A scalp serum sounds like one product. In our experience coordinating personal care development, it very often turns into two — and the split happens earlier than most brand owners expect.
Written & researched by Fenny Yip, Contributing Writer & Manufacturing Industry Practitioner · Technical input by ORIZI Group R&D Team · Fact-checked by Creaton Poh · Published by ORIZI Group · Last reviewed September 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: why does one scalp serum brief become two products?
Because a scalp brief usually contains two different jobs that cannot legally or technically live in the same bottle. A rinse-off product can carry anti-dandruff actives that a leave-on product cannot, and a leave-on serum can carry claims and sensory qualities a shampoo cannot deliver. Once the brand decides which job matters more, the brief resolves. When it refuses to choose, the development runs as two formulas, two stability programmes and two sets of artwork — with the timeline and cost that implies.
Key takeaways
- The rinse-off versus leave-on decision is not a packaging preference. It determines which actives are permitted and at what percentage, so it has to be settled before formulation starts.
- Zinc pyrithione — still the most familiar anti-dandruff active in this region — is permitted in ASEAN in rinse-off hair products only, at up to 1.0 per cent, and has been prohibited in European Union cosmetics since 1 March 2022.
- Malaysia’s cosmetic claims guideline allows “controls, reduces or prevents dandruff” but not “permanently eliminates dandruff”, and allows “helps to strengthen or nourish the hair root” but not “stimulates hair growth”.
- Most delays we see on scalp projects are not formulation failures. They are decisions that were left open — destination market, format, and the exact claim wording — and then had to be made twice.
- A scalp product is not a face serum with a different cap. Sebum load, contact time and the surfactant environment change both the preservation work and the irritation testing.
Scope of this article
This is a manufacturing and product-development coordination view of scalp care briefs for the Malaysian and wider ASEAN market, written for brand owners at the briefing stage. It covers how a brief translates into development work, where the decisions sit, and what commonly gets missed. It is not a formulation manual, and it is not regulatory advice — ingredient eligibility and claim acceptability must be confirmed against the current regulations for the specific product and market. Where we describe our own practice, we say so; where a statement comes from a regulator or a published study, it is cited.
What is actually in a scalp care brief?
Scalp care briefs have changed noticeably over the past few years. They used to arrive as hair care briefs — a shampoo, a conditioner, a fragrance direction, a price point. Increasingly they arrive written in skincare language: exfoliation, barrier, microbiome, essence, ampoule. The brand owner has usually been shown a trend presentation describing the scalp as skin, and the brief reflects that. The observation behind it is fair. The scalp is skin, with denser sebaceous glands and its own microbial population.
What the trend language does not carry across is the structure underneath it. A facial serum brief and a scalp serum brief look similar on paper and diverge almost immediately in development, for three reasons that have nothing to do with the marketing concept.
The first is format. Facial skincare is overwhelmingly leave-on. Hair care is structurally rinse-off, and several of the ingredient restrictions that matter most in this category are written by format rather than by product name. The second is the environment the product has to work in: more sebum, hair fibres in the way, and often a surfactant system in the same routine. The third is the claim. Scalp products attract claims about dandruff and hair fall, and those two words are governed more tightly in Malaysia than most brand owners realise.
How does the rinse-off or leave-on decision change the formula?
It changes which actives are available before anything else is decided. This is the single most consequential line in a scalp brief, and it is usually the one written most casually.
Zinc pyrithione is the clearest illustration. It is the anti-dandruff active most brand owners can name, and in ASEAN it remains available: the ASEAN Cosmetic Directive’s Annex VI list of permitted preservatives carries it at a maximum of 1.0 per cent in hair products and 0.5 per cent in other products — explicitly for rinse-off products only. So a brief that asks for “a leave-on version of our anti-dandruff shampoo” is not asking for a line extension. It is asking for a different active system.
