The topic is short and compact
Zero-waste extraction is not a legal term; any claim regarding the process relies on the documentation provided by the raw material supplier.
Supercritical CO2 leaves no solvent residue, but it only extracts polar substances with a co-solvent such as ethanol.
The process changes the active ingredient profile, color, and odor of the extract; a change in process is generally considered a formulation change requiring new testing.
As of September 27, 2026, generic environmental claims without recognized excellent environmental performance, as well as claims made about the entire product that actually only apply to a specific component, are prohibited.
Essential oils and CO2 extracts often contain fragrance allergens that, according to Regulation (EU) 2023/1545, must be labeled at concentrations of 0.001% or higher in leave-on products.
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What does zero-waste extraction mean for cosmetic raw materials?
Zero-waste extraction is not a legal term. Neither the Cosmetics Regulation nor any standard defines it. In practice, suppliers associate it with two things: obtaining an extract without traditional organic solvents such as hexane, and the most complete possible utilization of the raw material, often from side streams of the food industry such as pomace, peels, or seeds.
Technically, the term can be tied to the concept of green extraction, which Chemat, Vian, and Cravotto described in six principles: the use of renewable plant raw materials, alternative solvents—especially water or agro-solvents—lower energy consumption, co-products instead of waste, fewer process steps, and a non-denatured extract free from contaminants. These principles describe an aspiration for the process, not a test result.
For a brand, this leads to a sober classification: extraction takes place at the raw material manufacturer, not in cosmetics production. The brand purchases an extract with specific properties. Any claim regarding the process therefore stands or falls with the documentation provided by that supplier.
Which processes are considered solvent-free?
Common methods differ primarily in which groups of substances they extract. This determines the type of product in which the extract will later work.
Method | Typical result | Consequence for the formulation |
|---|---|---|
Cold pressing | Fatty oils and butters from seeds and kernels | Unsaturated oils oxidize; plan for antioxidants and low-oxygen packaging |
Supercritical CO2 | Lipophilic substances, essential oils, waxes, colorants | Works well in oil and wax phases, such as in sticks or balms; polar substances only with a co-solvent |
Steam distillation | Essential oils and hydrosols | Check and label fragrance allergens |
Aqueous, enzyme-assisted, or subcritical water extraction | Polar substances such as sugars, proteins, phenols | Water-containing raw material; preservation and microbiological quality are crucial |
With supercritical CO2, a distinction is important. In its supercritical state, CO2 acts as a solvent itself, but escapes completely upon depressurization. The review by Herzyk and colleagues on supercritical extraction methods therefore describes such extracts as free from solvent residues, but also highlights the limitation: for polar substances such as phenols, co-solvents like ethanol or water are required. If ethanol is added, the extract is no longer obtained solvent-free in the strict sense. As a further limitation, the study notes the high investment costs for high-pressure systems, which are reflected in the raw material price.
In addition, many aqueous extracts are formulated in glycerin or propanediol to ensure shelf life. These carriers appear in the INCI list and must be considered in any assessment of whether a claim of being solvent-free is valid.
What does the extraction process change about the active ingredient?
Depending on the process, the same plant provides a different raw material. A CO2 extract primarily contains lipophilic components, while an aqueous extract contains polar ones. This shifts the active ingredient profile, color, odor, and solubility, and thus also the phase into which the extract is incorporated. Changing the process for an ongoing product is therefore not a formality, but generally a formulation change requiring new testing.
Batch variation
Natural substances vary depending on origin, harvest, and storage. In the case of side streams, there is the additional factor that the starting material has already undergone a processing step whose conditions are not always controlled by the extract manufacturer. In the formulation, this manifests as color deviation, odor drift, or altered viscosity. A concept becomes robust when the specification defines marker substances with limit values, every batch includes a certificate of analysis, and retain samples from several raw material batches are compared in the laboratory.
Raw material effect and product effect
Supplier studies on the extract do not prove the efficacy of the finished formulation. Under the criterion of truthfulness, Regulation (EU) No. 655/2013 stipulates that claims regarding an ingredient must not give the impression that the final product possesses the same properties. A gentle process can preserve an active ingredient profile, but whether it reaches the formulation depends on the concentration used, the carrier system, and stability.
Which tests does an extract require in the finished formulation?
For the safety report, the same applies to a solvent-free extracted extract as to any other raw material. Annex I Part A of Regulation (EC) No 1223/2009 requires, among other things, information on composition, physical/chemical characteristics and stability under reasonably foreseeable storage conditions, microbiological quality, as well as impurities, traces, and information about the purity of the substances. If traces of prohibited substances are present, evidence must be provided that they are technically unavoidable; Article 17 only permits such traces if they are technically unavoidable and the product remains safe within the meaning of Article 3.
Purity in side streams: Depending on the starting material, it is advisable to request data on pesticide residues and heavy metals from the supplier before the safety assessment begins.
Stability in final packaging: Phenol-rich extracts can darken, and cold-pressed oils can become rancid. Accelerated storage at elevated temperatures should be conducted in the final packaging material, because oxygen and light permeability help determine the outcome.
Preservation: Aqueous extracts introduce nutrients for microorganisms. The efficacy of the preservation system is typically evaluated via the preservation challenge test according to ISO 11930, especially if the concept aims to avoid certain preservatives.
Fragrance allergens from plant extracts
Essential oils from distillation or CO2 extraction often contain fragrance allergens subject to labeling requirements. Regulation (EU) 2023/1545 significantly expanded the list in Annex III, including entries such as Lavandula angustifolia oil/extract, Mentha piperita oil, or Citrus limon oil. They must be indicated on the label if their concentration exceeds 0.001% in leave-on products or 0.01% in rinse-off products. Following the transition periods, products that do not comply with this labeling may no longer be newly placed on the market after July 31, 2026, and may only be made available until July 31, 2028. The detailed scope of testing is described in the article on stability and safety testing.
