Only One of Our 54 Products Says 'Preservative-Free'. The Other 53 Use Something That Isn't Called a Preservative.

We read the free-of chips on all 54 products in our catalogue looking for one phrase. "Preservative-free" appears exactly once, on the gyeol haus Skin Barrier Jojoba Oil, and there it is true: eleven ingredients, not one of them a preservative.

The other 53 make no such claim, which is just as well. Because 42 of the 54 contain 1,2-hexanediol, and our own data calls that a preservative in 37 of them. Parabens across the catalogue: zero. Phenoxyethanol: two products. Something is keeping micro-organisms out of the rest, declared under a different job title.

None of this is a loophole nobody noticed. The European Commission described the exact situation in a document dated 3 July 2017 and said the claim should not be used. The same document lands on us, too.

Annex V is a permission list, not a chemistry list

Regulation (EC) No 1223/2009 defines the word at Article 2(1)(l): "'preservatives' means substances which are exclusively or mainly intended to inhibit the development of micro-organisms in the cosmetic product." Intended. The category turns on declared purpose, set by whoever puts the product on the market.

Annex V carries the heading "LIST OF PRESERVATIVES ALLOWED IN COSMETIC PRODUCTS". Read that twice, because getting it backwards makes every sentence after it wrong. It lists what you are permitted to use when you are using it as a preservative. It is not a register of every substance in cosmetics that inhibits micro-organisms, and absence from it tells you nothing about whether a molecule kills bacteria.

The proof sits in the consolidated text, in salicylic acid. Annex V entry 3 caps it at 0.5% when used as a preservative. Annex III entry 98 permits up to 3.0% in rinse-off hair products and 2.0% elsewhere for "purposes other than inhibiting the development of micro-organisms in the product", with a condition: "This purpose has to be apparent from the presentation of the product." One molecule, two ceilings, six times apart. The only thing separating them is what you say it is for.

We counted salicylic acid across ten of our products earlier this month and never once asked which annex each of those ten was sitting under.

What is actually holding the line in 53 products

1,2-Hexanediol is in 42 of our 54 products, 77.8% of the catalogue. Ethylhexylglycerin is in 29, caprylyl glycol in 19. Phenoxyethanol, the one people argue about in the comments, is in two: the hatherine Pore Melting Shrinko Nose Pack and The Medi Dr.Day Blue UV Sun Mist SPF50.

The four unregulated entries appear 90 times between them. The four Annex V entries appear 12 times.

And the published work on the top entry is not ambiguous. Yogiara and colleagues, in Letters in Applied Microbiology in 2015, reported that 1,2-hexanediol shows broad-spectrum activity against Gram-positive and Gram-negative bacteria, with minimum inhibitory concentrations of 0.5 to 2% (v/v), that it is bactericidal at one to two times MIC, and that it depolarises the cytoplasmic membrane. Depolarising a membrane is not humectant behaviour.

A larger test came in 2022. Youenou and colleagues put four multifunctional ingredients (phenylpropanol, hexanediol, ethylhexylglycerin and hydroxyacetophenone) against 42 strains in the Journal of Applied Microbiology. Growth of Acinetobacter, the Burkholderia cepacia complex and Stenotrophomonas maltophilia was totally inhibited by all four. Their conclusion: "most multifunctional ingredients showed significant antimicrobial properties".

Ethylhexylglycerin has a file of its own. Aerts, Verhulst and Goossens, in Contact Dermatitis in 2016, described it as used for its "surfactant, emollient, skin-conditioning and antimicrobial properties" and reported 13 cases of allergic contact dermatitis. What matters is where those 13 came from: a high number of the implicated products were marketed as "hypo-allergenic" and "preservative-free". Thirteen people is a small series and we will not inflate it. It is still the tidiest illustration of what the phrase buys a shopper.

Seven of our 54 products carry no preservative-type ingredient at all: gyeol haus Skin Barrier Jojoba Oil, reve am Enzyme Cleansing Powder, FATION Nosca9 Spot Patch, Pure Somme Pure Organic Jojoba Oil, cloropy Jaungo Herbal Bubble Bath Fizz, foellie Eau de Bijou, and JHP Cosmetics Argan Oil Hair Essence. Two oils, a powder, a patch, a bath fizz, a perfume, a hair essence. Nearly all anhydrous, and water is what a contaminating organism needs.

An eighth is borderline. The papasoap Deep Clean Blemish Care Bar has Citrus Grandis Seed Extract at position 18, and our data gives that entry the function "Preservative", a call we would not defend hard.