The same molecule tells the export half of the story. Commission Regulation (EU) 2021/1902 added zinc pyrithione to the European Union’s list of substances prohibited in cosmetic products, in force from 1 March 2022. A shampoo built around it is an ordinary, compliant product in Malaysia and cannot be placed on the European market at all. When a brand tells us during the brief that Europe is a two-year ambition, that changes the formulation starting point today — not later.
| Brief says | What it commits the project to | What is easy to miss |
|---|---|---|
| “Anti-dandruff scalp serum, leave-on” | An active system permitted for leave-on use | The familiar rinse-off active is not available in this format |
| “Same formula, two formats” | Two formulas in practice | Two stability programmes, two sets of testing, two artworks |
| “Malaysia first, Europe later” | Either dual-market design now, or reformulation later | Reformulating reopens preservative efficacy and stability work |
| “Exfoliating scalp treatment” | Acid selection with its own restriction levels | Restrictions and warnings can differ by format and by user group |
| “Microbiome balancing” | Evidence that measured a microbial community | A single-organism laboratory result does not support the claim |
What may a scalp product claim in Malaysia?
Less than most briefs assume, and the guideline is unusually specific about it. Annex I Part 8 of the Guidelines for Control of Cosmetic Products in Malaysia, published by the National Pharmaceutical Regulatory Agency (NPRA = National Pharmaceutical Regulatory Agency), sets out acceptable and unacceptable claims by product type. Hair and scalp care products are the first row.
Unacceptable, in the guideline’s own terms: permanently eliminates or stops dandruff; hair loss can be arrested or reversed; restores hair cells; hereditary or hormonal hair loss such as baldness or alopecia; stimulate or promote hair growth; prevent grey hair; prevent or treat cradle cap or seborrhoeic dermatitis. Acceptable: control, reduce or prevent dandruff; anti-hair loss or hair fall due to a physical factor such as breakage; increase hair volume where that is the physical effect of the product; promote healthy hair; helps to strengthen or nourish the hair root or hair follicle.
Read those two lists together and a pattern appears. The acceptable claims describe a cosmetic, largely physical outcome. The unacceptable ones describe a biological mechanism or name a medical condition. That is the line, and it is worth understanding as a principle rather than memorising as a word list, because the same logic governs wording the guideline does not happen to list.
The ORIZI perspective: where scalp projects actually lose time
Based on ORIZI Group’s experience coordinating personal care development, the delays on scalp projects are rarely technical. In the briefs we handle, the recurring pattern is that a decision is left open at the start and then has to be made twice — once by the development team as a working assumption, and again by the brand owner when the consequence becomes visible.
Three decisions account for most of it. The destination market, because it determines which actives can be used at all. The format, because it determines which actives are permitted in that format. And the exact claim sentence, because it determines the artwork. Of those three, the claim wording is the one that costs the most when it moves late, since by then the artwork has usually been through design, brand approval and sometimes print quotation.
Our practical response is to bring the claim conversation forward, before the sample stage rather than after it. We ask a brand owner to write the exact sentences they intend to put on the front of the pack, in the words they intend to use, and we discuss those sentences against the guideline while the formula is still open. It is a short conversation that is uncomfortable early and expensive late. It also frequently changes the product: a brand that discovers it cannot say “stimulates growth” often decides the honest strengthening-and-breakage story is the better positioning anyway, and briefs a different, better product as a result.
The other thing we raise early is evidence. If a brief is positioned on microbiome balance, we ask what evidence will support it. This matters because the science has moved. A 2025 multi-omics study of oily scalps in Frontiers in Microbiology found that in dandruff-affected scalps Staphylococcus rose to 58.70 per cent against 23.85 per cent in healthy oily scalps, while Cutibacterium fell from 63.24 to 27.87 per cent — and Malassezia restricta, the organism the category is built around, differed comparatively little (Yu et al., 2025). If dandruff on an oily scalp is a community imbalance rather than one organism, then an in-vitro result against a single organism is not the evidence a microbiome claim needs. That gap belongs in the conversation at briefing, when the testing budget is still being set.
What commonly goes wrong
- Treating a scalp product as a face formula in a new pack. Sebum load, contact time and the surrounding routine all change the preservation and irritation picture, so a facial protocol does not transfer unchanged. Relevant product testing has to be scoped for the actual product.
- Leaving the export market undecided. This is the most expensive open question in the category, because the answer can invalidate the active system after development is complete.
