eBotaniq Blog

Articles for eBotaniq.com.au users

Exfoliants for the skin, what are the alternatives?

There are many methods of achieving skin renewal (exfoliation) in order to get back that youthful glow to the skin’s surface. Some skincare products use chemicals, some are physical and some are enzymatic (proteolitic enzymes that consume dead skin) exfoliants.


The simplest exfoliant is physical. The physical method uses abrasives. They can be quite aggressive and may leave some scarring from using these abrasive materials (such as crushed outer nut shells walnut/almond / coconut) to scrub off the dead outer layer. Admittedly this is a relatively cheap and effective way of bringing back a shinier skin but in some cases there are repercussions from using abrasives, namely soreness and redness of the skin (acne skin should never use this method). These may take several days to settle down and heal before the full effects can be seen.


The chemical method is a much more aggressive type of exfoliation. Chemical exfoliants which are used in the cosmetic and skincare field are known as Alpha Hydroxy Acids (AHA) and Beta Hydroxy Acids (BHA). These chemicals are organic acids compared to mineral acids and are used in a relative high concentration direct on the skin. Examples include products such as such as Glycolic acid, Kojic acid, Retinoic acid (vitamin A), Lactic acid,  Malic and Citric acid.

These chemicals act like any acid does; except that they are potentially more destructive than mineral acids (sulphuric, or hydrochloric acids) which can cause severe burns, but can be neutralised before any great damage is done.

The AHAs have a strong liking for the proteins in the skin which contain a high level of amino end groups and are active from those points by dissolving cell bonds and thus cause breakdown of the skin integrity. This breakdown can result in the potential exposure of the melanin sites in the skin. When these melanin sites are exposed; unsightly brown colour stains or blotches can appear on the skin.

When these acids have bonded to the amino groups the “neutralisation” of these products is very difficult even dilution is very difficult. What then happens is that they begin to react indiscriminately with all of the available skin, be it dead or live. Unfortunately the reaction continues until the acid is all “used up”.  So they are deemed unstoppable.  Hence lower concentrations are seen as more favourable in cosmetic applications.

The role of the acid is to “exfoliate” the outer layer of the skin and force the skin to repair itself by producing a fresh layer.  If this process is performed often then eventually there is no more skin regeneration available and hence unable to properly cover the capillaries in the outer layer of skin.

Asian skin is much finer than European type and so are often more significantly affected by these acids (brown stains). The capillary blood vessels help in the maintenance of body temperature. When the body gets hot, blood flows through these fine blood vessels and are able to cool the blood by natural radiation and disperion of heat.

When these capillaries are exposed and skin over this is removed or thinned , then the blood can clearly seen to course through them, giving the appearance that the person is blushing or getting a hot flushes and cannot retreat easily to normal until the person returns to a cool environment and their body temperature cools down.

In 1997, CIR --the cosmetic industry's self-regulatory body for reviewing and addressing safety of cosmetic ingredients--concluded that the AHA's glycolic acid and lactic acid and their related chemical compounds are safe for use in products intended for consumer use when:

  • the AHA concentration is 10 percent or less
  • the final product has a pH of 3.5 or greater (lower numbers indicate greater acidity)
  • the final product is formulated in such a way that it protects the skin from increased sun sensitivity or its package directions tell consumers to use sunscreen products.

There is an alternative to the physical and chemical exfoliants. These alternatives are specialty ingredients called “proteolitic enzymes” and are significantly more selective with what is being broken down.

One still needs to be careful which enzyme to use; as some enzymes can be rather aggressive, such as the pineapple enzymes, which are very acidic in nature.

Whilst enzymes take a little longer to achieve the desired results than the chemical and physical methods there are much less harmful side effects than any of the other methods listed above.

papayineAnother regularly used product is Papain which is a non-irritating stabilised acid-free exfoliant which operates in the pH range of 6 to 7. Papain is a natural enzyme derived from the unripe papaya. The enzyme only digests certain linkages in the skin causing no damage to the underlying living cell layer (Proteolitic enzyme). People with sensitive skin can easily tolerate papain enzyme therapy whereas they may not handle the irritation often associated with AHAs , Retinoids and to a lesser extent BHAs in water based creams and gels. 


