A contract manufacturer’s view of what actually changes inside a development project when the brief says clean, natural and sustainable — and why the preservative system is where the work lands first.
Written & researched by Fenny Yip, Contributor, ORIZI Group · Technical input by ORIZI Group R&D Team · Fact-checked by Creaton Poh · Published by ORIZI Group · Last reviewed August 2026
Disclosure: This article is published by ORIZI Group and may refer to our own manufacturing experience, services and capabilities. External factual claims are supported by cited sources.
Quick answer: what does a clean and natural brief change first in the lab?
A clean and natural brief changes the preservative system before it changes anything else. Removing or restricting preservatives narrows the margin of microbiological protection, and botanical extracts and plant waters add nutrient load that microorganisms can use, so the formula has to be rebuilt around pH, water activity, packaging and process rather than around a single ingredient swap. That rebuild is why a clean reformulation takes development cycles rather than a substitution, and why it needs a fresh preservative efficacy test on the final formula in its final pack.
Key takeaways
- The preservative system is the first thing a clean brief breaks, and the last thing to be re-validated. Everything in between — texture, colour, odour, stability — is downstream of that decision.
- Naturality is a compositional calculation, not a safety or performance property. ISO 16128 gives a number; it does not certify anything and it says nothing about how the product behaves on skin.
- Natural raw materials vary between harvests in colour, odour and active content. Managing that variation is a specification problem, not a formulation problem, and it is usually solved before the first pilot batch rather than after.
- Packaging is part of preservation. Airless and single-dose formats protect a lightly preserved formula in a way an open jar cannot, and a pack change means the microbiological test is repeated.
- From 27 September 2026 the European Union restricts generic environmental claims that a brand cannot substantiate, which makes the documentation behind a clean brief as important as the formula itself.
Scope of this article
This is a formulation and development view of clean, natural and sustainable briefs in cosmetics and personal care, written from a Malaysian contract manufacturing perspective. It covers rinse-off and leave-on cosmetic formats notified under the ASEAN Cosmetic Directive and regulated in Malaysia by the National Pharmaceutical Regulatory Agency (NPRA). It does not cover food, supplements or medical devices, and it is not a claims or legal guide — the market-side view of what a brand has to prove on the pack is covered separately in the further reading below.
Two definitions are worth fixing before anything else, because most confused conversations start here. Clean beauty is a marketing position with no legal or standardised definition — it means whatever restricted-substance list the brand chooses to publish and apply. ISO 16128 is a calculation method for expressing the natural, natural-origin, organic and organic-origin content of a cosmetic ingredient or product; it is not a certification, and the data behind the calculation comes from supplier declarations rather than from an audit.
Why is preservation the first thing to break?
Because a preservative system is not one ingredient doing one job. It is a balance between the preservative itself, the pH of the formula, how much free water the formula makes available, the nutrient load of everything else in the beaker, and how the pack lets air and fingers in. Remove one input from that balance and the others all have to move.
The chain is fairly predictable once you have watched it a few times. A brief excludes a preservative family. The alternatives that remain often work well only inside a narrower pH band, so the pH target tightens. A tighter pH target changes how some actives behave, and can change the viscosity of the system. Botanical extracts and plant waters, which the same brief usually adds, bring sugars and other nutrients that make the formula a more comfortable place for microorganisms to live. The result is a formula that is simultaneously less protected and more attractive to contamination, held inside a narrower operating window.
None of that is a reason to refuse the brief. It is a reason to sequence it properly. In our experience the projects that go badly are the ones where the preservative decision is made last, after texture and fragrance have already been signed off, because by then every fix costs a round of consumer-visible change. The projects that go well settle the preservation strategy early and let the sensory work happen inside the window that strategy allows.
The validation at the end is not optional either. Antimicrobial protection is evaluated by a challenge test — ISO 11930:2019 is the recognised method for cosmetics — and it has to be run on the final formula in the final primary pack, because the pack is part of the protection.
What else changes when the natural content goes up?
Three things, reliably. The table below is how we tend to explain the trade-offs at the start of a project, because it puts the cost in the right column rather than on the raw material line.
| What the brief asks for | What actually has to change | Where the development time goes |
|---|---|---|
| Restricted preservative palette | pH window, water activity, chelation strategy, packaging format | Multiple challenge test cycles; each failed test costs a reformulation and a re-test |
| Higher natural-origin index | Emulsifier and thickener system rebuilt around natural-origin alternatives | Sensory rework — naturals rarely reproduce a synthetic texture on the first attempt |
| Botanical extracts and plant waters | Colour and odour management, plus nutrient-load compensation in the preservative system | Batch-to-batch specification setting, because harvests differ |
| Fragrance-free or naturally fragranced | The base odour of the formula becomes the product odour | Raw material selection and deodorisation trials before any sensory panel is useful |
| Recycled or mono-material packaging | Compatibility and stability re-established against the new material | A full stability cycle, in parallel with a repeat challenge test |
| A stated naturality percentage on pack | Supplier declarations collected and the index calculated on the final formula | Documentation time, and it must be redone if the formula changes afterwards |
The row that surprises brand teams most often is the fourth one. Fragrance does a lot of quiet work covering the natural odour of a base, and a brief that removes it exposes raw materials that were never selected on odour. That is a raw material sourcing decision more than a formulation one, which is why it is handled alongside raw material sourcing and specification rather than at the bench.
