CPSR for Body Scrubs: Sugar, Salt and the Shower Problem

Here is a call we get more often than you would think. A small maker's coconut-oil sugar scrub, with brown sugar, a little vitamin E and a vanilla fragrance, has grown grey-green spots at the bottom of a customer's jar, six weeks after it was opened. The maker is baffled: there was no water in the recipe, and every forum she had read said anhydrous products don't need preserving. Both of those things are true. The scrub has still spent six weeks in a steamy shower being scooped out with wet fingers. That gap between the formula sheet and the bathroom is what a CPSR for body scrubs is really about.

This guide walks through what a safety assessor looks at for sugar, salt and other body scrubs under the UK and EU rules: the water problem, what sugar and salt can and cannot do, testing, exfoliant particles and the microbead bans, the slip risk, packaging and the period after opening. If you sell a scrub in an open jar, the packaging section will probably save you the most money.

What a body scrub safety assessment covers

A body scrub is a rinse-off cosmetic, so it needs the same report as anything else: a CPSR in the format set out in Annex I of Regulation (EC) No 1223/2009. In Great Britain that is the retained regulation as amended by Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 and enforced through the Cosmetic Products Enforcement Regulations 2013. The EU applies the original regulation directly. Part A collects the evidence and Part B is the assessor's conclusion, warnings and reasoning; our guides to Part A and Part B go through every section.

For a scrub, a handful of Part A sections do most of the work:

• Microbiological quality. Will the product stay clean once real people use it?
• Stability and packaging. Does the oil go rancid, does the salt attack the lid, does the pack let water in?
• Normal and reasonably foreseeable use. Wet hands, a hot shower, freshly shaved legs, a teenager borrowing it for their face.
• Exposure. How much is used and how much stays on the skin after rinsing.
• The exfoliant itself. What it is made of, how big and how sharp it is.

The Commission's guidelines on Annex I (Implementing Decision 2013/674/EU) spell out what each section should contain, and the GB regulator, OPSS, points assessors to the same principles in its guidance on the GB regulation.

Anhydrous in the jar, wet in the shower

A sealed jar of sugar scrub on a shelf is stable. Trouble starts with the first use. The customer opens it with wet hands, scoops some out, and leaves a few drops of water behind. The lid goes back on and the jar sits in a humid room, so the water doesn't dry out. After twenty or thirty uses it has built up. Water is heavier than oil, so it sinks through the oil and collects at the bottom against the sugar, in a warm, dark spot with plenty of nutrients. That is where the spots appear, and why customers usually find them when the jar is half empty.

So an assessor won't sign off "no preservative needed" just because no water went into the batch. The question is how much water the product will meet during its life. For an open jar in a shower, the honest answer is quite a lot.

Water activity: what sugar and salt really do

Microbes need available water, measured as water activity (a_w) on a scale from 0 to 1. Pure water is 1.0. Below about 0.6 essentially nothing grows, and ISO 29621, the standard used to identify microbiologically low-risk cosmetics, treats a water activity under 0.75 as one of the signs of a hostile product. A dry mix of sugar and oil sits comfortably below that.

The catch is what happens to water that gets in. Sugar and salt dissolve in it and lower its water activity, but only so far. A fully saturated sugar solution is still around 0.85, and a saturated salt solution about 0.75. Plenty of moulds and yeasts grow at 0.85. And the water pooling at the bottom of a used jar is rarely saturated, so the real figure there is higher. The product doesn't have to be wet all the way through to spoil. One wet corner is enough.

In the jar	What makers expect	What actually happens
Sugar	Preserves it, like jam	Lowers water activity in the water it dissolves in. A saturated sugar solution is still around 0.85, and pooled water is rarely saturated.
Salt	Preserves it, like curing	A saturated salt solution reaches about 0.75 at best. Salt also corrodes metal lids and stings broken skin.
Oil phase	Seals water out	Water is heavier than oil, so it sinks underneath and sits against the sugar or salt.
Coconut oil	Antimicrobial	Not at a level or in a form that protects a contaminated product.
Essential oils	Natural preservative	At cosmetic levels they mainly add scent and allergens.

Preserve it or keep the water out: your three options

Once the assessor has explained the water problem, there are three ways forward, and any one of them can work:

1. Preserve the scrub and prove it. Add a preservative that works in an oil-based product which later picks up water, then show it works with a challenge test on a water-diluted sample. Check our guide to Annex V preservatives for what is permitted and at what level.
2. Change the pack so water can't get in. A wide-mouth tube or a jar used with a dry spatula and clear directions cuts water ingress dramatically. ISO 29621 itself recognises that packaging which stops contamination can make a product low risk in use.
3. Go single use. Sachets or pods used once and thrown away never meet a second wet hand.

What usually doesn't work is the combination we see most often: an open jar, no preservative and a 12-month period after opening.

Testing an anhydrous scrub properly

A standard challenge test (preservative efficacy test, usually run to ISO 11930) adds known bacteria, yeast and mould to the product and checks whether their numbers fall over 28 days. Run that on a dry scrub and the organisms have no water to grow in, so the product passes without proving anything about the jar in the shower.

