Buyer questions · Purchase decisions
Shampoo and conditioner OEM for the United States: what matters in a sulfate-free formula and on the label?
For US sulfate-free shampoo and conditioner OEM, label compliance hinges on the MoCRA-era rules, which require ingredient declaration in descending INCI order. A true sulfate-free system must avoid SLES/SLS; if any sulfate remains, it must appear on the label. Formulation should target a weakly acidic to neutral-slightly-acid pH window to prevent acid precipitation. Foam, rinse-out feel, and cleansing power vary by surfactant stack, so acceptance method (pump, net, hand) must be fixed early. All numbers: see written quote.
1Labeling: MoCRA ingredient list and sulfate-free claims
US haircare labels follow FD&C Act Ch. VI + MoCRA: English identity, net contents, INCI ingredients in descending order, warnings, responsible person name/address. Any sulfate surfactant (SLES/SLS, etc.) must be declared. A "sulfate-free" claim means the main system excludes sulfates. MoCRA adds a domestic address/phone/email for adverse-event contact. See latest official text.
2Surfactant selection and foam design for sulfate-free systems
Amino-acid surfactants have weaker foaming than sulfates; stacking concentration raises cost and irritation without fixing foam—pair with amphoteric/nonionic co-surfactants, accepting a slightly slicker rinse feel. APG trends alkaline with a characteristic odor; plan pH and fragrance accordingly. Foam acceptance criteria differ by method (hand, net, pump), so confirm usage before setting standards.
3Preservation and stability
Rinse-off water-based products carry higher microbial risk than leave-on; challenge testing is mandatory. A "preservative-free" route usually means polyol/organic-acid alternatives, not zero antimicrobials. Low-temperature crystallization and haze are common amino-acid-system risks—confirm via low-temperature cycling and 40°C/3-month accelerated stability before finalizing. BIOSPHERE runs 36 QC checkpoints; stability per 40°C × 3 months.
Follow-up questions
- Q:Can we claim "0% SLS/SLES"?
- A:Yes, if the main system excludes all sulfate-class surfactants. Any other sulfate derivatives must still be declared; claim must match the actual formula.
- Q:What foam specs does a pump head set?
- A:Pump air ratio and orifice size determine foam structure. Fix packaging before tuning surfactant ratios and acceptance criteria.
Figures sourced from:各国法规 · 美国美国洗护发代工FDA 化妆品禁用与限用成分、色素添加剂配方库
Updated 2026-09-18
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