Private Label Hair Care Products: Formulation, Testing & Compliance Guide for Brands

You’re not selling “shampoo in a bottle”—you’re selling outcomes: smoother curls in humidity, color that lasts, a calmer scalp after a chaotic week. The fastest way to win retail and reviews is to align every decision (actives, pH, packaging, claims) with one job your SKU must do.

To launch private label hair care that truly performs and passes compliance, start with one defined hair or scalp problem, pick evidence-based actives at proven percentages, and engineer sulfate-free systems at cuticle-friendly pH. Build a preservation strategy that passes ISO 11930, verify with stability and packaging compatibility, and label to US/EU rules. Avoid drug-leaning claims. This is the fastest, safest route from brief to shelf, with fewer surprises in production.

Stick around—below is a practical blueprint, you can put straight into your OEM brief.

What hair/scalp concerns are you solving?

Start by translating real consumer pains into measurable problems: frizz in 80% RH, color fade after 10 washes, flaky scalp under stress, breakage on bleached hair. Prioritize one primary claim per SKU. Define success metrics, test method, and use setting; then reverse-engineer formula, packaging, and QA around that single job.

Define the single job

• Anti-frizz in humidity: Resist volume gain and flyaways at 70–85% RH.
• Color-safe: Maintain ΔE color change below agreed threshold after 10–20 wash cycles.
• Scalp comfort: Decrease visible flaking score and itch scale in 2–4 weeks (cosmetic claims only).
• Damage control: Reduce breakage (%) on wet combing vs untreated control.

User context matters

• Hard water vs soft water: Chelators (EDTA, GLDA) can be make-or-break.
• Heat styling habits: Add film formers/thermally activated silicones for 185–210 °C protection.
• Lifestyle: Gym-goers need sweat-resistant styling polymers; swimmers may need anti-chlorine chelation.

pick one “hero metric” per SKU (e.g., “breakage ↓ 40% vs baseline”), then choose actives and tests that prove that metric.

Map the concern to metrics and tests

Which actives and % back each claim?

Choose actives with published support and region-legal status, then set their effective ranges: e.g., niacinamide 2–5% for scalp balance, piroctone olamine 0.5–1% for flakes (where permitted), amodimethicone 0.2–1% for frizz control, caffeine 0.2–0.8% for feel of fullness. Pair with delivery systems, buffers, and compatible bases, and validate with prototypes plus instrumental tests before scaling.

Match actives to the job (with practical ranges)

• Frizz/smooth: Amodimethicone 0.2–1%, bis-amino PEG/PPG-41/3 aminoethyl PG-propyl dimethicone 0.1–0.5%, polyquaternium-10 0.1–0.4%, hydroxypropyl guar hydroxypropyltrimonium chloride 0.1–0.3%.
• Color-safe conditioning: Behentrimonium chloride 0.5–1.5% (rinse-off), cetrimonium chloride 0.3–0.8%, silicones as above; UV filters for hair (region-dependent) or polyphenols for antioxidant support.
• Scalp comfort & flake look: Piroctone olamine 0.5–1% (where permitted), climbazole (rinse-off, where allowed), salicylic acid 0.2–1% (exfoliation), zinc PCA 0.1–0.5%, niacinamide 2–5%, panthenol 0.2–1%.
• Damage repair feel: Hydrolyzed proteins/peptides 0.2–2% (wheat/silk/keratin), ester oils (C13-15 alkane, coco-caprylate) 1–5%, silicone-free gloss esters 0.5–2%.
• Fuller look: Caffeine 0.2–0.8%, polymer lift (VP/VA, PVP) 1–4%, root-lift sprays with polyquaterniums 0.2–0.6%.

Compatibility notes

Silicones can lower foam in shampoos—counterbalance with amphoterics and polymeric thickeners. Acidic pH (4.5–5.5) enhances cationic deposition on hair; avoid over-neutralizing. Some scalp actives require specific pH windows (e.g., salicylic acid works best pH < 4.5–5).

Evidence and ethics

Use a 2-stage proof plan: (1) instrumental lab test on tresses/scalp assessments; (2) 2–4 week consumer test with scaled questions. Avoid implying medical treatment.

