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Henna: Certifications, Sterilization, Heavy Metals - What you should know

After last week's deepening on

What is Lawsone/Naftoquinone, Prohibition in case of Favism and Allergy Risk , today I would like to continue talking to you about other topics such as:

  • the Certifications and what the purchase of a certified product certifies,

  • the sanitization and sterilization of dyeing herbs

  • the detection of heavy metals in dyeing and Ayurvedic herbs.

This 'natural' choice, henna and herbal dyes, requires attention and awareness because, once again, I reiterate that the 'natural' declared on the label does not mean that the product is harmless, beyond always making sure that a product is suitable for your skin and skin and does not cause allergic reactions.

Henna: Certifications, Sterilization, Heavy Metals - What you should know

Certifications. What it means to choose to buy a certified product:

  • Greater safety of use?

  • Better quality?

  • Tested and controlled product?

  • Without toxic substances?

  • Cruelty-free?

  • Nickel free?

These are just a few inaccurate answers that attest to the overwhelming confusion that reigns supreme when it comes to this topic and I hope that by the end of reading this article, much of this confusion has been cleared away.

Who issues the certification?

There are national and international private certifying bodies that propose their own regulations to which companies can adhere in order to obtain bio - natural - vegan - halal, etc. certification and the respective stamps to be used on the label.

The most famous European certifications are Cosmos and Natrue while in Italy the best known certification bodies are the CCPB, ICEA, AIAB, etc.

There are also certifications such as VEGAN OK - it certifies that vegan ethics are respected - certification based on self-declaration and which assumes that the company that adheres to it could be subject to any checks by the certifying body.

Beautilicious Delights herbal hair dyes are certified by ECOCERT with the European COSMOS standard , a specification born from the collaboration between the main certification bodies and international organizations in the sector.

So, for obvious reasons, I can tell you about it and learn more about what the COSMOS ORGANIC or COSMOS NATURAL certification certifies.

What does the certification guarantee?

In this specific case, I can tell you what COSMOS certification guarantees.

The Cosmos specification :

  • provides production and transformation processes that respect the environment and the health of consumers

  • prohibits the use of nanomaterials

  • provides for the development of the concept of green chemistry

  • requires the responsible use of natural resources

  • requires respect for biodiversity

  • requires the absence of petrochemical ingredients (except for authorized preservatives): paraben, phenoxyethanol, synthetic perfumes and dyes

  • provides for the absence of GMOs and derivatives from GMOs

  • prohibits irradiation with gamma rays ox

  • bans animal testing


All products marketed with the Cosmos Organic and Cosmos Natural logos have been checked by the certifying body (Ecocert) : from the composition ( by INCI ) and from the manufacturing, transformation and production process up to the validation of the packaging.

The certification ascertains that the product follows the strict standards set by the disciplinary to guarantee valid, natural and safe production processes for health.

There organic certification of henna and dyeing and ayurvedic herbs it also offers a further guarantee on the methods used in cultivation and agriculture and certifies the absence of use of GMOs or other hybrids not allowed.

The same specification requires that the different production processes are separated to prevent contamination of organic or natural ingredients.

There must also be a quality control system that includes:

  • complete traceability of ingredients and final products

  • standard production procedures at all stages

  • testing of ingredients and products

  • analysis, production and storage records.

Our supplier follows the rules of correct cultivation and harvesting (GACP) - following the Guidelines for Good Agricultural Practice for all his plants.

It maintains a sterilized production system in each processing phase, starting from the selection of the seeds up to the packaging of the finished products.

Regulation (EC) No. 1223/2009 establishes rules that every cosmetic product placed on the market must comply with , in order to guarantee the correct functioning of the internal market and a high level of protection of human health.

So a cosmetic product, certified or not , by the simple fact that it is marketed is presumed to be safe for the consumer's health because otherwise it would not be in compliance with the law.

It is up to the individual manufacturer to ensure that the product is used safely - whether it is lipsticks, face creams, hair shampoo or hair henna.

Sanitization and Sterilization of Henna and Dyeing Herbs

Henna and herbal dyes have only made a comeback in the last 6-7 years and the market for dyeing and highlighting plants is booming.

They represent a truly complex universe precisely because they are dried and pulverized plants at risk of bacterial contamination even more considering that NOT all processing and production factories are equipped to work them properly and safely, without contamination and bacterial proliferation.

This is one of the reasons that led us to rely on a single producer certified with the Cosmos standard and whose plants for the production and processing of dyeing herbs follow the guidelines of the Cosmos specification.