We are currenly adding more and more peptides to our actives listings and will be updating more on these products.

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MIT preservative ban by EC

The European Commission (EC) has formally approved a ban on MIT (methylisothiazolinone ) in leave-on cosmetics, as of Feb 2017 in Europe. (mainly creams and lotions) The product MIT has been under scrutiny for the last years; due to increased skin sensitising claims linked to MIT. It was claimed that MIT has a potential to cause allergic reactions (such as skin inflammation and itchiness ) that increased in severity over time as a result of repeated exposure to the skin.

Cosmetics Europe suggested to reduce its usage even in rinse-off formulations such as washes and shampoos (where it was initially allowed at concentrations of up to 100 ppm) even though in this product group the number of cases of allergic contact dermatitis attributed to MIT have ‘dramatically decreased’.

As a result, many cosmetic manufacturers are under increased pressure to remove it entirely from all forms of formulations as a precautionary measure. Many larger players have already reformulated or discontinued the methylisothiazolinone (MIT) which was often used as an alternative to parabens who are now looking at the alternatives that are on the market.
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The "Preservative-Free" Product

Formulators will almost universally agree that cosmetic products must be preserved sufficiently to protect the end customer.  The main reason that products must be preserved is that, that will ensure that the mixture is protected from the contamination, that it will be exposed to during normal usage (whether that contamination is intentional or unintentional). We can't keep products in our fridge just to minimise bacterial growth.biocide

In todays market we find a wide range of users from those who don't know what they are using (and dont even bother to read the instructions) to the other side of the spectrum where the product's ingredient label is read carefully and unknow ingredients  are carefully researched. Today's consumers are experts as to where to find ingredient information on the products they purchase, and are extensively using the internet to validate label information.

We know from experience that there are some ingredients that have their own anti-microbial activity. These are short chain alcohols, antioxidants, glycols, a number of herbal extracts, essential oils and a number of other ingredients. Even Zinc Oxide when used as an inorganic sunscreen will have sufficient anti-microbial properties at high enough concentrations to inhibit microbial growth. In those sircumstances a preservative-free claim can safely be made. Ingredients listed as preservatives must be used and notified as such,  but ingredients not appearing on any official preservative lists but which do have their own inherent anti-microbial activity, can be used to make a preservative-free claim.  Microbiologists would have the experience and background to see that some of the other ingredients in the formula are working in that capacity.  This is certainly on the proviser that the product passes the typical 3 month microbiology challenge test. 

in 2010 a questsion was posed to formulators  "would you be comfortable launching a preservative free product" and the responce was significant.

preservative free

So, with a good percentage  responding that they would not be comfortable launching a preservative-free product, how do we address this issue and convince the consumer that preservatives should and must be used in all cosmetic products?

So we certainly do need to launch clean cosmetic products and make sure they stay clean during their use and shelf life while in the possession of the consumer using whatever ingredients necessary and available to achieve this goal. This should be the objective of every formulator no matter where they are from. It's a fairly simple task - but very safe and effective. And by the looks of that poll, most of the formulators out there are certainly in agreement with this.

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Packaging compatability and compliance

Packaging Compatibility and Compliance

Product development must include stability testing to ensure that a formulation is stable and that there are no adverse interactions between the package and formulation.
There are many interactions that can occur between the primary pack and the formulation. Some common issues that can arise are:

    •  Weight loss due to water evaporation through the pack
    •  Colour leaching from the pack into the product or vica-versa
    •  Panelling, causing the walls of the bottle to partially collapse inward
    •  Absorption of preservative into certain plastics resulting in reduced preservative efficacy.
    •  Stress cracking

Transportation should also be considered. Changing demands for smaller shipper cartons and shelf-ready packaging require thorough transport testing prior to introducing a product to the market. Increasing sales via the internet means that parcels containing a mix of items are being transported direct to consumers.