“Private label hair care products” actives cheat sheet

How to build sulfate-free systems and ideal pH?

Build cleansing and conditioning systems without sulfates by combining mild anionics (isethionates, sarcosinates) plus amphoterics (betaines) and nonionics (glucosides). Target pH 4.5–5.5 to protect the cuticle and color. Balance foam, slip, and residue using polymers and emollients. Test in hard water and high humidity for real-world performance. Use chelators to control minerals and maintain viscosity.

Shampoo base patterns

• Gentle daily clean: Sodium lauroyl sarcosinate + cocamidopropyl betaine + lauryl glucoside; pH 5.0–5.5.
• Color-care wash: Sodium methyl cocoyl taurate + betaine + APG blend; pH 4.8–5.2; include cationic polymer for combability.
• Clarifying (weekly): Higher anionic %, boosted chelators; still avoid sulfates; pH 5–5.5.

Conditioners & masks (sulfate-free)

• Emulsion core: Cetearyl alcohol + behentrimonium chloride/cetrimonium chloride.
• Slip & gloss: Esters (coco-caprylate), light silicones (or silicone-free esters) to reduce friction.
• Bond-building trend: Add diacids/functionalized polymers (region-dependent) for breakage-reduction feel claims (cosmetic wording).

pH targets by format

• Shampoo: 5.0–5.5 for cuticle alignment and scalp comfort.
• Conditioner/Mask: 4.0–4.8 for shine and detangling.
• Scalp serum: 4.5–5.5 to balance barrier and actives.

Real-world stress tests

Hard water foaming/viscosity, humidity frizz tests, and “oily roots/dry ends” panels. Don’t forget fragrance solubility and clarity (if marketing “clear”).

Sulfate-free base picks & pH

What preservation passes ISO 11930 (PET)?

ISO 11930 challenges your finished formula with defined microorganisms to verify preservation. Start with a broad-spectrum system suited to pH and water activity, then add synergy boosters and packaging barriers. Pass criteria typically require log-reductions at T7/T14 and no rebound by T28. Confirm re-challenge and real-use contamination resistance. Document results within your PIF and change-control.

Build a multi-hurdle system

• Primary: Phenoxyethanol 0.5–0.9% (rinse-off/leave-on), benzyl alcohol + dehydroacetic acid blends, sodium benzoate/potassium sorbate (need pH < 5.5), sorbic acid derivatives.
• Boosters: Ethylhexylglycerin 0.3–0.8%, caprylyl glycol 0.2–0.6%, chelators, low pH.
• Packaging as a hurdle: Airless pumps and disc-tops reduce ingress; shower use favors flip-top/dispensing caps.

Micro strategy by format

• Shampoo/Shower formats: Higher water activity but frequent rinse-off; classic phenoxyethanol + booster is robust.
• Conditioners/Masks: Cationics can inhibit some preservatives—screen early.
• Scalp serums: Often lower water activity (alcohol/glycols). Preserve to leave-on standards.

Preservation planner for private label hair care products

How are stability & compatibility tests designed?

Design stability and compatibility to predict shelf life and packaging fit. Run accelerated (40 °C/75% RH), freeze-thaw, and light exposure for 12–13 weeks, plus micro checks. Track pH, viscosity, color, odor, separation, and weight loss. Test interaction with caps, valves, liners, and labels. Approve only after predefined acceptance criteria. Include shipping simulations for hot and cold lanes.

Core stability suite (cosmetics)

• Accelerated: 40 °C/75% RH, 12–13 weeks (pulls at T0/2/4/8/12).
• Long-term: 25 °C, 12 months (parallel where possible).
• Freeze–thaw: 3–6 cycles, −5 °C to 40 °C.
• Light exposure: Simulate bathroom lighting or UV if relevant to colorants.
• Centrifuge: Early predictor of separation (e.g., 3000 rpm, 30 min).

What to measure

pH (±0.3 tolerance), viscosity (cP range per format), appearance/odor, color (ΔE), phase separation, microbial counts, net content (evaporation), and fragrance integrity.