- Approving artwork before claims are checked. A rejected formula costs development time. A printed carton costs the print run.
- Assuming a supplier’s claim language is usable here. Ingredient documentation is often written for a different regulatory regime. Wording such as “regrowth” or a named skin condition is a signal to check the rest of the pack carefully.
- Underestimating fragrance and sensory work. A leave-on scalp product stays in contact with skin and hair for hours; sensory acceptability and irritation potential need more attention than a rinse-off equivalent, not less.
Frequently asked questions
Can we launch a scalp serum and an anti-dandruff shampoo as one development project?
Yes, and it is often the sensible route — but it should be scoped as two formulas from the start rather than one formula in two packs. The two products can share a positioning, a fragrance direction and much of the brand work. They will not share an active system if one is rinse-off and the other leave-on. Scoping it correctly at the briefing stage keeps the timeline predictable.
Is zinc pyrithione still allowed in Malaysia?
It appears in the ASEAN Cosmetic Directive’s preservative annex at up to 1.0 per cent for hair products and 0.5 per cent for other products, restricted to rinse-off products and excluded from oral hygiene products. The European Union prohibited it in cosmetics from 1 March 2022. Because annexes are amended periodically, the current position should be confirmed against the latest release before a formula is committed for any market.
Can our product say it reduces hair fall?
Malaysia’s claims guideline lists anti-hair loss or hair fall as acceptable where the loss is due to a physical factor such as breakage, and lists claims to arrest or reverse hair loss, or references to hereditary or hormonal loss, as unacceptable. In practice the claim should be framed around reducing breakage-related fall rather than around growth. We recommend having the exact sentence reviewed before artwork is prepared.
How long does a scalp care development take?
It depends chiefly on how many of the three key decisions — destination market, format, and claim wording — are settled at the briefing stage, and on the testing the claim requires. A straightforward single-market rinse-off product with conventional claims is a shorter path than a dual-market leave-on serum positioned on microbiome evidence. We would rather give a realistic range once we have seen the brief than quote a number that ignores those variables.
Does a scalp product need its own stability and compatibility testing?
Yes. Format, pack and active system all affect stability, and a leave-on scalp product in a dropper or applicator pack behaves differently from a shampoo in a flip-top bottle. Preservative efficacy also has to be established for the actual formula and pack, not inherited from a related product.
Sources and references
- National Pharmaceutical Regulatory Agency, Guidelines for Control of Cosmetic Products in Malaysia, Annex I Part 8 — Guideline for Cosmetic Claims (Second Edition, August 2022).
- ASEAN Cosmetic Directive, Annex VI — list of preservatives which cosmetic products may contain (Version 2021-1, 15 November 2021).
- Commission Regulation (EU) 2021/1902 amending Annexes to Regulation (EC) No 1223/2009 as regards CMR substances.
- Yu H, Li J, Wang Y, Zhang T, Mehmood T, Habimana O, “Dysbiosis and genomic plasticity in the oily scalp microbiome: a multi-omics analysis of dandruff pathogenesis”, Frontiers in Microbiology 16:1595030 (2025).
- Source / inspired by: Azelis Personal Care, “In tune with tresses: what APAC consumers demand in hair care”.
- Further reading, a market and sourcing view of the same subject: “Scalp Care Claims and Actives: What OEM Buyers Must Check” on OEM Hallmark.
Related reading from our team
Two earlier articles cover decisions that come up constantly in scalp briefs: why a clean and natural brief becomes a preservation problem first, and what a request to make it for sensitive skin actually changes in formulation. Both are relevant here, because scalp products sit at the intersection of the two.
Update history
September 2026 — first published.
If you are working on a scalp brief
If you are at the stage of writing a scalp care brief and would like to talk through the format and claim decisions before committing to a direction, our team is happy to discuss it. The most useful conversation is usually the early one — the exact sentences you want on the pack, and the markets you eventually want to sell into. You can see the categories we work in on our OEM shampoo and scalp care and hair serum and oil pages, or simply send us the brief as it stands and we will tell you honestly which parts need a decision first.