The ORIZI perspective: sequence the brief, do not translate it
Based on ORIZI Group’s manufacturing and product development experience, the most useful thing we do at the start of a clean project is not chemistry. It is turning a marketing brief into an ordered list of constraints, and telling the brand which of them conflict before any beaker work begins.
In practice that means asking four questions in this order. Which substances are genuinely excluded, and is that list the brand’s own published position or a retailer’s requirement? What claim will appear on the pack, and does anybody have to be able to calculate it? What is the primary pack, and does it protect the formula or expose it? And which market is this notified in first? The answers reorder the project. A brand that wants an open jar, no traditional preservatives and a 98% natural-origin figure is describing three requirements that pull against each other, and it is far cheaper to find that out in a meeting than in a failed challenge test three months later.
The second observation, and it is the one we repeat most, is that clean substitutions are rarely one-for-one. A supplier who offers to raise a naturality percentage without changing the formula is describing an arithmetic exercise, not a reformulation — and the number on the pack has to describe what is actually in the bottle. Our product research and development work starts from the constraint list precisely so that the figure at the end is one we can evidence.
This same pattern shows up in adjacent briefs. It is why a sensitive-skin brief changes more than the ingredient list, and why changing a sunscreen formula means testing the SPF again. In each case the visible change is small and the validation behind it is not.
What commonly goes wrong, and what we cannot promise
- Preservation decided last. The single most expensive sequencing error, because the fix is always visible to the consumer by that point.
- A naturality figure quoted from a draft formula. If the formula moves after the calculation, the number on the pack no longer describes the product being filled.
- Certification assumed rather than checked. A certificate covering a facility is not a certificate covering a product, and certificates expire.
- Packaging chosen for sustainability alone. A recycled or mono-material pack is a new material in contact with the formula and needs its own compatibility and stability data.
- Claims written before evidence exists. From 27 September 2026, Directive (EU) 2024/825 restricts generic environmental claims in the European Union unless the trader can demonstrate recognised excellent performance. Malaysia’s own NPRA Guideline for Cosmetic Claims already requires quantitative claims to be substantiated, and states that natural ingredients must not be used to imply a product is safe.
What we cannot promise is a timeline that ignores the challenge test, or a naturality figure decided before the formula is final. Preservative efficacy outcomes are determined by testing, not by intention, and a failed test means another cycle. We would rather set that expectation at the brief stage than manage it as a surprise.
Frequently asked questions
Can a cosmetic product be made completely without preservatives?
Only in specific formats. Anhydrous products such as balms, oils and powders contain no free water for microorganisms to grow in, and single-dose or fully airless formats limit contamination during use. Any water-containing product in a pack the user opens repeatedly needs a preservation strategy of some kind, and the challenge test is what shows whether that strategy works.
How much longer does a clean reformulation take than a conventional one?
It depends on how many constraints conflict, but the dominant variable is the number of challenge test cycles, and each cycle takes weeks rather than days. A brief with one preservative exclusion and a familiar pack usually behaves like a normal development timeline. A brief that combines preservative restriction, a high naturality target and a new packaging format should be planned with at least one additional test-and-reformulate loop built into it.
Does a higher natural-origin percentage make a product gentler?
No. Natural origin describes where a material came from, not how skin responds to the finished product. Tolerance is established by testing the final formula, and Malaysia’s cosmetic claims guideline specifically warns against using natural content to imply that a product is safe.
Do we need ISO 16128 certification to say our product is natural?
There is no such thing as ISO 16128 certification. ISO 16128 is a calculation method, so what you can say is a calculated figure attributed to the method — for example, a stated natural-origin content calculated in accordance with ISO 16128. If you want a certified natural or organic claim, that comes from a certification scheme such as COSMOS or NATRUE, through an approved certification body.
Will natural raw materials make our batches look different from each other?
They can, and planning for it is normal practice rather than a problem. Plant-derived materials vary between harvests in colour, odour and composition, so the answer is a specification with realistic tolerances agreed before production, plus a retained reference standard. Brands that set a colour tolerance up front avoid the far more disruptive conversation about rejecting a batch that is entirely within normal natural variation.
Is sustainable packaging a formulation decision?
Partly, yes. A new packaging material is a new surface in contact with the formula, so compatibility and stability have to be re-established, and because the pack contributes to microbiological protection, the challenge test is normally repeated. It is best treated as a development workstream running in parallel with the formula, not as a decision made after the formula is signed off.
Sources and references
- ISO 11930:2019 — Cosmetics, Microbiology, Evaluation of the antimicrobial protection of a cosmetic product.
- ISO 16128-2:2017 — criteria for natural and organic cosmetic ingredients and products.
- NPRA Guideline for Cosmetic Claims — Guidelines for Control of Cosmetic Products in Malaysia, Second Edition, Annex I Part 8, August 2022.
- Directive (EU) 2024/825 — Empowering Consumers for the Green Transition, applicable from 27 September 2026.
- Source / inspired by: Azelis Personal Care, “Clean, sustainable, and science-backed”, from the Azelis Personal Care inspiration hub.
- Further reading, from the buyer’s side of the same trend: Clean and Sustainable Claims: What OEM Buyers Must Prove on OEMHallmark.
Update history
24 August 2026 — first published.
If your 2027 range is being written around clean, natural or sustainability positioning, the most useful conversation to have early is about which constraints in the brief pull against each other. We are always glad to talk that through, whether or not it leads anywhere — you can reach the team through ORIZI Group, or read more about how we approach product testing and validation first.
