Non-Toxic at Truly Free Badge | 🚫 Restricted Substance List

The Restricted Substance List is structured in two parts.

Part 1: Intentionally Added Ingredients outlines substances that may be used in formulation and are either prohibited or restricted based on their potential health impact.

Part 2: Contaminants, Residuals & Byproducts addresses substances that are not intentionally added but may be present as impurities or introduced during manufacturing. These substances must be controlled to the lowest technically achievable levels and, where applicable, meet defined limits.

Together, these requirements ensure that both formulation choices and supply chain inputs are evaluated to support a comprehensive, risk-based definition of “Non-Toxic at Truly Free.”

Acrylates (Monomers)
Restriction: Prohibited 🚫

Low molecular weight acrylate and methacrylate monomers are prohibited due to their potential for skin sensitization, irritation, and systemic toxicity.

Examples:

• Ethyl acrylate
• Ethyl methacrylate
• Butyl methacrylate
• Methyl methacrylate
• Hydroxypropyl methacrylate
• Tetrahydrofurfuryl methacrylate
• Trimethylolpropane trimethacrylate

Alkylphenols & Alkylphenol Ethoxylates
Restriction: Prohibited 🚫

Examples:

• Nonylphenol (NP)

• Nonylphenol ethoxylates (NPEs)

• Octylphenol

Aluminum Salts (Soluble)
Restriction: Prohibited 🚫

Soluble aluminum salts commonly used as antiperspirant actives are not permitted.

Examples:

• Aluminum chloride
• Aluminum chlorohydrate
• Aluminum hydroxybromide
• Aluminum zirconium compounds
• Aluminum chlorohydrex
• Aluminum dichlorohydrate
• Aluminum sesquichlorohydrate
• Aluminum zirconium complexes

Aluminum Salts (Insoluble / Inert Aluminum Compounds)
Restriction: Allowed ✅

Insoluble aluminum compounds used as pigments, opacifiers, or coating agents are permitted where they are not bioavailable. These materials must comply with the heavy metal limits defined in Part 2: Contaminants, Residuals & Byproducts.

Examples:

• Aluminum oxide

• Aluminum hydroxide

Ammonia & Ammonium Hydroxide
Restriction: Prohibited 🚫

Benzophenones and Related Compounds
Restriction: Prohibited 🚫

Examples:

• Benzophenone

• Benzophenone-1 through -12

• Benzophenone-3 (Oxybenzone)

Benzyl Acetate & Butyl Acetate
Restriction: Prohibited 🚫

BHA (Butylated Hydroxyanisole)
Restriction: Prohibited 🚫

BHT (Butylated Hydroxytoluene)
Restriction: Prohibited 🚫

Bisphenols (All forms)
Restriction: Prohibited 🚫

Includes, but is not limited to: BPA, BPS, BPF, BPAF, BPB, BPE, BPP, BPZ and related analogues.

Butoxyethanol
Restriction: Prohibited 🚫

Chemical UV Filters & Boosters (General Category)
Restriction: Prohibited 🚫

Examples:

• Oxybenzone

• Avobenzone
• Octinoxate
• Butyloctyl Salicylate

Chlorphenesin
Restriction: Prohibited 🚫

Coal Tar & Coal Tar Derivatives
Restriction: Prohibited 🚫

Colorants (General Category)

Synthetic Organic Colorants (Dyes & Lakes)

Restriction: Prohibited 🚫

Synthetic organic colorants, including FD&C and D&C dyes, aluminum lakes, and other petroleum-derived dyes, are not permitted.

Carbon Black (CI 77266)

Restriction: Prohibited 🚫

Inorganic & Mineral-Based Colorants (Including Synthetic Mica)

Restriction: Allowed ✅

Inorganic and mineral-based colorants, including iron oxides, titanium dioxide, zinc oxide, and synthetic mica (fluorphlogopite), are permitted where compliant with the heavy metal limits defined in Part 2: Contaminants, Residuals & Byproducts.

Ethanolamine Compounds
Restriction: Prohibited 🚫

Examples:

Ethoxylated Compounds
Restriction: Prohibited 🚫

Ethoxylated ingredients are commonly identified by names containing “-eth” (e.g., laureth, steareth, ceteareth), as well as PEG (polyethylene glycol), polysorbates, poloxamers and alcohol ethoxylates.

Examples:

• Laureth-4, Laureth-7
• PEG-40 Hydrogenated Castor Oil
• Polysorbate 20, Polysorbate 80

Flavors (Synthetic Flavoring Agents | Artificial Flavors)
Restriction: Prohibited 🚫

Fluoride
Restriction: Prohibited 🚫

Formaldehyde
Restriction: Prohibited 🚫

Formaldehyde-Releasing Ingredients
Restriction: Prohibited 🚫

Examples:

• DMDM hydantoin
• Quaternium-15
• Imidazolidinyl and Diazolidinyl Urea
• Bronopol
• Glyoxal

Fragrance / Parfum (Synthetic)
Restriction: Prohibited 🚫

Fragrance / Parfum (Natural)

Restriction: Restricted ⚠️

Allowed only if composed solely of disclosed natural aromatic materials (e.g., essential oils, isolates or botanical extracts). Documentation may include full ingredient disclosure or supplier confirmation of composition.

