24 CERTIFICATION
This requirement often surprises manufacturers whose quality systems do not traditionally document microbial lineage in this way. It can also be frustrating for sales teams. Biotech remains one of the fastest-growing
areas of cosmetic innovation - biosurfactants, postbiotic complexes and fermentation-derived actives - but suppliers must be prepared for deeper technical interrogation than for conventional materials.
Processing aids Processing aids are rarely listed on specification sheets yet play a critical role in Vegan Trademark assessment. Suppliers must disclose: ■ Bleaching agents ■ Extraction solvents ■ Catalysts ■ Carriers ■ Clarifying agents ■ Column chromatography media ■ Defoamers ■ Enzymes used to modify botanical materials Even if processing aids are not present in the
final ingredient, the Vegan Trademark requires evidence that they were not animal-derived. For example: ■ Botanical extracts might be processed with animal-derived clarifiers. ■ Waxes or oils may rely on animal-based bleaching earths or filtration media: ■ Fatty acids may have used tallow-derived intermediates during distillation. Testing cannot be used to ‘prove’ the absence
of animal inputs—the assessment relies entirely on process data:
Ingredients that appear vegan, but aren’t Several ingredient classes are frequently assumed to be vegan by default, yet pose recurring compliance challenges:
Fatty acids and fatty alcohols Common feedstocks include palm or coconut - but tallow remains widely used in global supply chains. Origin must be specified.
Alcohols Ethanol, benzyl alcohol and other cosmetic alcohols can be produced from animal-fermented substrates. Origin must be declared.
Fragrance materials Fragrances may contain animal-origin components such as civet, musk, ambergris, castoreum or shellac derivatives-even when the ingredient is proprietary.
Botanical extracts These may rely on non-vegan extraction solvents or processing aids. Suppliers must disclose both. Understanding where hidden animal
derivatives appear in the supply chain is the key to minimising non-compliance surprises.
Cross-contamination The Vegan Trademark requires manufacturers to
PERSONAL CARE MAGAZINE June 2026
minimise cross-contamination from animal-derived substances “as far as reasonably practicable.” The benchmark level for cross-contamination
is ideally under 100 ppm in the final product. If levels exceed this threshold, the Trademark team may evaluate: ■ Plant traffic flow ■ Raw material storage ■ Production scheduling ■ Equipment design ■ Hygiene procedures ■ Training protocols If the manufacturer can demonstrate robust risk minimisation, exceeding 100ppm does not automatically invalidate an application but it will require investigation. This is an area where ingredient suppliers benefit from strong GMP documentation.
Animal testing The Vegan Trademark maintains strict prohibitions on animal testing, including: ■ Efficacy, toxicity, safety or cosmetic testing ■ Testing conducted by the applicant, on their behalf, or by any party under their effective control ■ Tests that rely on animal-derived systems, including HET-CAM, BCOP, and ICE Suppliers must confirm compliance for each
raw material used. This can be challenging for multi-tier or international supply chains and early communication with upstream manufacturers is essential.
Myth busting Myth 1: Selling in China automatically disqualifies a product Selling in territories requiring mandatory animal testing does disqualify products from the Vegan Trademark. Suppliers must confirm the regulatory jurisdiction of their finished goods.
Myth 2: Fertilisers used in crop production affect compliance Fertiliser origin is not assessed, as doing so would dramatically restrict supply chains without materially reducing animal exploitation.
Myth 3: Packaging must be vegan Packaging is generally outside the Trademark scope unless made from obviously non-vegan materials.
These clarifications help suppliers direct their regulatory efforts efficiently.
Preparing for certification To minimise delays and reduce back-and-forth communication, suppliers should prepare the following data package for each ingredient:
Ingredient-level details ■ All raw materials (listed individually) ■ Origin of each raw material (animal/plant/ mineral/petrochemical/biotech) ■ Details of extraction, synthesis or fermentation processes
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