This places additional demands on the robustness of primary packaging when compared to transport of pallet quantities.

Misleading the consumer is not permitted.

Packaging selection must be appropriate to the size of the product.  Deceptive packaging is packaging which is designed to make a pack appear to hold more content that it actually does. An extreme example would be to have 100mL of product filled into a bottle which has an actual capacity of 500mL.  Caps, thickness of packaging material and gift packs are all covered by this legislation to ensure fair practices. This should be taken into consideration when designing and sourcing. 

This Code of Practice was developed and adopted by all Australian jurisdictions in 1987 and, while not a regulation all parties agreed that:


The requirements of the Code covers features of packaging that are likely to deceive consumers. These are:

    • Free space or ullage. Maximum permitted is 25%
    • Recesses – the aggregate volume of recesses is 10% maximum
    • Cavities – aggregate volume of cavities must not exceed 15%

The code provides full information on definitions, exceptions and methods of calculation and determination of free space, recesses and cavities.

The Australian Packaging Covenant

This is a voluntary scheme between Government and companies with the aim of reducing the environmental impact of consumer packaging. The scheme is not backed by legislation, however companies who choose not to be part of the scheme or fail to comply with the requirements of the Covenant will be regulated by the National Environmental Protection (Used Packaging Materials) Measure (NEPM) in each of the Australian States and Territories within which the company sells its products.

Member companies are required to submit an action plan with the goals of:

    • Design to optimise use of resources
    • Recycling to efficiently collect and recycle packaging and
    • Product stewardship to demonstrate commitment of all parties.

A new action plan for 2010 to 2015 has been issued which details how the Australian Government will incorporate the principles of the covenant in its operations.

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Cosmetic Ingredient Labelling

Cosmetic Ingredient Labelling

Once a decision has been made on how the information will be printed on the container (screen print or label) it is necessary to establish exactly what information must be included on the label. (You will by now have developed your company and brand name and the product inside.)

The marketing story will give the consumer a idea what the product is about and how to use it. For example “Tea Tree was used in Aboriginal times. When scratches and wounds were cleaned in the pools of water in which tea tree grew in, the wounds  healed much quicker rather than just leaving the wounds untreated. Tea Tree is called as such because tea was hard to come by in the early colonial days so settlers improvised by boiling the leaves of the tea tree fronds.

Next write a short description for application and how to use the product. For example “place a small amount on affected areas and spread on the skin followed by gentle tapping into the skin for maximum absorption”. It would be beneficial to associate this product with other products you may have in your range. For example “After cleansing your face with “my brand” face cleanser you should use this “my brand” toner followed by “my brand” moisturiser.

Creating the information to be displayed

Cosmetic Ingredient labelling falls under the Australian Trade Practices Regulations and was introduced in 1991 with the last amendment in 2008. The Australian Competition and Consumer Commission (ACCC) is responsible for this legislation.

Full details of the regulation can be found at: http://www.comlaw.gov.au/Details/F2008C00244

The basic requirement is for all ingredients to be listed on the product label in descending order of concentration. Ingredient names should use International Nomenclature of Cosmetic Ingredient (INCI) system of defining names for Cosmetic Ingredients or their English name. In order to cover all markets in the world it would be safest to give both:- the common name (which is most necessary in the US market) as well as the INCI name (most necessary in the EU market). Trade names may not be used. Ingredients in concentration of 1% or more must be listed in descending order by volume. Followed by ingredients of less than 1% that may be listed in any order.

Alternative naming systems are not permitted although provision of additional information is allowed. For example, naming an ingredient as “coconut derived surfactant” on its own does not comply with the requirements, however listing the ingredient as Sodium Cocoate (coconut derived surfactant) would be acceptable. The purpose of ingredient labelling is to provide public information of all the chemicals included in a product. Inaccurate or non-specific ingredient identification may be considered deceptive and lead to action from the ACCC.

