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Shampoo and conditioner OEM for the Philippines: what matters in a sulfate-free formula and on the label?
For shampoo and conditioner OEM in the Philippines, compliance requires Pre-market Cosmetic Product Notification under Republic Act No. 9711 and the ASEAN Cosmetic Directive (ACD), filed by a Philippine entity holding an FDA License to Operate (LTO). Labels must be in English or Filipino per ACD Appendix I. A sulfate-free formula using amino-acid or APG surfactants is not inherently low-irritation; APG systems also carry alkaline pH and characteristic odor that must be managed in formulation.
1Label and Notification Requirements (ACD & RA 9711)
Labels must state product name, function, full INCI ingredient list, country of manufacture, LTO holder name/address, net quantity, batch, and manufacture/expiry dates. Claims must follow ACD guidelines. Pre-market notification is filed via the FDA eServices portal with PIF upload, valid for 1–3 years and renewable. Reference the latest official text.
2Sulfate-Free Surfactant Selection and System Control
When amino-acid or APG surfactants are primary, pH must sit in the mildly acidic to neutral range. APG has an alkaline tendency and a characteristic odor, requiring simultaneous pH and fragrance management. Rich foam must be supported with amphoteric or nonionic co-surfactants; simply increasing total active concentration raises irritation and cost without solving the foam problem.
3Soap-Free Claims and Rinse-Off Preservative Challenge
“Sulfate-free” often implies “soap-free,” but soaps and amino-acid systems are distinct routes; a soap-free creamy texture with a slight dry-tight feel requires fatty-ester co-surfactants and higher process difficulty. Rinse-off products carry high microbial risk; even on a “preservative-free” route (polyol/organic-acid substitution), the preservative challenge test per ISO 11930 / USP <51> is mandatory.
Follow-up questions
- Q:Will a sulfate-free shampoo always foam less than SLES?
- A:Not necessarily. Amino-acid or APG systems alone foam less than SLES, but adding amphoteric or nonionic co-surfactants can bring foam close to traditional levels without sacrificing mildness.
- Q:Must the Philippine label be in English only, or can it be bilingual?
- A:The ACD requires labels in English or Filipino (Tagalog); bilingual is permitted, but all mandatory fields must appear completely. Refer to the latest official text.
Figures sourced from:各国法规 · 菲律宾菲律宾洗护发代工东盟化妆品指令附录配方库
Updated 2026-09-18
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