The formulator’s perspective: ‘free from’

There have been rumours flying around the industry for some time that ‘free from’ claims are going to be banned. While a statement given by the CTPA in June 20121 stated such a blanket ban was not being introduced for the time being, a key development in February 2013 was the publication of a document by the European Commission (EU)2 that has caused some sizeable ripples across the industry.

Claims for cosmetic products shall not ‘denigrate ingredients legally used’3

The above quote from the document is of most interest here. Where does that leave claims and pack wording such as ‘petrochemical-free’, ‘propylene glycol-free’ and even ‘paraben-free’ (I will leave this one in particular for another day!)? Of course ingredients of petrochemical origin, propylene glycol, and parabens are legally used in cosmetic products in line with European legislation. For parabens specifically you can access a useful summary document prepared by EU back in 2011 for consumers.3 I am in no doubt the latest EC document and text will be open to interpretation and challenge, but I think it certainly makes for interesting reading and contemplation. Like all formulation companies, we are regularly asked to formulate products that are free from XY and/or Z. I do not believe for a minute that will change in light of this new situation regarding claims. I always ask clients for their reasoning for using or not using certain ingredients and to challenge thinking, but ultimately there is no right and wrong answer in most cases. I believe the natural sector will continue to grow, but what may change (will change if you read the letter of the legislation) is the related claims, including ‘free from’. I do not sit in the camp of automatically fighting against marketing-led requests for free from XY & Z (whether it is paraben or petrochemical ingredients for example) but equally I cannot sit back and bite my tongue when I hear talk of ‘chemical free’ products and the like. Formulators can get a reputation for always simply toeing the technical line rather than accepting consumer demand. I think there is a balance to be met where we should always challenge reasoning for desired claims and wording to assist marketing colleagues in making informed decisions. The vast majority of brands do a great deal of research before reaching a point of wishing to steer clear of certain ingredients and we should fully support this, whether we necessarily agree with specific cases or not. However at the same time we all come across brands (usually at natural trade shows for instance) claiming to be free from X, Y or Z without really knowing why, or more likely without really having a relevant reason. Perhaps the new legislation will help the industry to strive away from such situations. Ultimately we as formulators have to react to consumer demand so there is no point wasting energy justifying and recommending the use of parabens (for example) to a brand that will never in a million years do so. There is nothing new about this, and it certainly is not unique to personal care. In fact when talking to a lot of natural-themed brands, the awareness of the overall good safety profile of parabens is well appreciated but that still does not mean consumers will agree, and therefore a lot of the time hands are tied. It is exactly the same across all consumer good markets, where sometimes trends and consumer demands are driven less by scientific facts and more by media reports, specific marketing successes or random events.