Some examples

  • Cocos nucifera (coconut) oil.
  • In the case of herbal extracts the common and Latin names as well as where it is extracted from e.g. Chamomila Matricaria (Chamomile) flower extract

A contact address and/or a website must be included along with the name of your business. Writing PO Box as the contact is not acceptable and can lead to difficulties with the authorities especially when the public wish to make inquiries or complaints.  Imported products must also carry an Australian street address. This may be achieved either through repackaging or over-labelling with the local distributor’s detail

The front of the label should clearly show “Your Brand”, what it is (e.g. Super Hydrating Face Moisturiser) and all products must indicate the quantity, volume, mass or number, contained within the pack.

A National standard for quantity marking was implemented in July 2010 in Australia, where one can choose to comply with either the AQS standards or the UTML standards. See this Guide to Average Quantity System for full details

Different categories of products are measured and labelled in different ways. Solid products, semi-solids and powders are measured by ‘mass’ (weight).  Whereas liquids are measured by ‘volume’.  Products measured by mass are labelled using kilograms (kg), grams (g) or milligrams (mg). Grams are suitable when the nett weight is less than one kilogram and milligrams are suitable when weight is less than one gram. Products measured by volume are labelled in litres (L) or millilitres (mL). Millilitres are used when the product is less than one litre. In both cases, these measurements are exclusive of the packaging.  It is often beneficial to write several options as not all products have the same properties. For example use a weight such 50 g/mL, and/or 4.5 fl oz (when distributing to the American market).

In order for a product to be labelled “Product of Australia”, it must include 100% Australian content. This means that every ingredient must be from Australia. Whereas, the label claim of “Made in Australia” can be utilised when the product has undergone significant alteration and the majority of the manufacturing costs have occurred in Australia. Of the two, the latter is more achievable as many ingredients are often sourced internationally.

Labelling Claims

Next is what you can “claim” your product does. Product labels and the claims made for products must be carefully considered to ensure consumers are not deceived or mislead. Be careful not to make therapeutic claims such as healing, antiseptic, scar removing, disinfectant, etc as this may incur the wrath of authorities such as the Therapeutic Goods Administration (TGA) or other Administrations.  Claims made for a product can also result in a product being therapeutic rather than cosmetic, irrespective of the ingredients. If a product was to claim that it “smooths the appearance of wrinkles” this would be cosmetic but if the claim was "eliminates wrinkles" then this would not be an allowed cosmetic claim. Cosmetic claims should be carefully considered to ensure that therapeutic claims are not being made. Any claims must be supported by verifiable test protocols. Guidance on acceptable claims can be found on the TGA website. The authorities may either force you to withdraw the product or prove that the product was made in a proper authorised facility. They may even force you to have to do double blind tests to prove the validity of your claims. This can be extremely costly.

Packaging and Labelling of Cosmetics in Australia can be a complex task to ensure that all Regulatory, Compatibility and Environmental requirements are met. Marketers must be aware of all these requirements and where you don't have that expertise in-house then external expertise should be sought. Your contract manufacturer can usually help you to word your descriptions so that you will not cross that fine line into the therapeutic world.



FAIS Handbook
FAIS Handbook

Guide to Labelling Drugs and Poisons

Australian Competition and Consumer Commission, Cosmetics and Toiletries – Ingredient Labelling (December 2000)

Australian Competition and Consumer Commission, Green Marketing and the Trade Practices Act (February 2008)

Therapeutic Goods Administration, Cosmetic Claims Guidelines

Comm law for latest Australian Government Regulations

Australian Made

Cosmetic Ingredient Labelling

CosIng Website (Searchable EU cosmetic INCI names)
updated Oct 2016

Product Safety Australia


Who and What is NICNAS

NICNAS soap and cosmetics information


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Selling Your Own Home Made Cosmetic

b2ap3_thumbnail_your-cosmetic-range1.jpgSelling Your Own Cosmetics

Distributing and selling cosmetics that you have made on your own can be very rewarding fun and creative.  
Often when you venture into this cosmetic area it does not stop at just making the product from scratch for your own use.  So when you have taken some classes and are confident and satisfied with the product you may want to offer the products to family and friends as gifts; and then offer these to the wider public. 