Packaging compatibility

• Migration/extractables: Check stress cracking on PET/PE, interaction with pumps/valves, and liner swelling.
• Label/ink: Smear, curl, or delamination under humidity; shower use simulations.
• Closure torque & leakage: Drop tests and inverted storage.

Stability & compatibility plan

Which packaging and labeling meet US/EU rules?

Labels are legal documents. In the US, list INCI in descending order, net contents, warnings, responsible name/address, batch code, and PAO or expiration where applicable. In the EU, appoint a Responsible Person, maintain a PIF, follow INCI/CLP/Allergens rules, and use truthful, substantiated claims. Harmonize artwork early. Add recycling symbols and country-of-origin where required.

Packaging that works in bathrooms

• Shampoos/Conditioners: PET or HDPE bottles, disc-top/flip-top or pumps; shower-safe grip; PCR options for sustainability.
• Masks: Wide-mouth PP jars or tubes; liners to prevent weeping; consider scoop hygiene.
• Scalp serums: Airless pumps or noz zles; droppers are fragile/slippery in wet settings; consider UV-safe bottles for color-sensitive actives.

Labeling essentials (US/EU)

• INCI list: Descending order >1%; below 1% in any order; allergens where required.
• Identity & net contents: Front panel; US in fl oz + mL; EU in mL/g.
• Responsible party: US—name/address; EU—Responsible Person address on pack; PIF retained.
• Batch & PAO: Traceability and shelf-life intent.
• Claims: Truthful, fair, and evidence-based; no disease claims.

Artwork workflow

Freeze exact claims language early; lock ingredients and allergens; pre-check pictograms (recyclability, cruelty-free where permitted by truth), barcodes, and regulatory font sizes.

Labeling & documentation checklist (US/EU)

Do “hair growth/dandruff” claims trigger drug status?

Yes—certain claims push you into drug territory. In the US, “treats dandruff” or “regrows hair” typically falls under OTC drug frameworks; in the EU, medical claims are prohibited for cosmetics. Safer cosmetic alternatives: “reduces flaking,” “improves hair density appearance,” or “helps reduce breakage.” Document claim tests and legal review. Map language to each region before artwork lock.

Understand the lines

• US perspective: “Treats dandruff/seborrheic dermatitis” and “regrows hair” are drug claims (OTC monograph/NDAs). Cosmetic claims focus on appearance or feel: reduces visible flakes, soothes the scalp, improves the look of density, reduces breakage.
• EU perspective: Cosmetics cannot claim to treat diseases or modify physiological functions; keep language cosmetic and support with appropriate testing.

Claim-language playbook (safe direction)

• Instead of “treats dandruff,” say “helps reduce the appearance of flakes with routine use.”
• Instead of “hair growth,” say “improves the look of density and thickness” or “reduces breakage so hair looks fuller.”
• Include usage qualifiers (“with consistent use,” “when used as directed”) and instrument/consumer test references.

Evidence gradation

• Level 1: In-house instrumental on tresses/scalp (flake count, breakage %).
• Level 2: 2–4 week panel with dermatologist/clinician grading.
• Level 3: Third-party lab verification (strongest for retail buyers).

Risk management

Create a claims matrix per market before copywriting; run legal review; keep substantiation in the technical file.

Conclusion

In short, winning private label hair care products start with one clear problem to solve, evidence-based actives at effective % ranges, sulfate-free bases tuned to pH 4.0–5.5, robust preservation that passes ISO 11930, and stability/packaging compatibility to protect performance. Align labels and claims to US/EU rules, then validate with lab and user tests. Partner with Zerun Cosmetic to turn a tight brief into compliant, shelf-ready SKUs fast.

Why Zerun Cosmetic?

We’re a manufacturing partner that blends formulation science with regulatory discipline: low MOQs for market tests, fast prototyping (3–7 days typical for existing bases), in-house packaging and label printing, ISO-aligned QA, and region-specific claims guidance. We’ll help you move from idea to shelf with fewer reformulations and fewer surprises.

Ready to build your line? Tell us the one job your first SKU must do—reduce frizz in humidity, keep color vivid, or calm a flaky-looking scalp—and we’ll send base options + active ranges + sample lead-times within 24–48 hours. Contact Zerun Cosmetic for a free brief review and samples.