The topic is short and compact
The surfactant system is the first choice: sulfate-free systems are milder, but harder to thicken, foam less, and generally cost more.
A pH value of at most about 5.5 is technically justifiable; it is coordinated with the preservation system and also measured during stability testing.
Zinc pyrithione has been banned in EU cosmetics since March 1, 2022; anti-dandruff shampoos require substitutes and a new preservative challenge test.
At Labtree, a shampoo based on a tested white-label formulation with standard packaging is usually ready for delivery after 2 to 3 months, while a new development typically takes 3 to 6 months.
Starting October 17, 2027, the EU restriction on synthetic polymer microparticles will also apply to rinse-off products such as shampoos.
So läuft die Entwicklung bei Labtree
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Konzeptionierung
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Bemusterung – Standardmuster in 24 h
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Individualisierung
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Prototyping
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Produktion
White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
Which surfactant system matches which positioning?
The surfactant system determines cleaning performance, foam characteristics, skin compatibility, and raw material costs. It is therefore the first specification defined in the briefing. A review paper in the Indian Journal of Dermatology categorizes surfactant classes as follows:
Anionic surfactants such as Sodium Laureth Sulfate remove sebum very well and foam vigorously. According to the review paper, excessive degreasing makes hair appear rough, dull, and more easily tangled.
Amphoteric surfactants such as Cocamidopropyl Betaine behave anionically or cationically depending on the pH value and are considered mild. They are typically used as co-surfactants.
Non-ionic surfactants are among the mildest cleansers and are usually combined as secondary surfactants with an ionic surfactant; in practice, these are frequently alkyl glucosides.
Cationic surfactants have weak cleansing power, but they improve softness and combability and are primarily found in products for damaged hair.
According to the same study, modern shampoos usually combine two to four surfactants: a primary surfactant and co-surfactants that compensate for its weaknesses. The primary surfactant appears first in the INCI list because it has the highest concentration.
What sulfate-free systems change technically
Sulfate-free systems based on amino acid surfactants (such as Sodium Cocoyl Glutamate), isethionates, or glucosides are milder, but behave differently in the formulation. Traditional sulfate-betaine systems can be thickened with common table salt, whereas sulfate-free systems often hardly respond to it and require polymer or gelling thickeners. Foam volume is usually lower. These raw materials typically cost more than sulfates, which directly impacts the unit cost in rinse-off products with a high surfactant content. Anyone wishing to claim sulfate-free should be aware of these compromises prior to the first sampling.
What is the right pH value for a shampoo?
From a technical standpoint, a slightly acidic shampoo with a pH value of at most about 5.5 is justifiable. A study in the International Journal of Trichology cites a pH value of 5.5 for the scalp and about 3.67 for the isoelectric point of the hair fiber. An alkaline pH value increases the negative charge of the fiber surface, thereby increasing friction, snagging, and frizz. The authors therefore recommend shampoos with a pH value of no more than 5.5. Of 123 shampoos examined, 61.78 percent were above this; a uniform target value does not exist.
What pH control means in the formulation
Adjustment: The pH value is lowered using organic acids; the review paper on surfactants mentions citric and glycolic acid, while lactic acid is also common in practice.
Preservation: Many common preservatives based on organic acids are only effective in the acidic range. The target pH value and the preservative system are therefore determined together.
Surfactant compatibility: Not every surfactant remains clear and stable in viscosity at pH 5. Some amino acid surfactants become cloudy in the acidic range.
Drift: The pH value can shift over time. It is therefore one of the parameters measured during stability testing.
A claim such as “skin-neutral” or “pH skin-friendly” requires a measured value on the finished product, not just a target value from the formulation.
What applies to anti-dandruff shampoos since the ban on zinc pyrithione?
Zinc pyrithione was the standard active ingredient in anti-dandruff shampoos for decades. Since March 1, 2022, the substance has been banned in cosmetic products: Regulation (EU) 2021/1902 removed the substance, classified as a CMR substance of Category 1B (toxic for reproduction), from Annex III (entry 101) and Annex V (entry 8) of Regulation (EC) No 1223/2009 and added it to Annex II, the list of prohibited substances. An exemption under Art. 15(2) for anti-dandruff shampoos up to 1 percent was applied for, but not granted, because it was not established that suitable alternative substances were lacking. Inquiries regarding zinc pyrithione formulations for the EU cosmetics market thus come to nothing, and existing formulations had to be reformulated.