Many people have the idea of starting their own skin care range, but would like some guidelines on what is necessary for them to research before they invest in launching their own cosmetic skincare range. This article aims to answer some of the many questions that are often asked by many small cosmetic entrepreneurs.  In starting up  a small business in Australia we face many real challenges and there are a lot of things to think about. Below we have summarised some of the points we believe you’ll have to consider when you plan to create your own cosmetic business.

Remember that you dont have to do everything yourself. You can get help and guidance from professionals and consultants who can assist you in many varied areas; from creating formulae, help with contact manufacturing and filling, right to the marketing and distribution aspect of the business.  There are graphic designers who can assist you with packaging design, and specialists that can assist you with regulatory questions (e.g. export compliant labelling). However, such services often come with a price attached.      

FIRST and FOREMOST  Do Your Research And Define Your Marketplace

We can’t stress enough that you will need to do your research.  Research where and how you are going to sell the product so that the buyer can get your product range.  There are many channels available from craft markets and eBay to specialist retail shops:- which one is right for you?
You should have a very clear understanding about which segment of the market you'd like to focus on. As the cosmetic market is lead by large, international companies selling mass products in all market segments you will most likely find success if you focus on just one type or group of customers to stay competitive.
Within this specific group, you can easily outdo the larger competitors by offering better products and better service. And remember: whilst the marketplace does not need more cosmetics, the consumers in the marketplace have an insatiable appetite for exciting, different, fresh NEW product concepts.

By the end of your research you should have a very clear understanding into what market niche your product will fit  (e.g. "I want to sell natural, non-synthetic moisturising soap at an affordable price for outdoor working people with rough and dry hands.")

  • Define Your Market Niche: Focus on a specific group of customers (e.g. garden loving, middle-aged men). Remember that one can always expand your business to new segments but it's a lot easier to start with just one group of customers in mind.
  • Know Your Customer: Do your research and get to know your customer's habits, wishes, willingness to spend money, locations where they prefer to shop, colours and odours they might like best, etc.

Creating and Testing Formulas

There are a number of sources for formulations upon which you can base your product(s).  There are a number of guide formulas posted on our website for various products which you are welcome to use and modify; or you can access other online formulation databases.  At times formulators copy formulations based upon the ingredient lists of commercial products. 
Sometimes it may be necessary that the formula you have obtained from other sources needs to be modified to suit your specific needs. 
Creating your own formula is very satisfying even though it often requires a lot of experimentation, modification, and tweaking of various ingredient concentrations, and replacing ingredients with new ingredients. However, once your formula is finished you know you have created something truly unique.

  • Create or Choose the Right Formulas: Before starting to formulate, make sure you consider the right form of the product (e.g. is a lotion or cream better for the container I have in mind?), and the kind of ingredients that fit your target customer (e.g. high-performance or more natural ingredients?)
  • Test Your Formulas: Don't just test your formula on your own or your friend's skin expand your testing to larger groups. We strongly suggest that you also do your own stability tests! Stability testing is your best guarantee that the product will perform now and in the future; it will prevent you from marketing a product that is unstable over time, and thus ruining your company and reputation. Check out our stability testing article in a later blog.

Manufacturing Your Products

First off, always attempt for the best quality whether you plan to manufacture your products from scratch or modify prefabricated bases purchased from us or somebody else. Pay strict attention to stringent hygiene, a clean working space, and proper use and storage of ingredients.
Once your business moves past the kitchen bench-based production facility to a more professional set-up (maybe even with your own laboratory)  you should follow the Cosmetic Good Manufacturing Practice Guidelines as required by the cosmetic industry.