Our own data cannot decide what 1,2-hexanediol is for

Of the 42 products containing it, our data labels the function "Preservative" in 37 and a humectant in five. Same molecule, same field, five exceptions with no visible principle behind them.

It gets worse when you open the five. Two use a lowercase spelling: EPLE&ME Hydra Cell Boosting Toner at position 4 and lesschemi Galactomyces Derma Lotion at position 6, both reading "humectant". Three use a capital: birthtii Glow Hand & Body Wash Cake at 25, birthtii Layered Hand & Body Lotion Cake at 27, and anean Argan Oil Curling Up Hair Lotion at 5, all "Humectant". Nobody decided hexanediol behaves differently in a hand wash cake. This is two people typing on two different days, in our field, under our name. We have owned up to this class of error before and it is still here.

Caprylyl glycol is more consistent and, we think, more wrong. Our data calls it "Humectant" in all 19 products that contain it. Never once a preservative, despite it being a standard partner in phenoxyethanol-free systems. Consistency is not accuracy.

Then there is the gap we cannot close by tidying a spreadsheet.

We hold ingredient lists in declared order. We do not hold percentages, because manufacturers do not publish them and INCI order only constrains entries above 1%. The MIC for 1,2-hexanediol in the 2015 work starts at 0.5%. A formula using it at 0.2% for slip and one using it at 1.5% to stay sterile look identical on a carton, same position, same spelling. So we cannot tell you which of our 42 products genuinely depend on it, and neither can anyone else working from a label. That is a hard limit on this article and we would rather say it than write around it.

The Commission already wrote this down, in 2017

The Sub-Working Group on Claims published its technical document on cosmetic claims on 3 July 2017. On free-from wording it is direct: "The claim 'free from preservatives' should not be used when a product contains (an) ingredient(s) showing a protective effect against microorganisms, which are not included in Annex V of Regulation 1223/2009, e.g. alcohol."

That is the situation we have been describing, named in public, in 2017.

One caveat, stated clearly: this is a sub-working group document, agreed best practice for national authorities, not the Regulation. Nobody is fined for breaching it directly. Enforcement bodies cite it, but calling the claim "banned" would overstate things.

The same document then walks into our own shop. It says "the claim 'free from parabens' should not be accepted, because it is denigrating the entire group of parabens." We have 46 of 54 products carrying a Paraben-free chip against a catalogue paraben count of zero. Every one is factually accurate and, on the Commission's reading, still not acceptable, because it earns its force by implying something bad about a group of lawful, assessed ingredients. We put those chips there. Nobody made us. Same failure mode we picked apart in which label claims actually mean something, now pointed at us.

There is a legitimate way out, and it needs saying, or this reads as an accusation against every brand using hexanediol. The guidance allows an exception where the responsible person holds evidence that the ingredient does not contribute to protection, such as a challenge test run on the formula without it. A brand dosing hexanediol at 0.2% for texture, with a passing test on a version that leaves it out, can say preservative-free and mean it.

That test is usually ISO 11930. Published method summaries describe it as inoculating the product with Staphylococcus aureus, Escherichia coli, Pseudomonas aeruginosa, Candida albicans and Aspergillus brasiliensis, then counting survivors at days 7, 14 and 28, with Criterion A requiring at least a 3-log bacterial reduction by day 7. We are reading a testing laboratory's summary, not the standard, which is paywalled, so treat the detail as indicative.

Which is why our two phenoxyethanol products deserve a word in their defence. Phenoxyethanol is in Annex V, and the SCCS opinion of 6 October 2016 states that it "considers 2-phenoxyethanol safe for use as a preservative with a maximum concentration of 1.0%." Those two took the reputational hit of naming a preservative instead of hiding one behind a second job title.

What our screening found

The practical takeaway

Treat "preservative-free" on any water-containing product as a warning, not a feature. Either the formula is genuinely unprotected, which is worse for you than a well-chosen preservative at 1.0%, or the protection is being done by an ingredient filed under another function and the phrase is doing work it has not earned.

Scan the list for 1,2-hexanediol, caprylyl glycol and ethylhexylglycerin. Finding them does not mean a product is badly made. Our catalogue is full of them, and the 2016 series was 13 cases against enormous exposure. It means the word on the front is not describing the back.

Anhydrous products are the exception that works, and Pure Somme's single ingredient is the clean version of it.

Our own homework is two items long. Fix the hexanediol function field so 42 products agree with each other, and decide whether 46 Paraben-free chips survive a rule we have now quoted in public. Our screening criteria say we grade what is on the list, not what is on the box, which makes the second one hard to argue our way out of.