risk than any of the ingredients we are now “free-from.”3 From years speaking with consumers, we know that they constantly need reminder that cosmetics require the use of preservatives to protect them from microorganisms. This, in fact, is likely the largest issue pertaining to their health in the cosmetic category. It is not only ethical but legally required for all manufacturers. The most effective preservatives are the ones that have years of safety data supporting their use. It is believed that many new preservative systems do not have the same level of study and support.3

So the important question we must face is: Are cosmetics fundamentally safer now that so many are “free from” countless ingredients? Is there evidence of fewer cases of contact dermatitis among users? 

Searching for hard evidence is difficult. Anecdotal conversations with frontline medical practitioners would suggest that not a lot has changed, partly because our industry has never created a great deal of health issues for consumers. However, there is reason to believe things have the potential to become worse yet.3

The Future

From 60,000 feet, the industry seems to be headed towards unchartered water. In the area of preservation of aqueous cosmetics, we have all but eliminated parabens. Some manufacturers moved to the MI/MCI preservative system but the European Union—and most recently Health Canada—have rushed to eliminate it. Phenoxyethanol became an important ingredient in our armamentarium, and it is now under pressure. Anecdotal reports from colleagues in microbiology labs suggest more and more products are failing preservative challenge tests and micro content tests in finished products.4

Our alternative choices are limited. In the European Union, if a preservative is not listed within Cosmetic Directive 76/768/EEC, it cannot be used. It is possible to use a non-listed ingredient, however, it can be complicated and expensive. In almost all cases, many new preservative systems have far less data, both in terms of effectiveness and safety.4

Married to the “free-from” claim is the other very important trend toward “natural” ingredients. The simple concept in the consumer’s mind is, “get rid of the chemicals, make everything natural.” While there is no universal definition of “natural,” consumers tend to believe the word means, “derived from nature” and “free from synthetics or chemical compounds.” Also implied is that these products will be free from adverse reactions.

From what we see, the paradigm that natural is better and safer than “synthetic” is ubiquitous among the consuming public, including many new innovative companies. This is in spite of the well-established position of regulators such as the U.S. FDA and Health Canada. For example, when asked if cosmetics made with “organic” ingredients are safer for consumers than those made with ingredients from other sources, the FDA stated “No. An ingredient’s source does not determine its safety. For example, many plants, whether or not they are organically grown, contain substances that may be toxic or allergenic.”5

According to Health Canada, there is a general assumption among consumers that “natural” products are better or healthier than similar ones that use synthetic ingredients. However, it is important to understand that “natural” ingredients are sometimes no different in chemical composition than their synthetic counterparts. In fact, the Canadian government has stated that, “a synthetic substance that mimics a natural one can sometimes produce a purer, more stable ingredient that gives the product a longer usable life.”6

An important paper written by An Goossens, called New Cosmetic Contact Allergens, said:2

“There are however several problems involved regarding the allergenic behavior of natural products: these are complex mixtures of many chemical ingredients, the exact nature of which is, in most cases, not known. Their chemical nature, hence their allergenic potency, may vary from batch to batch according to their origin, which also influences patch testing since standardization is not possible. Moreover, there is the role of auto oxidation, skin penetration and or skin metabolization.”4

It is not uncommon to isolate thousands of individual chemical entities from natural materials. For any given plant species, this can vary from season to season and even field to field where the plants are grown. Pause for a moment and consider that the EU has identified 26 fragrance allergens it no longer wishes to have in cosmetic products.7 How many potential allergens exist in a single plant extract? How will we possibly deal with the enormous number of individual plants being pushed into service for cosmetics, with their extremely complex chemistries, species variation and global differences?


So what is the outcome from the “free-from” obsession? Looking at the two factors considered here, our growing difficulty preserving cosmetics and the dramatic increase in natural materials, it would be straightforward to extrapolate to issues ahead.

It could be expected that consumer complaints could rise, and adverse events increase. In other words, a program intended to make life better for consumers may in fact have the opposite effect. We have also created enormous consumer confusion because proclaiming that certain ingredients are absent falsely implies they are harmful. As a result, consumers are being misled to believe that any product not using a particular ingredient is safe.8

All this said it would seem the “free-from” claim is here to stay. Consumers’ minds are made up, and at the end of the day, it is their vote that counts. What consumers should be looking for are cosmetics that are “free-from” bacteria, yeast, mold and fungi, as well as irritation and allergic reactions.

How can the industry meet such a challenge? Are we headed towards anhydrous cosmetics? Or perhaps cosmetics in the refrigerator case next to milk and yogurt? Single-serve pasteurized moisturizers like dairy creamers on the airplane? And finally, we will be looking for careful refinement and tight quality control of natural ingredients. Products formulated with these will need very thorough allergy assessments and adverse event tracking to see how they perform.

With the enormous resources and endless creativity of this industry, we are confident these challenges will be met, as so many others have in the past.


  1. Free From Skin Care Awards 2016. (n.d.). Retrieved from Free From Skin Care Awards: http://www.skinsmatter.com/freefrom_skin_care_awards/index.html
  2. Bird, K. (2009, March 13). “Free from” claims can trade on false safety concerns says trade body. Retrieved from Cosmetics Design-Europe: http://www.thefactsabout.co.uk/files/237201013545Allergy_Card.pdf
  3. Alternative Cosmetic Preservatives - What are your options? (n.d.). Retrieved from Chemists Corner: http://chemistscorner.com/alternative-cosmetic-preservatives-what-are-your-options/
  4. Goosens, A. (2015, February 4). New Cosmetic Contact Allergens. Cosmetics, 2, 22-32. doi:10.3390/cosmetics2010022
  5. U.S. Food and Drug Administration. (2010, September 15). “Organic” Cosmetics. Retrieved from Labeling Claims: http://www.fda.gov/Cosmetics/Labeling/Claims/ucm203078.htm
  6. Government of Canada. (2014, June 10). Cosmetic advertising, labelling and ingredients. Retrieved from Government of Canada: http://healthycanadians.gc.ca/product-safety-securite-produits/consumer-consommation/education/cosmetics-cosmetiques/advertising-publicite-eng.php
  7. European Union Cosmetics Directive. (2013, July 11). Cosmetic Products Ingredient Labelling. Retrieved from The Cosmetic, Toiletry & Perfumery Association: http://www.thefactsabout.co.uk/files/237201013545Allergy_Card.pdf
  8. Free From “Free From”. (2010, November 4). Retrieved from Personal Care Truth: http://personalcaretruth.com/2010/11/free-from-free-from/ 
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