The fix is to add water first. Labs call it a spiked, diluted or in-use challenge test. A set percentage of water is mixed into the sample before inoculation, to mimic a jar that has been used for a few weeks, and then the test runs as normal. There is no single official protocol for the water level, so agree it with your assessor before you book. A pass on the dry product will usually be sent back.

Water-containing scrubs are simpler. A gel scrub or a creamy emulsion scrub with water in the formula is assessed like any other water-based product, with a standard challenge test and normal stability testing.

How exposure is worked out for a rinse-off scrub

For each ingredient, the assessor estimates how much reaches the skin and compares it with the safe level for that substance. The SCCS Notes of Guidance (12th revision) give default figures for common product types. Body scrubs don't have their own entry, so assessors usually borrow the shower gel values: 18.67 g used per day with a retention factor of 0.01, meaning 1% is assumed to stay on the skin after rinsing.

That shortcut needs some thought for scrubs. The amount is generous, since most people scrub two or three times a week rather than daily. But the retention factor can be too kind. An oil-rich scrub is sold on the soft, oiled feel it leaves behind, so more of the oil and anything dissolved in it, such as fragrance, stays on the skin than with a foaming gel. A careful assessor will say which figures were used and why, and may use a higher retention factor for oil-soluble ingredients. If your report just copies the shower gel line without comment, ask about it.

Fragrance is where this matters most. Allergens must be named on the label above 0.01% in a rinse-off product. In the EU, Regulation (EU) 2023/1545 added 56 more allergens to the list: products placed on the market from 31 July 2026 must comply, and products already on the market before that date can be sold until 31 July 2028. Great Britain has not adopted the longer list at the time of writing (October 2026), but an EU-style list on a GB label is accepted. Our allergen labelling guide has the details.

Exfoliant particles and the microbead bans

Plastic microbeads used to be the default scrub particle. They are now banned almost everywhere you are likely to sell:

• Great Britain: the Environmental Protection (Microbeads) (England) Regulations 2017 banned their use in making rinse-off personal care products from 9 January 2018 and their sale from 19 June 2018. Scotland's 2018 Regulations took effect on the same day, Wales followed on 30 June 2018 and Northern Ireland made its own regulations in 2019.
• EU and Northern Ireland: the REACH microplastics restriction, Regulation (EU) 2023/2055, banned synthetic polymer microparticles used to exfoliate, polish or clean from 17 October 2023 with no transition period. Other rinse-off uses of microplastics follow from 17 October 2027. Northern Ireland follows EU REACH under the Windsor Framework.
• United States: the Microbead-Free Waters Act stopped manufacture of rinse-off cosmetics with plastic microbeads from 1 July 2017 and interstate sale from 1 July 2018.

The wider EU microplastics phase-out has no GB equivalent yet, but the 2018 microbead ban already rules out plastic exfoliants in GB rinse-off products. Our microplastics and glitter guide covers the full EU timetable.

Natural exfoliants solve the plastic problem and bring their own questions. Sugar and salt dissolve as you use them, so they start gritty and finish gentle. Ground walnut shell, apricot kernel and pumice don't dissolve and can have sharp, irregular edges that scratch, which matters on freshly shaved legs. Coffee grounds, oats, rice powder and jojoba beads all behave differently again. The assessor wants the particle type, size range, hardness and shape, and the body area it is meant for. Check "biodegradable" beads too: ask the supplier for a written statement that they are not synthetic polymer microparticles under 2023/2055, because some are chemically modified polymers that still fall inside it.

Scrubs meant for the face are judged more strictly on all of this. If you are also making one, our guide to facial scrubs and exfoliants covers it, and lip scrubs have their own rules because some of the product gets swallowed.

The slip hazard nobody photographs

Most body scrubs are 30 to 60% oil, and that oil ends up on the shower tray or bath. A fall is far more likely to hurt a customer than anything in the formula, and it is the risk makers forget most often. Part B of a scrub CPSR normally includes a warning along the lines of "Take care, the product may make surfaces slippery". Under Article 19(1)(d) precautions for use have to be on the label, so that warning goes on the artwork, not just in the report.

A line in the directions telling customers to rinse the shower tray afterwards costs nothing, and it is much better than them finding out the next morning. Salt scrubs usually also carry "Do not use on broken or irritated skin", because salt on a shaving nick stings.

Packaging is part of the safety case

Pack	How much water gets in	Usual assessor outcome
Wide-mouth jar	A lot: wet fingers at every use	Preservative plus water-challenge test; shorter PAO
Jar with a spatula	Less, if customers use it	Helps, but rarely enough on its own
Wide-mouth squeeze tube	Very little	Often the best compromise for a thick scrub; may allow a preservative-free formula
Pump	Very little	Particles tend to block it, so rarely practical
Single-use sachet	None after opening	Preservation question largely disappears

Moving from a jar to a wide-mouth tube is the most effective single change a scrub brand can make. It costs a few pence more per unit, cuts off the main contamination route, usually earns a longer period after opening, and is often cheaper than a preservative system plus testing. Brands push back because jars photograph better. That is a fair commercial point, but it is worth weighing against a product that spoils before the customer finishes it.

