Hypochlorous acid is THE new product taking the skin care industry by storm. It has been shown to treat a wide range of skin complaints including acne, psoriasis and eczema as well as being an effective cleanser and toner but in the UK there are strict rules and regulations about how you market it and what you can and can’t say on the label.


Firstly, what is hypochlorous acid?

Hypochlorous acid is a weak acid (a chemistry term for acid with a low pH level — think citric acid) with strong antimicrobial properties.

It is naturally produced by the human immune system to fight infection but is produced commercially by the electrolysis of salt and water to produce what is classed as a biocide. It’s power and application potential is astonishing;

  • It is over 100 times more powerful than bleach yet is as gentle as water on the skin
  • It kills 99.99% of bacteria and 99.9% of viruses
  • It has been proven to kill coronaviruses
  • It works in seconds, unlike many other biocides that can take up to 10 minutes to be effective
  • It is pH neutral so is non-sensitising and non-irritating to skin.

Due to it being better and faster than competitive disinfectant and by also being pH neutral, its popularity has grown exponentially for surface disinfection in facilities and healthcare environments and also for hand hygiene as an alcohol-free caring alternative to alcohol gels.


Can it be used on skin?

Yes but there are rules and regulations that we’ll come on to below. However, skin experts do actually recommend using products with hypochlorous acid to fight common bacterial skin problems like acne, eczema, and psoriasis. It basically disinfects your face, reducing inflammation and speeding up your skin’s natural healing processes.

However, it is not its efficacy that is the issue, more the rules and regulations in the UK that are the problem.


Hypochlorous acid skin care rules and regulations – Europe

Hypochlorous acid is fully approved as an active substance for PT1 use (skin care) in Europe if sourced by a manufacturer approved on Europe’s Article 95, although individual brands currently need local authorisation to sell in each country. ECHA is currently working through individual product authorisations for EU-wide approval which we expect to be completed in 2024.


Hypochlorous acid skin care rules and regulations – UK

Due to the impact of Brexit, whilst hypochlorous acid is an approved active substance for other applications, it is not currently authorised in the UK for Pt1 use which impacts any brand wishing to launch a hypochlorous acid based skin care product.

Currently, (Feb 2023) the only way to legally launch or sell a hypochlorous acid skin care product in the UK is to not market it as a biocide but seek “cosmetic authorisation” instead.

With cosmetic authorisation, you are unable to make any biocidal claims e.g you can’t claim that it kills bacteria or viruses on the skin, however you may be able to claim that is cleanses or refreshes and that it has anti-microbial properties.


How can Aqualution help

Aqualution manufactures skin care products for a range of uses and for a number of brands. Our hypochlorous is the purest on the market at 150ppm and with a pH of 7.2 and therefore ideal for use on the skin.

We can help guide you on the rules and regulations as well as support you on label design and appropriate claims.


How to pick the right hypochlorous acid product checklist 

Some top tips to ensuring that you are getting the best hypochlorous acid for your brand:

  • Only use hypochlorous acid that is manufactured by a company listed on Article 95
  • Ensure that you are guided on regulations in your market
  • Use only black HDPE bottles to ensure efficacy and shelf life of the HOCl
  • Be wary of manufacturers that say they treat any specific skin condition
  • Check that you are not being sold bleach
  • Speak to Aqualution who can advise on the best products for your needs.