Is it necessary to sanitize / sterilize the henna?

As you may already know, the powders we use to color / wash or simply pamper our hair are the result of drying and micronizing some specific plants (dyeing, reflecting or cleansing properties thanks to the vegetable saponins they contain).

A minimal bacterial load is also naturally present in plants.

Based on the hygiene and humidity conditions of the production and storage plants, based on the healthiness of the processing plants, these powders can have a significant bacterial load, molds and yeasts and in some cases even pathogens.

'Good manufacturing practices should be able to ensure that products, while not necessarily sterile, do not contain harmful organisms and that the background microbial population remains stable and in low concentrations.' (source ISTISAN Reports 13-15 )

In an extract of the UNI EN ISO 17516:2015 Standard "Cosmetics - Microbiology - Microbiological limits" we find the following guidelines:

Click on the photo to view the enlarged certificate

Cosmetics- Microbiology – Microbiological limits

This International Standard sets microbiological limits for cosmetics.

If the manufacturing process of the dyeing herbs takes place from the beginning in all stages of processing in sterilized and well-ventilated rooms, the risk of contamination and deterioration of the powders is reduced to a minimum .

However, if the processing and transformation conditions of the product are favourable, bacteria can proliferate.

In these cases it would be essential to sanitize / sterilize the powders to break down the bacterial load and eliminate the pathogens.

I say " it would be essential " because the vast majority of Indian establishments DO NOT carry out sanitization and DO NOT break down the bacterial load present in the powders because they are not structured to be able to do it.

In addition, it must be said that it is NOT mandatory to carry out sterilization / sanitization in order to export these hair care powders.

Are the henna and Beautilicious Delights powders sanitized / sterilized?

Our Indian supplier uses a sterilized production process in all manufacturing stages , from the harvest of the plants to the packaging of the finished products.
The facility where the plants are processed is sterilized and well ventilated to protect the crop from moisture and other possible contaminants.

Once harvested, the plants are analyzed through organoleptic and sensory tests regarding the colour, aroma, size and appearance of the plant.

Subsequently, after this first step of approval of the raw material, specific tests are carried out to detect E. coli, moulds, bacteria, coliforms, salmonella and yeasts.

State-of-the-art systems are used for drying and pulverizing the plants, while a steam sterilization system and a latest generation cooling system are used for the sanitization of the dyeing powders, which make it possible to maintain a high quality of the powders without altering the active principles of plants.

If microbiological contamination is found , the batch is sanitized using the state-of-the-art steam sterilization facility.

Subsequently , analyzes are also carried out to detect the levels of aflatoxins, traces of pesticides and pesticides , all this despite the fact that the plants come from organic and/or spontaneous agriculture in which pesticides and pesticides are not really used.

In addition, all products are tested to detect the presence and levels of heavy metals (lead, mercury, arsenic, cadmium).

Does the BIO certification exclude sanitization?

Some of you have pointed out to me that there are those who say that sterilized / sanitized herbs CANNOT be certified organic because sanitization is usually carried out with gamma or X-ray irradiation, physical processes prohibited in the organic regulations (as we have also seen above when we talked about Certification).

Wrong information because fortunately there are also other types of physical processes for sanitizing henna and powders, such as sanitizing with heat treatments.

I leave in the image below, the appendix I of the COSMOS specification which shows the admission of sanitization through steam sterilization.

henna sanitization steam sterilization cosmos ecocert beautilicious

The sanitization processes through irradiation with Gamma rays or X-rays are NOT allowed by the organic regulations as there are still too few studies on the impact that this procedure may have on the phytocompound of the plant which is in any case modified following this procedure.

All in all, it is NOT true that a certified BIO hair powder can contain bacteria, mold and pathogens because presumably it has not been sanitized.

It is obviously up to the individual producer to make sure of the production process and to carry out the sanitization procedures when necessary but the organic certification DOES NOT exclude a priori that the product has been sanitized precisely because there are physical processes such as steam sterilization , allowed by the organic regulations.

So for every Beautilicious Delights import batch we provide certificates with microbiological count, heavy metals and pesticide free.

Below is an example of a sample certificate issued for Indigo.

Click on the photo to view the enlarged certificate

indigo microbial count analysis heavy metals pesticides fertilizers beautilicious

Microbial count and search (absence) of pathogens which is then also carried out in Italy by an external laboratory .

Click on the photo to view the enlarged certificate

indigo microbiological analysis heavy metals pesticides fertilizers beautilicious

Below is an example of another certificate, taken as a sample, issued for the Kapoor Glow. The tests are carried out on all hair powders, both dyeing and reflecting, washing or Ayurvedic such as Kapoor.

