Formulation and Regulatory Considerations of Waterless Cleansers

Powder cleansers have become an increasingly popular format within the waterless cosmetics movement. Unlike traditional liquid cleansers, they are supplied as dry powders that are mixed with water immediately before use to create a foam, paste, or creamy cleanser.

Their growing popularity is driven by several factors, including reduced packaging, improved product stability, lower transport weight, and consumer demand for more sustainable cosmetic products. Although their presentation differs from conventional cleansers, powder formulations are regulated under the same European cosmetic legislation and must meet the same safety and compliance requirements.

How Powder Cleansers Work

The primary function of a powder cleanser is identical to that of any facial cleanser: removing dirt, excess sebum, sunscreen, make-up residues, and environmental impurities from the skin.

The main difference lies in the formulation. Since the product contains little or no water during storage, manufacturers must carefully select ingredients that remain stable in dry form but become effective once activated with water.

Many formulations combine mild powdered surfactants with additional ingredients such as mineral powders, starches, enzymes for gentle exfoliation, or soothing and conditioning agents.

Packaging Is Part of the Formulation Strategy

Packaging has a particularly important role in maintaining the quality of powder cleansers. Moisture exposure can cause clumping, reduce performance, and increase the risk of contamination.

For this reason, manufacturers generally use airtight containers or dispensing systems that minimise contact with humidity while allowing consumers to dispense the correct amount of product. Packaging should also support hygienic use throughout the product’s lifetime.

Regulatory Requirements in the European Union

Powder cleansers are regulated under Regulation (EC) No. 1223/2009. European legislation does not distinguish cosmetic products according to their physical form, meaning that powders, liquids, creams, and solid cosmetics are all subject to the same legal obligations.

Before being placed on the EU market, a powder cleanser must undergo a cosmetic safety assessment, have a complete Product Information File (PIF), be notified through the Cosmetic Products Notification Portal (CPNP), and comply with all applicable labelling requirements.

While the regulatory framework remains unchanged, the product format may influence the safety assessment. For example, the safety assessor should evaluate potential exposure to airborne powder during dispensing, as well as how the product behaves once mixed with water.

Supporting Cosmetic Claims

Powder cleansers are often marketed with claims that extend beyond basic cleansing, such as gentle exfoliation, soothing properties, hydration, or suitability for sensitive skin.

Under Regulation (EU) No. 655/2013, every cosmetic claim must be truthful, supported by appropriate evidence, and presented in a way that does not mislead consumers.

Manufacturers should pay particular attention to claims such as waterless, natural, preservative-free, eco-friendly, or sustainable. These statements should accurately reflect the product’s characteristics and be supported by suitable documentation or testing where necessary.

Labelling Considerations

As with any cosmetic product, powder cleansers must comply with the mandatory labelling requirements set out in Article 19 of Regulation (EC) No. 1223/2009.

Because consumers must activate the product before use, labels should include clear instructions explaining how much powder and water to use, together with any relevant storage recommendations or precautions needed to maintain product quality after opening.

Providing clear instructions helps ensure both regulatory compliance and safe consumer use.

Innovation Does Not Change Compliance Obligations

Powder cleansers demonstrate how cosmetic innovation can change the way a product is formulated and used without altering the regulatory obligations that apply to it.

Although their waterless format offers advantages in stability, packaging, and transport, manufacturers must still ensure full compliance with European cosmetic legislation. Careful formulation, appropriate packaging, robust safety assessments, accurate labelling, and properly substantiated claims remain essential before these products can be placed on the market.