“Free From” Claims
You may have noticed the abundance of websites and products that claim something is “free-from” particular ingredients, like “Paraben-free”. We are pivoting away from this but wanted to ensure our customers know why and how they can start doing this themselves.
No True Guarantees It’s “Free From”
Essentially, no company can fully guarantee, with absolute certainty, that a product is completely “free-from” a certain ingredient. Even if it is not added or part of the formulation, many molecules are carried in the air, found in nature, or make contact with ingredients at some stage of its life.
You can do everything possible as a company to ensure that no part of your product is stored in or around packaging that contains phthalates, for example, but can you truly guarantee that the goat milk used in your bath soak never passed through plastic tubing that contained phthalates? Even if you can guarantee this, what if there is a rupture in the phthalate-free tubing on the Greek farm you source from and one day they repair it with a new tube?
This can quickly slide into a pedantic argument, where it becomes clear that an ingredient or molecule in question is present in only very negligible amounts. However, several companies have faced lawsuits and lost because trace amounts of a compound have been found.
EU Regulations: No More Misleading [Chemical]-Free Claims
Recently the European Union (EU) enacted legislation starting on July 1st, 2019, prohibiting the use of “free-from” statements. Not only because companies cannot 100% guarantee the absence of a chemical, but because those statements imply that the use of approved chemicals is unsafe, such as parabens.
By stating that this lotion is “paraben-free”, the assumption is that parabens are dangerous in levels that are approved as safe. The EU is content that its regulations are safe and thus doesn’t appreciate the implication that products using approved ingredients are somehow harmful.
This is an easy marketing trick for any product too—describe what a product is – by either renaming it or saying it is free from something, even if there would be absolutely no reason to have that other ingredient in it. For example, you could release a Micellar Water and add that it is “Rice Sugar-free” or “free from rice sugars”. This statement is essentially worthless, in part because it implies that most people would find that information useful and in part because it implies that rice sugar is both a normal ingredient in this instance, but also a harmful one.
So, to cover both the impossibility of guaranteeing a lack of a compound and to follow EU regulations, we are erring, as we always try to do, on the side of proactive compliance.
Given the number of products on our site, I can assure you that there are NEVER added parabens, or phthalates, etc. There are many ingredients that are never used here at Private Label Skincare Florida. A full list of ingredients is available for every product we make, both custom and stock. You will always be given this list which also reflect the percentage of organic ingredients in the formula. We pride ourselves in being Natural and Organic and are proud to say we are now Certified Organic. While it is impossible to make every product 100% organic, we stay as close to that standard as possible and use mainly plant based ingredients.
However, we strongly encourage you to adopt this change as soon as possible, especially if you are interested in entering the EU market. It is only a brief matter of time until consumers catch up, so we hope our reasoning makes sense.
No Added Phthalates
No Added Parabens
No Added Palm
No Added Gluten
In the meantime, if not the EU market, let the threat of litigation be a guide: there is really no way you can fully guarantee a lack of a certain common ingredient. For example, blueberries, cucumbers, and carrots all have naturally occurring parabens. Perhaps you have a blueberry powder that floats through the air and “contaminates” a nearby lotion—now you can no longer ensure that there are zero parabens present.
Human bodies produce parabens as well, in addition to many other seemingly unappealing chemicals that are useful for our functioning, including formaldehyde, acetone, and ammonia. Which is simply to say everything in moderation, with transparency coming first. Therefore, we appreciate compliance—there is so much to learn and labeling laws help consumers understand it all better.
Here at Private Label Skincare Florida do our very best to educate our clients on all the label and compliance regulations, so that we can better serve our clients. All the claims by the marketing personnel have given many safe and effective ingredients a bad name and made the consumer feel it is being damaged by many great products on the market. Please feel free to ask us any questions regarding labeling, ingredients, and compliances we will be happy to help. Call Product development for more information. Direct number: 727-258-5740 or our main number 727-466-1703 Ext.110 for more information.