Click on the photo to view the enlarged certificate.

kapoor beautilicious microbiological analysis

Obviously, also in this case, for a matter of privacy, the data of the laboratory issuing the certificates have been obscured.

Heavy metals - what does the law say?

Heavy metals are substances widely diffused in the environment, naturally present in rocks, soil and water, and therefore can be found in the processing of dyes and other raw materials used in all industries, including the cosmetic one.

Precisely because their presence is ubiquitous in the environment, it is practically impossible to avoid daily exposure to heavy metals.

Toxicology studies have shown that heavy metals have a toxicological potential: some heavy metals do not cause toxicity problems, but in certain concentrations and in predisposed people, they are capable of triggering allergic reactions.

Some metals have been used in the past as ingredients in cosmetic products, such as, for example, lead acetate used as a hair dye and cinnabar red (mercury sulphide) already used in Roman times.

The use of metals as ingredients is explicitly prohibited by Regulation (EC) 1223/2009 which inserts them in Annex II , i.e. in the list of substances whose use is prohibited in the composition of cosmetic products.

However, due to their ubiquitous presence in the environment, article 17 of Regulation (EC) 1223/2009 indicates the following:

"The unintended presence of a small amount of a prohibited substance, resulting from impurities in the natural or synthetic ingredients, the manufacturing process, storage, migration from the packaging and which is technically unavoidable despite the observance of good manufacturing practices , is permitted provided that such presence is in accordance with Article 3."

So basically, the Regulation tolerates the presence of heavy metals in finished products in small quantities when they are a residue of the production and conservation process of the cosmetic or when present as impurities of other ingredients of the cosmetic (such as colourants).

The presence of low doses of heavy metals, in fact, does not compromise the safety of the cosmetic and does not jeopardize the protection of consumer health.

This presence is accepted only if:

  • Heavy metals are present in technically unavoidable trace levels;
  • If the presence occurs despite the observance of good manufacturing practices;
  • The cosmetic product has been assessed as safe by the Safety Evaluator under normal or reasonably foreseeable conditions of use.

Is there a limit value for heavy metals allowed in cosmetic products?

As specified above, Regulation (EC) 1223/2009 indicates that the presence of heavy metals, in technically unavoidable traces, is tolerated but in fact no global maximum threshold has been defined for heavy metals in cosmetics.

To date it is not yet clear what the limit for heavy metals is above which the cosmetic product is not compliant and an individual limit for each of the heavy metals has not yet been clearly indicated.

Therefore, when "reduced quantity of prohibited substance" is mentioned in Article 17 of Regulation (EC) 1223/2009, in fact there is no reference value.

There are epidemiological studies conducted by the ISS (Istituto Superiore di Sanità) which come to the conclusion that a maximum concentration of 1 ppm is safe, but there is no agreement at the European level.

Considering that the European Union has not yet defined the concentration of metals in a cosmetic that can be defined as a "tolerable trace", the ISTISAN Report 14/14 has led some Authorities of the individual Member States to adopt transitional measures and establish guideline values to be respected that you will find listed below.

Click on the photo to view the enlarged certificate.

heavy metal cosmetic henna beautilicious

Claim: Metal free?

There are no products " free of heavy metals " because, as we have ascertained, heavy metals are ubiquitous substances and, therefore, traces can be found in any product, cosmetic or food, as well as in the environment and in nature.

The claim " metal free " is consequently misleading if it is used to indicate that heavy metals are not used as ingredients in the cosmetic because it is already prohibited by law.

Nickel free or Nickel tested?

Plants accumulate metals, so much so that some are used to reclaim contaminated land. Nickel, like all other heavy metals , occurs naturally and it is NOT possible to have a product that contains 0%. So the law provides that cosmetic products can contain "traces" of nickel, ie within a certain percentage.

The "NICKEL FREE" claim is NOT in compliance with the law because it is not possible to be sure that it has been completely eliminated.

The claim "NICKEL TESTED" means that there is a voluntary certification by the company which certifies that the value of nickel in the product is less than a certain amount.

On SITOX INFORMA, the periodical of the Italian Society of Toxicology (Year XVI n. 1 - May 2013) a Consensus Document on unavoidable residues of heavy metals as impurities in cosmetics has been published.

I hope I was able to be as comprehensive as possible, but for any doubts, I'll wait for you in the comments area below.

© Beautiful Delights

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