Hypochlorous acid arrived in personal care from two directions at once. Dermatologists and ophthalmologists had been using it for years in specific clinical contexts, and the published literature on topical application was accumulating quietly. Meanwhile the consumer skincare market went looking for something that was not another acid, not another retinoid and not another fragrance-heavy serum, and found a molecule the body already makes.
What happened next is the reason this page exists. A category filled up fast with products whose front panels look similar and whose contents are not. Concentration varies by an order of magnitude between brands. Some are stabilised with additive packages that are doing more work than the active. Some declare a shelf life that their packaging cannot support. And a great many carry claims that the regulatory framework they sit in does not allow.
This page is about what we supply for that market, what the specification is and why, and where the lines are. It is deliberately unexciting about performance, because the performance claims are the part that gets brands into trouble.
Where the cosmetic line sits
Material on this page describes solution supplied for cosmetic, dermatological, ophthalmic and other non-regulated topical use. It is not supplied for pesticidal claims, sterilisation or medical device claims, and nothing here should be read as an antimicrobial or therapeutic claim for a cosmetic product. If your product needs a registered pesticidal claim, that is a different regulatory pathway — see HOCl-AS200. If it needs a drug or medical device claim, that is a third pathway again, and one you will need your own regulatory counsel for.
The cosmetic-grade specification
Cosmetic-grade is a different specification from anything intended for surfaces or process water, and it is different in the inputs rather than only in the numbers.
| Parameter | Specification | Why it is set there |
|---|---|---|
| pH | 5.0 – 6.5 | Keeps the available chlorine predominantly in the hypochlorous acid form, and sits close enough to skin pH that the product is comfortable on the face and around the eyes. |
| Oxidation-reduction potential | Above 800 mV | An independent measurement of the same solution. Two numbers that have to agree is a more useful specification than one number on its own. |
| Water | Double-filtered reverse osmosis and deionised | Dissolved minerals and organics consume available chlorine during storage. Feed water quality is the largest single influence on how a batch ages. |
| Acid | Pharmaceutical grade hydrochloric acid | Used to set pH. In a product that will be sprayed near the eyes, industrial-grade impurities are not acceptable. |
| Salt | USP grade sodium chloride, free of heavy metals | Trace metals catalyse decomposition, so salt grade is a stability parameter as much as a purity one. |
| Additives | None by default | No buffers, surfactants, fragrances, colourants or preservative systems unless a specification requires one and it has been tested with the oxidiser. |
| Chlorine retention data | To 24 months, sealed configurations | Supports a declared shelf life with data rather than with optimism. |
| Optional | Nitrogen-blanket sealing | Displaces headspace oxygen at fill for formats where it materially helps. |
Why additive-free is the default
The instinct in cosmetic formulation is to build a system: an active, a buffer, a humectant, a preservative, a fragrance, a chelating agent. That instinct fights the chemistry here. Hypochlorous acid is an oxidiser, and most of the things a formulator would reach for are oxidisable. A preservative system in a hypochlorous acid product is frequently being consumed by the active it is supposed to be protecting, which is bad for both.
So the default is nothing else in the bottle. That has three consequences worth stating plainly. The ingredient list is short, which is increasingly what the market wants anyway. The safety assessment is simpler, because there is less to assess. And there is nowhere to hide — if the water, the salt or the acid is not right, there is no additive package masking it, which is precisely why the input specification above is as tight as it is.
Where a specification genuinely needs an additional component, we test it with the solution rather than alongside it, and we will say so if the combination does not hold up. That is a more useful answer than agreeing and letting the stability programme discover it nine months later.
The safety package
Cosmetic-grade solution is supplied with human repeat insult patch testing showing it to be non-irritating and non-sensitising, and is formulated to be non-cytotoxic. That combination is what makes the contact positions below defensible: skin, mucosal and ocular contact are use cases where an irritation or sensitisation finding would be disqualifying, and where the absence of additives removes the most common sources of both.
What that package does and does not do is worth being precise about. It characterises the solution we supply. It supports the safety assessment for your finished product. It is not that assessment. Your finished product is this solution in your container with your closure, used the way your instructions describe, on the population your marketing targets, and the responsibility for assessing it sits with you and your safety assessor. A supplier who tells you their patch test discharges your obligation is doing you no favours.