Which alternatives are used
Mainly climbazole and piroctone olamine are used as replacements, sometimes combined with salicylic acid. For climbazole, the Scientific Committee on Consumer Safety (SCCS) stated in an addendum to its opinion (SCCS/1600/18) that the substance is safe for consumers up to a concentration of 2 percent in shampoos. All these substances are regulated in the annexes of the Cosmetics Regulation with maximum concentrations and product types. The current annex entry should always be checked prior to formulation approval, as the Commission regularly adapts the entries.
Formulation issues during the transition
Zinc pyrithione was present as an insoluble dispersion, whereas climbazole and piroctone olamine are generally incorporated dissolved. Viscosity, appearance, and pearlescence can change as a result.
Zinc pyrithione was also listed as a preservative, and the substitute active ingredients influence the preservation system. A new challenge test according to ISO 11930 is therefore generally recommended.
The claim "anti-dandruff" is an efficacy claim and must be substantiated on the finished product according to Regulation (EU) No 655/2013. Medical claims such as the treatment of a scalp condition do not belong on a cosmetic product.
Which evidence supports which formulation is described in the magazine article on cosmetic claims in the EU.
What nourishing active ingredients can achieve in a rinse-off product
A shampoo is a rinse-off product with a short contact time on the hair and scalp. A large portion of the active ingredients is rinsed out with the foam. This limits what can credibly be claimed about conditioning agents. Realistic expectations primarily include effects on the hair surface:
Cationic conditioning polymers such as Polyquaternium-10 or Guar Hydroxypropyltrimonium Chloride deposit onto the hair during rinsing and improve wet combability. Their effect depends heavily on the surfactant system: with anionic surfactants, they form complexes upon dilution that ultimately produce the conditioning effect.
Panthenol and hydrolyzed proteins are well tolerated and can be incorporated into clear systems. Claims regarding shine or smoothness require substantiation on the finished product.
Caffeine and plant extracts are often associated with hair loss or hair growth. With a short contact time, such an effect is difficult to substantiate. Furthermore, claims regarding hair growth quickly border on medicinal products.
For purchasing and product management, this means: The list of active ingredients should be built around the planned claim and the available evidence, not the length of the list. Raw material data from the supplier describes the raw material at its test concentration, not the rinsed-out shampoo.
Viscosity, appearance and microplastics: Where formulation and filling are connected
Viscosity and appearance determine how a shampoo comes out of the bottle and how it looks on the shelf. At the same time, they decide its fillability.
Clear gel: requires all raw materials to remain dissolved, even in the cold. Cloudiness at low temperatures often only becomes apparent during cold storage.
Pearly or opaque: is created using pearlescent waxes such as glycol distearate or opacifiers. Pearlescence requires a controlled cooling process during production, otherwise it will vary from batch to batch.
Viscosity: A formulation that is too thin will leak from the flip-top cap for the customer, while one that is too thick is difficult to dispense via pump dispensers and slows down filling. The target range is therefore coordinated with the packaging material.
Microplastics in rinse-off products
Some opacifiers and film formers are solid synthetic polymers that may fall under the EU restriction on synthetic polymer microparticles. According to Regulation (EU) 2023/2055 (Annex XVII entry 78 para. 6 point b of the REACH Regulation), the ban for rinse-off products within the meaning of the Cosmetics Regulation applies from October 17, 2027. For shampoos with a longer life cycle, it is recommended to examine polymers for this issue as early as the raw material selection stage, instead of modifying the formulation later.
Which tests does a shampoo need before launch?
Prior to being placed on the market, every shampoo requires a safety report (Art. 10(1)), a product information file (Art. 11), and notification via the CPNP (Art. 13) in accordance with Regulation (EC) No 1223/2009. These obligations lie with the responsible person (Art. 4), which in contract manufacturing is usually the brand. The data for this is generated across three testing blocks:
Stability: The Cosmetics Europe stability testing guidelines cite storage at 37, 40, or 45 °C for 1, 2, or 3 months as standard conditions, supplemented by thermal cycling and freeze-thaw tests. Testing is carried out in the packaging made from the exact material in which the product is sold—in the smallest size if there are multiple sizes—and in various orientations such as upright, inverted, or horizontal. Typical parameters measured are appearance, odor, pH value, and viscosity.