Which advertising claims about the procedure are permitted?
The basis is Article 20(1) of the Cosmetics Regulation: texts, names, and images must not imply characteristics or functions that the product does not have. The common criteria of Regulation (EU) No 655/2013 additionally require sufficient and verifiable evidence. A claim such as “with solvent-free extracted extract” is therefore only sustainable if the supplier's documentation proves the process, including all processing aids. If it was extracted using ethanol as a co-solvent, it would be misleading.
New Limits for Environmental Claims
Since September 27, 2026, the Member States have been applying their national provisions transposing Directive (EU) 2024/825; it had to be transposed by March 27, 2026 (Art. 4). Two prohibitions are particularly relevant for zero-waste concepts:
Generic environmental claims (Annex I point 4a): Terms such as environmentally friendly, green, or ecological are inadmissible without proven recognized excellent environmental performance if their specification is not clearly and prominently stated on the same medium.
Claims about the entire product (Annex I point 4b): An environmental claim concerning the entire product is inadmissible if it only relates to a certain aspect. A “zero-waste serum” in which only one extract originates from a side stream is likely to fall squarely under this.
A specific claim limited to the ingredient is sustainable, such as: “Extract from grape pomace, a by-product of winemaking, obtained through supercritical CO2 extraction”. Whether supplementary statements can be made about the packaging is a separate question; this includes the article on sustainable cosmetics packaging. The criteria for advertising claims overall are covered in the article on cosmetic advertising claims in the EU.
Which documents should you request from the raw material supplier?
The documentation of the process does not originate with the brand, but must come from the supplier and be incorporated into the product information file, which, pursuant to Art. 11(2)(c) of the Cosmetics Regulation, also contains a description of the manufacturing method. Prior to raw material release, the following checklist is recommended:
Specification: INCI designation, plant part, origin, extraction method with all auxiliary substances and co-solvents used.
Certificate of analysis per batch: Marker substances with limit values, microbiological values, appearance, and odor.
Purity data: Information on impurities and traces, for side streams related to the specific starting material.
Allergen list: Contents of fragrance allergens according to the extended Annex III.
Carriers and preservation: What the extract is adjusted and preserved with.
Samples from several batches: so that batch-to-batch variation becomes visible in the laboratory before the formulation is finalized.
Availability: Minimum order quantity and delivery time of the raw material, as seasonal side streams can limit subsequent production.
How a robust origin story can be derived from these documents is described in the article on Source Storytelling.
Labtree is a B2B cosmetics developer and manufacturer from Hamburg with its own laboratory and production facilities in Germany. Formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production are therefore all under one roof. For a solvent-free extract, this means: the laboratory tests at which phase and concentration it can be incorporated, how it interacts with the emulsifier, preservative system, and packaging material, and whether it remains stable during filling—whether in a lip stick, a serum, or a cream.
Samples of pre-qualified formulations usually leave the sample warehouse within 24 hours and serve as a starting point for texture and sensory profile. An adapted white-label formulation with standard packaging is generally ready for delivery in 2 to 3 months. If a product is developed from scratch around a new extract, the private label usually takes 3 to 6 months to reach market readiness; raw material availability and stability data help determine the schedule. The minimum order quantity is typically 1,500 units per product, depending on the product type, fill size, and packaging. The safety report and regulatory documentation are part of the scope of services; conformity or a test result is not guaranteed, but rather the path to achieving it is planned.
The process from conceptualization to production is described on the page Have cosmetics developed.
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FAQ
Is supercritical CO2 extraction really solvent-free?
In its supercritical state, CO2 acts as a solvent itself, but it evaporates completely when depressurized, leaving no residues behind. For polar substances like phenols, ethanol or water is often added as a co-solvent. In that case, marketing should not claim a solvent-free extraction.
Can a brand put "Zero Waste" on its packaging?
As of September 27, 2026, under Directive (EU) 2024/825, generic environmental claims made without proven, recognized excellent environmental performance are prohibited, as are claims about an entire product when they only concern a single aspect. A blanket zero-waste promise is therefore risky. A more viable approach is to make a specific claim that clearly refers to the exact component it applies to.
Are upcycled raw materials from food side streams permitted for cosmetics?
Yes, they are subject to the same requirements as any other raw material. The safety report requires information on purity, impurities, and traces, and traces of prohibited substances are only permitted if they are technically unavoidable. For side streams, the purity data should relate to the specific starting material.
Do allergens from plant extracts need to be listed on the label?
Yes, if the extract contains substances from Annex III and the concentration in the product exceeds 0.001% for leave-on or 0.01% for rinse-off products. Regulation (EU) 2023/1545 expanded the list to also include essential oils such as lavender or peppermint oil. Therefore, these levels should be specified in the supplier's allergen statement.
Is a gently extracted extract automatically more effective?
No. The process determines which substances end up in the extract, but the effect in the product depends on concentration, carrier system, and stability. Supplier data on the raw material does not prove any efficacy of the finished formulation. Read more about this in the magazine article on cosmetic advertising claims in the EU.
Does the extraction method need to be included in the INCI list?
No. Article 19(1)(g) of the Cosmetics Regulation requires a list of ingredients; the extraction method is not mandatory information. However, any intentionally used substance present in the finished product is considered an ingredient, which also includes glycerin or propanediol used as extraction solvents. Mentioning the process is a voluntary marketing claim and requires supporting documentation from the supplier.
