20 FORMULATION
Figure 1: The multi-hurdle preservation system: robust defence against P. gergoviae adaptation
measure of how often it occurs. It is a measure of how often someone looked.
Why this is in the spotlight The German Federal Institute for Risk Assessment assessed this organism in cosmetics in Opinion 038/2020, updating an earlier 2017 statement. At that point, ten cosmetic products had been notified through the European rapid alert system, RAPEX (now Safety Gate), with confirmed P. gergoviae contamination — at counts between 3×103
and 1.9×107 CFU/g. The upper end of that range is four orders
of magnitude above the ISO 17516 limit of 103 CFU/g for externally applied products, and five above the 102
CFU/g limit applying to products for
children under three, for use around the eyes, or on mucous membranes. The German Federal Institute for Risk
Assessment’s conclusion was clear: externally applied cosmetic products should be free of P. gergoviae. Its second conclusion is the more interesting one. The Institute could not quantify the health risk — not because the risk is small, but because the data do not exist. There is no reliable figure for infectious dose and no epidemiological data on infection rates from cosmetic use. That is an absence of evidence, not evidence of absence.
Not localised but an international trend The European notifications accumulate steadily: a liquid soap in 2017, a cleansing wipe and a hand cream in 2020, the amika shampoo recall in the UK in early 2025, skin cleansing wipes at the end of 2025, and in early 2026 a shower gel and a bulk-dispensed hand soap. The hand soap is worth a second look: its ingredient list is preserved with isothiazolinone — precisely the chemistry Périamé’s group used to select preservative-adapted derivatives in the laboratory. Set that European sequence alongside the US
cases — Jergens in 2022, Neutrogena in 2025, Oribe in 2026 — and the picture stops looking like a series of unrelated incidents and starts looking like a trend.
PERSONAL CARE MAGAZINE September 2026
Other key factors The recall record is not accelerating by accident. Three things are happening simultaneously:
1. The preservative palette is contracting Annex V has been under sustained pressure for well over a decade. Isothiazolinones have been progressively restricted, formaldehyde donors are in commercial retreat, and parabens have been narrowed far more by consumer rejection than by regulation. The net effect is fewer tools and heavier reliance on the few that remain — phenoxyethanol above all. Concentrating the industry’s preservation onto a small number of molecules concentrates selection pressure onto exactly the molecules this organism has a documented history with.
2. Substrates and formats have changed Water-rich, botanically loaded, mild-surfactant systems are more hospitable than what they replaced. Compostable cellulose wipe substrates are a case in point: they retain moisture, provide micro-niches, and adsorb preservative onto the fibre, reducing the free concentration in the water phase where it actually works.
3. Development cycles are faster Reformulating to remove an ingredient, requalify a supplier now happens on timelines that leave stability and preservative efficacy data thinner at launch than they used to be.
The costs when this goes wrong A recall is the worst case, but not the only case. When a batch fails microbial release testing, remediation is expensive, revenue is lost, and plants can be taken offline, with consequences that travel down the supply chain. A recall carries all of those costs and adds public notification, retailer disruption, and reputational damage that outlasts the incident. There is a larger cost, and it is for the beauty
industry. Every batch that ships marginally preserved, every line that keeps running with
a low-level environmental positive, every formulation leaning on a single mode of action contributes to the selection pressure that produces adapted strains. The industry has spent fifteen years arguing
about which preservatives it is permitted to use. It may find that the more consequential question is which ones still work against P. gergoviae.
What to do about it Defeating an adapted organism requires a multi- layered defence. P. gergoviae enters through predictable vectors and survives in identifiable formula gaps—and closing one without addressing the others leaves the backdoor open. The following interventions cover every link in the defence chain.
1. Start with the water P. gergoviae is a water organism. That is where it lives, and that is overwhelmingly where it comes from. Ben Elmadi, technical manager at MSL
Solution Providers put it directly. “One of the biggest sources of contamination can be traced back to water — and is one of the most expensive problems to fix if allowed to fail. Companies should take steps to avoid or resolve such problems early, such as testing the water regularly and then analysing the data to ensure it stays within pre-defined limits,” he says.12 Testing water and filing the result is not
monitoring. Monitoring means trending results against pre-defined alert and action limits so that drift is visible before it becomes a failure. In practice: sample at points of use as well
as at generation; attend to dead legs, low-flow branches, storage vessels and distribution loops where biofilm establishes; and validate sanitisation against biofilm rather than planktonic organisms, because a regime that clears free-swimming bacteria may leave an established biofilm intact.
2. GMP, unglamorously and repeatedly Knowing ISO 22716 is one thing; executing it on
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Photo Credit: Green Chem Finder
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