Pura

Guide

What "natural", "clean" and "chemical-free" legally mean

Some words on a package are regulated. Most of the reassuring ones are not.

Part of Sensitive skin

The front of a package is an advertisement. The back is a document. Almost everything that follows comes from taking that distinction seriously.

The words that mean nothing

“Clean.” Not defined by any regulator. It means whatever the brand using it has decided, and different brands using it on the same shelf mean different things.

“Chemical-free.” Not merely undefined but impossible. Water is a chemical. Everything in the product is a chemical. The claim tells you the marketing department has a view about chemistry that the formulation department does not share.

“Non-toxic.” Undefined in this context, and meaningless without a dose. See hazard versus exposure, because this word is where that confusion usually enters.

“Natural”, on the front of a cosmetic. Essentially unregulated. Arsenic is natural. Petrolatum is refined from something that was once alive. The word divides ingredients by where they came from, which is not the same as dividing them by whether they suit you.

“No nasties”, “free from”, “pure”, “gentle”. Rhetoric. A product can say “no nasties” on the front and contain exactly the same preservative as the one beside it, because “nasty” is not a category anyone defines.

The words that do mean something

“Natural flavors”, in US food labelling. A defined term under 21 CFR 101.22. It describes origin: the flavouring came from a plant or animal source rather than being synthesised. It says nothing about processing, complexity or health, and there is a whole page on how much it does not say.

“Parfum” or “Fragrance”, on a cosmetic. A permitted collective term, which is why one word can stand in for dozens of components. In the EU, specific fragrance allergens must be named separately once they pass set thresholds, and that list was significantly expanded in 2023, which is why fragranced products have been growing longer ingredient lists.

The ingredient list itself. Ordered by weight, descending. In cosmetics, ingredients at or below one percent may appear in any order after that point, which is set out in the EU Cosmetic Products Regulation. That ordering rule is worth more than every front-of-pack claim combined.

Allergen declarations. The one part of a label with real teeth. Major allergens must be declared plainly and cannot hide behind a technical name.

“Organic”, where certified. Backed by an actual certification scheme with an auditable standard, which makes it one of the few reassuring words on the front that has something behind it. It certifies farming practice, not that the product suits your skin.

The quickest way to check

Turn the package over and compare the promise to the list.

A shampoo advertising itself on argan oil, with argan oil second from last, contains a rumour of argan oil. A “sugar-free” biscuit whose second ingredient is a syrup has moved the sugar rather than removed it. A “fragrance-free” moisturiser listing a masking fragrance has told you something interesting about the word “free”.

None of this requires chemistry. It requires reading two things and noticing when they disagree, which is most of what reading a label amounts to.

Why we do not use these words either

You will not find “clean” or “non-toxic” anywhere in Pura’s own writing, and that is deliberate. Once you decide that a page should say what the evidence supports, the reassuring vocabulary stops being available, because none of it survives the question “compared to what, at what dose.”

What replaces it is longer and less quotable. That is the trade, and we would rather make it than sell you a word that means nothing.

Sources

  1. 21 CFR 101.22: Foods; labeling of spices, flavorings, colorings and chemical preservatives US Food and Drug Administration, via eCFR · ecfr.gov
  2. 21 CFR 101.4: Food; designation of ingredients US Food and Drug Administration, via eCFR · ecfr.gov
  3. Regulation (EC) No 1223/2009 on cosmetic products EUR-Lex · eur-lex.europa.eu