Preservation: Shampoos consist predominantly of water and are used in humid environments. The preservative efficacy test according to ISO 11930 demonstrates whether the system adequately inhibits microbial contamination.
skin compatibility and Claims: Depending on the claims made, dermatological compatibility tests or user trials are added, such as for “mild,” “for sensitive scalp,” or “anti-dandruff.”
Packaging materials and filling limits
surfactants can stress plastics, fragrances can migrate through container walls, and recycled material does not always behave like virgin material. Anyone switching to recyclate or a new bottle shape should repeat stability testing in the new packaging. Shampoos foam easily during filling. Filling speed, fill level, and, if necessary, deaeration times are therefore determined based on the actual formulation. More details on the scope of testing and time required can be found in the article on stability and safety testing for cosmetics, and regarding recyclate and mono-materials in the article on sustainable cosmetic packaging.
Labtree is a B2B cosmetics developer and cosmetics manufacturer with its own laboratory and production capacities in Germany. Formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production are thus under a single responsibility. Two service models come into consideration for a shampoo:
Criterion | White Label | Private Label |
|---|---|---|
Starting point | Finished, tested Labtree formulation, adapted to the brand | New development according to brand requirements |
Time to delivery capability | Usually 2 to 3 months with standard packaging | Typically 3 to 6 months |
Formulation rights | Remain with Labtree | Can be contractually transferred to the brand |
In both cases, the process follows the steps of conceptualization, sampling, individualization, prototyping, and production. Samples of pre-qualified formulations usually leave the sample warehouse within 24 hours, allowing foam appearance, viscosity, and fragrance to be evaluated early on the physical product. The minimum order quantity is generally 1,500 units per product, depending on filling size and packaging. Whether an adapted white-label shampoo is sufficient or a proprietary formulation makes sense is explored in depth in the articles on White Label Cosmetics and Private Label Hair Care.
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FAQ
Is zinc pyrithione in shampoos still allowed in the EU?
No. Since March 1, 2022, zinc pyrithione has been listed in Annex II of Regulation (EC) No. 1223/2009 and is banned in cosmetic products. Today, anti-dandruff shampoos for the EU market generally rely on climbazole or piroctone olamine, the maximum concentrations of which are regulated in the annexes to the regulation.
Can a shampoo be advertised as sulfate-free?
Generally yes, if the claim is true and meets the common criteria of Regulation (EU) No. 655/2013. "Free from" claims must not disparage permitted ingredients or promise a benefit that the product does not have. The magazine article on cosmetic advertising claims in the EU explores these limits in detail.
Who owns the shampoo formulation?
That depends on the service model. With white label, the adapted standard formulation remains the property of the manufacturer. With private label, the formulation is newly developed, and rights or exclusivity can be contractually transferred to the brand.
What is the minimum order quantity for a custom shampoo?
At Labtree, the minimum order quantity is generally 1,500 units per product. The exact quantity depends on the product type, fill size, and packaging.
What does the EU microplastics restriction change for shampoos?
Under Regulation (EU) 2023/2055, the ban on synthetic polymer microparticles applies to rinse-off products such as shampoos starting October 17, 2027. Individual opacifying agents or film formers made from solid synthetic polymers may be affected. Existing formulations should therefore be checked for their polymers in good time.
Can a liquid shampoo formulation be turned into a solid shampoo?
Usually not directly. Solid shampoos work with powdered surfactants like sodium cocoyl isethionate, require little to no water, and are pressed or cast. The formulation, preservation, stability testing, and packaging therefore need to be developed independently.
What does a new manufacturer need to take over an existing shampoo?
The complete formulation with raw material specifications, the manufacturing instructions, existing test data, and the product information file are required. If raw material suppliers or packaging materials change during the transfer, comparison samples and, as a rule, a new stability test are necessary. The magazine article on changing cosmetics manufacturers describes the process.
