System 1 Cleanser Thickening Daily Shampoo

These describe what an ingredient is, not whether it is a problem. The stance marks above are the ratings; these are not.

• common irritantSodium Lauryl Sulfate, Cocamidopropyl Betaine, Propylene Glycol

  • Sodium Lauryl Sulfate: A strong cleansing agent used as the reference irritant in skin-irritation testing. OECD Test Guideline 439 (in vitro skin irritation, reconstructed human epidermis), paragraph 24: "The suggested PC is 5% aqueous SDS", sodium dodecyl sulphate, the same substance as sodium lauryl sulfate, CAS 151-21-3.
  • Cocamidopropyl Betaine: A mild cleansing agent, but a recurring patch-test finding, usually traced to leftovers from how it is made. American Contact Dermatitis Society, Allergen of the Year 2004 (Fowler JF Jr, Dermatitis 2004;15(1):3-4).
  • Propylene Glycol: A solvent that shows up in patch-test clinics, more often as irritation than as allergy. American Contact Dermatitis Society, Allergen of the Year 2018 (Jacob SE, Scheman A, McGowan MA, Dermatitis 2018;29(1):3-5).

• fragrance materialMentha Piperita Oil, Menthol

  • Mentha Piperita Oil: A cooling essential oil the EU names on its own account as a fragrance substance to be declared on the label. EU Regulation (EC) 1223/2009, Annex III entry 361, inserted by Commission Regulation (EU) 2023/1545: a fragrance substance whose presence must be indicated in the list of ingredients above 0,001% in leave-on and 0,01% in rinse-off products. It is declarable in its OWN right, not by way of any component it carries. The name to look for on a label is "Mentha Piperita Oil". The duty applies now. Transition footnote (40) lets stock that does not comply, lawfully placed on the Union market before the 31 July 2026 cut-off, be made available until 31 July 2028.
  • Menthol: The cooling component of mint oils, named by the EU as a fragrance substance to be declared on the label. EU Regulation (EC) 1223/2009, Annex III entry 338, inserted by Commission Regulation (EU) 2023/1545: a fragrance substance whose presence must be indicated in the list of ingredients above 0,001% in leave-on and 0,01% in rinse-off products. It is declarable in its OWN right, not by way of any component it carries. The name to look for on a label is "Menthol". The duty applies now. Transition footnote (40) lets stock that does not comply, lawfully placed on the Union market before the 31 July 2026 cut-off, be made available until 31 July 2028.

• exfoliating acidSalicylic Acid

  • Salicylic Acid: A beta hydroxy acid that clears the inside of pores; the EU restricts its level and keeps it off children under three. SCCS Opinion on Salicylic Acid, Submission I (SCCS/1601/18, corrigendum of 20 to 21 June 2019); EU Regulation (EC) 1223/2009 Annex III entry 98, as amended by Commission Regulation (EU) 2021/850, which for purposes other than preservation caps it at 3,0% in rinse-off hair products, 2,0% in other products, and 0,5% in body lotion, eye shadow, mascara, eyeliner, lipstick and roll-on deodorant, and states "Not to be used in preparations for children under 3 years of age." Its separate PRESERVATIVE use sits at Annex V entry 3, capped at 0,5% (acid), where the salts carry the carve-out "except for shampoos".