In the modern cosmetics landscape, the term “preservative-free” is one of the most debated and misunderstood claims on the market. To get to the heart of what this actually means to the experts behind the beaker, we recently conducted two LinkedIn polls targeting cosmetic formulators and industry professionals.
The results highlight a significant shift in how products are being protected and why the industry is moving away from traditional regulatory lists
What Does “Preservative-Free” Actually Mean for the industry?
When formulators see a “preservative-free” claim, they don’t necessarily think the product is unpreserved; rather, they interpret it through the lens of regulatory loopholes and innovative chemistry.
- No Annex V Preservatives (49%): Nearly half of the respondents interpret “preservative-free” as the absence of ingredients specifically listed in Annex V (the approved list of preservatives in the EU).
- Extreme pH or Waterless (21%): Many professionals associate the claim with formulas that are inherently hostile to microbial growth, such as anhydrous products or those with very high/low pH levels.
- Does Not Pass Challenge Testing (16%): A smaller segment views the claim literally, assuming the product may actually lack a robust defense against contamination.
- Hurdle Technology / No Antimicrobials (14%): Some see it as a holistic approach to preservation that avoids traditional antimicrobial agents entirely.
The Shift Away from Annex V
If “preservative-free” largely means “Free of Annex V ingredients,” the next logical question is why formulators are abandoning the traditional list. The data suggests that performance and consumer perception are driving the bus
| Reason for Moving Outside Annex V | Percentage of Votes |
| Multifunctionals Work | 50% |
| Annex V Entry Costs Too High | 33% |
| Consumer Expectations | 17% |
| Regulatory Uncertainty | 0% |
The clear winner here is the efficacy of multifunctional ingredients. These are raw materials—like certain humectants or antioxidants—that provide primary formulation benefits while also offering secondary antimicrobial protection. Because they aren’t classified as “preservatives” on Annex V, they allow brands to claim “preservative-free” status while still ensuring product safety
Interestingly, regulatory uncertainty was not a factor for any respondents, suggesting that the industry feels confident in the current rules—they just prefer the flexibility of using multifunctional alternatives
Key Takeaway for Brands
For formulators, “preservative-free” is less about the absence of protection and more about the evolution of preservation strategy. As multifunctional ingredients continue to prove their worth, the reliance on traditional Annex V lists is likely to continue its decline
Final Note
The Legal Reality: Why “Preservative-Free” is a High-Risk Claim
While the data shows formulators are successfully moving toward multifunctional ingredients, the legal department might have a different take. The gap between technical interpretation and consumer perception has led to a surge in litigation.
The “Hidden Preservative” Lawsuit In recent years, several high-profile brands have faced class-action lawsuits for labeling products as “preservative-free” while using multifunctional ingredients that possess antimicrobial properties. Plaintiffs argue that if an ingredient—regardless of its primary function—effectively preserves the product, the “free-from” claim is factually false and misleading to the average consumer.
Regulatory Scrutiny In many regions, including the EU and UK, “free-from” claims are under fire. Regulators argue that these claims can denigrate an entire class of safe, approved ingredients (like those on Annex V) and create a false sense of safety for the consumer.
Dr Barbara Olioso, MRSC, is a green chemist with over 25 years’ experience in cosmetic science, specialising in green preservation and sustainable formulation. A member of the Society of Cosmetic Scientists and author of The Green Chemist’s Handbook for Cosmetic Preservation, she created GreenChem Finder to help formulators make informed, data-driven ingredient choices. She regularly contributes to industry events and publications including in-Cosmetics Global, COSSMA and SOFW.