  • Manufacture at consistent quality: Set up quality rules and follow them strictly: buy only ingredients from trusted sources, use only distilled water (not tap water), store ingredients adequately, use only clean and disinfected tools and containers, wear disposable gloves and a face mask, keep a log book to record all your batch productions, reserve samples of every batch.
  • Consider a contract manufacturer: If you can not or do not want to manufacture your products on your own consider consulting a contract manufacturer. This is especially the case if your business has grown to a size where you have to manufacture large quantities (drum sizes) as large scale production has its own challenges! We have access to, contract manufacturers that are able to make small quantities where most producers are only interested in quantities of 5000+.

Packaging, and Labelling

Packaging is your silent salesperson. Purchasing cosmetics is often an emotive purchase and choosing appropriate packaging is critical within the marketing plan; whether it responds to market needs or whether it creates new opportunities and new markets.
Research showed that over 50% of consumers bought a certain brand only because they initially were attracted to the packaging.
Our recommendation is: find your best compromise between a high-end luxury packaging and unprofessionally looking home-made packaging.
Don’t spend all efforts on a custom-designed container with silk-screen printed labelling, packed in a 4-colour printed carton box, and over-wrapped in cellophane. (Unless you are in a very exclusive market segment where you can recoup the exorbitant cost.)  Remind yourself that cosmetic packaging needs to be functional, practical, and made of a good quality (no leaking, no strange odours, and certainly no breakages during transport).

  • Finding Containers: Before buying a container in bulk quantities (typically in the thousands) buy first a few single containers of various sizes, designs and materials and decide only then which containers fits your needs best. Ideally to minimise cost you should try to purchase the packaging in carton lots which may be from 100 to 500 units although this will vary depending on the packaging size.
    Before choosing packaging it is necessary to understand what your skincare creams, lotions and liquids are made of as this will impact on what material can be used. Often your contract manufacturer and/or formulator, can help you to choose the appropriate materials for jars and bottles and so you can avoid having to invest in the cost of researching compatibility tests on the packaging.
  • Design Your  Label: If you are familiar using drawing or photo editing programs and have a flair for good design, go ahead and design your own label. Unfortunately MS Word and MS Publisher documents are not used by industry and whilst they are acceptable to convey a idea they are not capable to convert it into a printers graphics file except a great added cost.  If you are not trained we really suggest that you get help from a professional graphic designer to prepare your artwork so it looks professional.
  • Confirm Labelling Regulations: cosmetic products have very strict labelling regulations which you have to follow. If your label doesn't meet all the requirements you can be fined and/or your products must be withdrawn from the market. Read more in our article about labelling requirements in the Australian market and its regulations
  • Select Type of Label: Cosmetic containers are typically labelled in two ways, either by having the text printed directly onto the container  (silk screen printing) or by using a printed label, stuck to the container.
    The advantage of silk screen printing is that it looks very professional and you don't have to stick labels to the containers. However, there is usually a minimum quantity (1000's of containers)  and another potential issue is once printed you can't change the text any-more. Silk screen printing is offered by most container manufacturers or by specialised printing companies.
      There are many label printing companies who offer custom label printing at reasonable cost and with low minimum quantities which you can find on the internet and White Pages.  If you want to print your own labels we recommend using a high-quality colour laser printer (don’t use bubble jet printers as the colours will run if the label gets wet and colours will fade on sun-exposure).



 Register with Authorities:

Besides registering your business with local government; In Australia if you manufacture for commercial purposes cold processed or hot processed soap then you must register your business with NICNAS and pay a nominal annual fee. If you import raw ingredients for use in cosmetic manufacturing and formulation, again for commercial purposes, then you must also register your business with NICNAS and pay the annual registration fee. There could be some instances where you may be exempt from this. However, it is best that you research and read all the information provided by NICNAS .

You don't usually have to register your business or your cosmetic products with the Therapeutic Goods Administration (TGA).

However, if you plan to sell specific cosmetics that contain APIs (active pharmaceutical ingredients) defined by the TGA or produce products that make pharmaceutical claims such as sunscreens, disinfectant, acne preparation, and certain skin lightening preparations; head lice prevention actives and others, then you do need to register your business and your products with the TGA.   See the TGA website for specific information to get more details. (for example sunscreens)

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