The published context
There is a substantial literature on topical hypochlorous acid, and it is the reason the category exists. Published work has examined hypochlorous acid as a skin antiseptic at low concentration, in disinfection, antisepsis and wound care, as a stabilised wound care agent, and its microbicidal and anti-inflammatory properties, alongside work on hypochlorous acid hygiene solutions on ocular skin, effects on wound healing, post-debridement tissue burden and low-concentration nasal irrigation.
That body of work is indexed in full in our research library. Two things about how to use it. First, these are studies of particular solutions at particular concentrations under particular conditions, most of them clinical or laboratory rather than cosmetic; they do not transfer to a cosmetic product as substantiation, and a brand that quotes them on a product page has made a claim. Second, and more usefully, they are excellent orientation. If you are deciding between 100 ppm and 300 ppm for a facial mist, or trying to understand why ocular applications are specified the way they are, this is where the reasoning lives.
Categories we supply into
| Category | Typical formats | What tends to drive the specification |
|---|---|---|
| Facial mists and toners | Continuous spray, box spray | Feel and drying time matter as much as anything. pH at the skin end of the range, fine even mist, no fragrance. |
| Eye-care and lid hygiene | Fine mist spray, single-use sachets | The most demanding purity case. Additive-free is not a preference here, and sachets remove the in-use contamination question. |
| Post-procedure aftercare | Spray, hydrogel, wipes | Sold through clinics, which means the practitioner asks for the technical file. Documentation quality is part of the product. |
| Acne and eczema support | Spray, gel spray | The category sits closest to the drug claims boundary. Positioning has to be settled before artwork. |
| Pet and equine care | Spray, gel spray, hydrogel | Larger fills, robust packaging, and an audience that reads ingredient lists closely. |
| Professional and clinic bulk | Bulk containers, refills | Cost per use and stability in an opened container dominate. Decanting practice needs to be in the instructions. |
Formats, and the hydrogel
The formats shown at Cosmoprof 2026 — box spray, continuous spray, gel spray, wipes, single-use sachets, hydrogel and hand cleanser — are the practical menu. Most are self-explanatory. Two are worth expanding on.
Single-use sachets solve two problems at once in this category. They remove headspace and in-use contamination entirely, which makes them the most stable format we offer, and they make sampling economics work for a product whose benefit is easier to feel than to explain. For clinic channels they also travel in a kit without a decanting conversation.
The hydrogel is a separate product rather than a thickened spray. Conventional cosmetic gelling systems are organic polymers, which is to say they are exactly what an oxidiser will attack; a gel built that way loses available chlorine steadily and quietly. Ours is a stabilised inorganic matrix with no oxidisable polymer backbone, which is the whole reason it works. It runs 200–600 ppm available chlorine at pH 5.0–6.5, has passed human repeat insult patch testing, and fills into rollers, tubes or jars. Where a format needs dwell time rather than a mist — aftercare, occlusive applications, veterinary use — it is usually the right answer.
The claims boundary, in two jurisdictions
This is the part brands most often get wrong, and the part where the answer differs depending on where you sell.
United States. A cosmetic is intended to cleanse, beautify, promote attractiveness or alter appearance. A claim to treat or prevent disease, or to affect the structure or function of the body, makes the product a drug. A claim to kill or control micro-organisms on a surface makes it a pesticide. The words on the front panel decide the category, not the formula. “Soothing facial mist” is a cosmetic. “Kills acne-causing bacteria” is not, and no amount of asterisked small print rescues it.
European Union. Cosmetic products fall under Regulation 1223/2009, which requires a responsible person established in the EU, a product information file, a safety assessment by a qualified assessor, and notification through the CPNP before the product is placed on the market. There is a further question specific to this chemistry: a product presented with an antimicrobial function may fall under the Biocidal Products Regulation rather than, or as well as, cosmetics legislation, and active chlorine chemistry is a live area there. We are not going to pretend to a conclusion on your behalf — it depends on the presentation and the claim, and it is a question for a regulatory adviser who works in that framework. What we will say is that it is a question to resolve before artwork and before an EU launch date is committed, not after.
The workable discipline is the same as in the registered lane: decide the claim first, let it determine the category, and then design the product and the paperwork for that category.