Glycol Ethers
Restriction: Prohibited 🚫

Examples:

• 2-ethoxyethanol
• Butoxyethanol (2-butoxyethanol)
• Ethylene glycol ethers

Grapefruit Seed Extract (Commercial Preservative)
Restriction: Prohibited 🚫

Does not apply to authentic botanical grapefruit seed extract not used for preservative function.

Hydrocarbon Propellants
Restriction: Prohibited 🚫

Hydrocarbon propellants, including butane, isobutane, and propane, are not permitted.

Hydroquinone
Restriction: Prohibited 🚫

Isothiazolinone Preservatives
Restriction: Prohibited 🚫

Examples:

• Methylisothiazolinone
• Benzisothiazolinone
• Methylchloroisothiazolinone

Methoxyethanol (Methyl Cellosolve)
Restriction: Prohibited 🚫

Methylene Chloride
Restriction: Prohibited 🚫

Nano Hydroxyapatite
Restriction: Restricted ⚠️

Nitromusks & Polycyclic Musks
Restriction: Prohibited 🚫

Parabens
Restriction: Prohibited 🚫

Petroleum-Derived Occlusives (Mineral Oil & Petrolatum)
Restriction: Prohibited 🚫

Examples:

• Mineral oil
• Petrolatum
• Paraffin
• Hydrogenated mineral oil

PEGs, PPGs

Restriction: Prohibited 🚫

See Ethoxylated Compounds section.

PFAS or PFC Compounds

Restriction: Prohibited 🚫

Per- and polyfluoroalkyl substances (PFAS), including fluorinated compounds used for water, oil, or stain resistance, are not permitted. This includes, but is not limited to, PTFE, perfluorinated and polyfluorinated ingredients.

Phenoxyethanol

Restriction: Prohibited 🚫

Phthalates

Restriction: Prohibited 🚫

Polyacrylamide

Restriction: Prohibited 🚫

Polyacrylamide is not permitted due to its potential to contain residual acrylamide, a neurotoxicant and probable carcinogen. Restrictions on polymeric ingredients are based on specific toxicological concerns associated with their monomers or manufacturing processes. Not all synthetic or acrylic-based polymers are treated equally.

Propylene Glycol

Restriction: Prohibited 🚫

Quaternary Ammonium Compounds (Quats)

Restriction: Restricted ⚠️

Quats used for disinfecting purposes are prohibited 🚫

Examples:

• Didecyldimethylammonium chloride (DDAC)
• Alkyl dimethyl benzyl ammonium chloride (ADBAC)

Quats used for softening and conditioning are permitted ✅

Examples:

• Behentrimonium methosulfate (BTMS)
• Stearalkonium chloride
• Distearoylethyl dimonium chloride
• Lauryl Trimethyl Ammonium Chloride

Resorcinol

Restriction: Prohibited 🚫

Sodium Hypochlorite

Restriction: Prohibited 🚫

Talc

Restriction: Prohibited 🚫

Titanium Dioxide (Nano)

Restriction: Prohibited 🚫

Titanium Dioxide (Non-Nano

Restriction: Prohibited in aerosolized or inhalable forms 🚫

Titanium dioxide must not be used in spray or aerosol products where inhalation exposure is reasonably likely.

Toluene

Restriction: Prohibited 🚫

Triclosan & Triclocarban

Restriction: Prohibited 🚫

Zinc Oxide  (Nano)

Restriction: Prohibited 🚫

The following substances are not intentionally added to cosmetic products but may be present as impurities, residuals, or byproducts of raw materials or manufacturing processes.

All such substances must be reduced to the lowest technically achievable levels. Compliance must be supported by supplier documentation, including Certificates of Analysis (COAs), supplier declarations, or process validation statements. Third-party testing may be required where appropriate or in higher-risk applications.

Where specified, quantitative limits must not be exceeded.

Benzene

Restriction: Non-detect ⚠️

Applies to aerosolized products and spray applications. Benzene must not be intentionally added and must not be present above detectable levels. Compliance must be supported by supplier documentation and/or testing where applicable.

Heavy Metals

Restriction: Must not exceed the following levels ⚠️

• Lead - less than10 ppm
• Arsenic - less than 3 ppm
• Cadmium - less than 3 ppm
• Mercury- less than 3 ppm
• Antimony - less than 5 ppm.

Heavy metals must not be intentionally added and must be minimized to the lowest technically achievable levels.

These limits apply to raw materials and finished products, with particular relevance for colorants, mineral-based ingredients, and products with ingestion potential (e.g., lip products). This requirement also applies to naturally derived mineral ingredients (e.g., clays), which may contain trace levels of heavy metals.

Compliance must be supported by supplier documentation. Additional testing of finished products may be required for higher-risk applications.