What MoCRA changed for US brands
The Modernization of Cosmetics Regulation Act brought US cosmetics into a registration and listing regime for the first time in a meaningful way. If you are launching a cosmetic in the US, the obligations that matter to a white-label project are these. Facilities that manufacture or process cosmetics must be registered with the FDA. Products must be listed, with their ingredients. There must be a responsible person named on the label. That person must maintain adequate substantiation of safety for the product. And serious adverse events must be recorded and reported.
Two implications for how you plan. First, “adequate substantiation of safety” is an obligation with your name on it, which is why the distinction earlier between our safety package and your safety assessment matters commercially and not just pedantically. Second, listing requires an ingredient statement, which means the formulation has to be settled before you can complete the administrative steps — another reason the specification conversation belongs at the start of a project rather than the end.
Stability, packaging and the shelf life on the artwork
Everything said about stability in the turnkey overview applies here with more force, because cosmetic packaging is chosen for how it looks. Clear PET shows the product beautifully and is a harder stability environment than amber HDPE. A pump that feels premium may have an internal component that is quietly consuming available chlorine. A cap liner is a formulation decision.
The sequence that works: specify the solution, shortlist packaging, test the combination, then let the artwork declare a shelf life the data supports. We hold chlorine retention data to twenty-four months on sealed configurations and can add nitrogen-blanket sealing where a format benefits, but the number that goes on your carton has to be the number your configuration earned. A brand that prints twenty-four months because a competitor does, on a component that has not been tested, has created a quality problem with a two-year fuse.
What we will and will not do
Three commitments that shape how these projects run. We build the generation equipment ourselves, so the chain from water to filled unit is in one place and a specification change is something we can actually make and verify. We do not compete with contract customers in their own categories, and we do not take a specification developed with one brand to the next one. And we will tell you when a proposed claim sits outside the lane you are in, even when the honest answer slows a launch down — which is less commercially costly than the alternative, and considerably less costly than a recall.
Numbers we deliberately have not put on this page
Minimum order quantities, fill sizes, unit pricing, lead times and tooling costs depend on the format, the regulatory lane and the volume, and quoting a single figure here would be misleading for most of the people reading it. Those come back in writing with the specification. Ask on the quote form and say which lane you are in — registered disinfectant, cosmetic, or not yet decided.
Questions we get asked
Can our cosmetic product say it kills bacteria?
Not as a cosmetic. An antimicrobial claim moves the product into pesticide or drug territory depending on what you claim and where you sell, and in the EU it raises the biocidal product question as well. If an antimicrobial claim is essential to the proposition, you are in the registered lane, not the cosmetic one.
What safety data comes with the cosmetic-grade solution?
Human repeat insult patch testing showing the solution to be non-irritating and non-sensitising, a formulation developed to be non-cytotoxic, and stability data for the sealed configurations we supply. That supports your safety assessment. It is not the same thing as your safety assessment, which has to consider your finished product in your packaging for your intended use.
Why no preservative?
Because a conventional preservative system and an oxidiser are in an argument with each other, and the oxidiser usually loses. The additive-free default exists for that reason, not for marketing. If a specification genuinely requires an additional component we will test it with the solution rather than assume compatibility.
Can you match a competitor’s product?
We can generally match a published specification — concentration, pH, ORP, format. We will not attempt to reverse-engineer somebody’s proprietary formulation, and a matched specification is not the same product.
Do you sell into our category yourselves?
No. We do not compete with contract customers in their own categories. It is a straightforward commitment and it is the reason several of our customers talk to us openly about their roadmaps.
Is the hydrogel a separate product or a thickened version of the spray?
Separate. It is built on a stabilised inorganic matrix specifically chosen because it has no oxidisable polymer backbone for the available chlorine to attack, which is why most conventional gelling systems are unsuitable. It runs 200–600 ppm available chlorine at pH 5.0–6.5 and fills into rollers, tubes or jars.
Where to go next
The full cosmetic-grade specification is on the white-label page. For the mechanics of running a private-label programme end to end, see what a turnkey programme actually involves. If your product needs a registered antimicrobial claim rather than a cosmetic one, that is a different pathway. The published literature is indexed in the research library.
Written by the EcoloxTech engineering team. If you want this applied to your own facility, the free sanitation audit sizes the system and models the payback in writing, at no charge.