If you stay with a jar, choose a closure that seals well and a lid that won't rust. Salt and metal lids don't mix, and corroded lids turn up in assessment photos more often than you'd think.

Emulsified, whipped and salt scrubs

Emulsifying scrubs contain an emulsifier so the oil rinses off the skin and the shower floor instead of coating them. That helps a lot with the slip problem. It doesn't help with water: the emulsifier lets water that gets into the jar disperse through the product rather than sitting on top, so the preservation question stays.

Whipped scrubs, where butters and oils are whipped into a mousse, hold a lot of air. More air means faster oxidation, so the period after opening may be limited by rancidity rather than microbes. An antioxidant such as tocopherol helps, and so does a tube.

Scrubs with added water, such as gel scrubs or "milky" emulsion scrubs, are no longer anhydrous at all. They are assessed as water-based products with a standard challenge test, just like a shower gel.

Setting the period after opening

Scrubs usually get a shorter period after opening than makers expect. In our experience, an open-jar scrub with a preservative and a passed water-challenge test often lands at around 6 months. A tube or sachet can support 12. For an unpreserved jar product, the assessor will either refuse a positive conclusion or set a very short period with strict directions about keeping water out, which few customers will follow.

The rules on the label are simple. If the scrub has a minimum durability of more than 30 months, it carries the open-jar PAO symbol; if 30 months or less, it needs a "best before end of" date instead. Most natural oil scrubs fall into the first group on paper, but the PAO is where the real-life limit shows. Our PAO and best-before guide explains both. Match the pack size to the PAO as well: a 500 g jar with a 6-month PAO will still be in the bathroom after it has expired.

A worked example: the coconut-oil sugar scrub

Take a scrub like the one at the start, a composite of the small-batch scrubs we assess most often: 60% brown sugar, 38% fractionated coconut oil, 1% vitamin E and 1% fragrance, in a 250 ml glass jar with a metal lid. Here is how a sensible assessment of it goes.

• Preservation: the maker adds a preservative suitable for an anhydrous system and runs a challenge test on a sample with water added, at a level agreed with the assessor beforehand (10% is a common choice).
• Packaging: the main retail version moves to a 200 ml wide-mouth tube. The jar is kept for a gift set, with a plastic lid instead of metal and a small spatula in the box.
• Fragrance: the IFRA certificate and allergen breakdown show linalool and coumarin above 0.01% in the finished scrub, so both go on the ingredient list.
• Part B: if the test passes, something like 6 months PAO for the jar and 12 for the tube, a slip warning on both and a note to avoid broken skin.

The extra cost is one preservative, one challenge test and a packaging change. That is a lot cheaper than a batch recall and a run of one-star reviews with photos.

What to send your assessor

• The full formula with percentages, including anything that could carry water (honey, aloe, hydrosols, botanical extracts in glycerin).
• The exfoliant: type, particle size range and supplier specification, plus a statement that it is not a synthetic polymer microparticle.
• Packaging details, including the closure and whether a spatula is supplied.
• Directions for use, including anything about keeping water out of the jar.
• The challenge test report (with the water level used) if the scrub is preserved.
• Stability data, ideally including warm storage that mimics a bathroom.
• The fragrance IFRA certificate and allergen breakdown.
• Draft label artwork with the slip warning.

Get those together and a body scrub CPSR is quick and predictable. Phoenix assesses sugar, salt and natural exfoliant scrubs every week, and you can order a CPSR or cover a whole scent range in one go. If you sell salts too, see our guide to bath salts, and for leave-on oils our guide to body butters and oils.

Related reading on the Phoenix blog

• What is a CPSR? The UK and EU guide
• CPSR for facial scrubs and exfoliants
• CPSR for lip scrubs
• Cosmetic challenge testing explained
• Microplastics and glitter in cosmetics
• PAO symbol and best-before dates
• Mandatory label warnings in the UK and EU

Myths we hear

• No added water means no preservative. The test is the water the product meets in use, and a jar opened with wet hands in a shower gets plenty of it.
• Sugar preserves the scrub, the way it preserves jam. Jam is cooked, sealed and very high in sugar throughout. Water pooling at the bottom of a scrub jar is dilute sugar water, which mould likes.
• Coconut oil and essential oils are natural preservatives. At the levels used in a scrub they scent and soften. They do not protect a contaminated jar, and essential oils add allergens to declare.
• A standard challenge test on my dry scrub proves it is fine. On a dry sample the microbes have nothing to grow in, so the pass tells you nothing about the jar in the shower. Water has to be added first.
• Natural exfoliants are automatically gentle. Crushed shells and kernels can have sharp edges. Fine sugar is gentle; ground walnut shell on freshly shaved legs is a different story.
• A bigger jar is better value for the customer. Not if the period after opening runs out halfway down the jar.

What to do this week

1. Decide where the scrub will live: open jar, wide-mouth tube or single-use sachet.
2. If it stays in a jar, pick a preservative suited to an oil-based product and book a challenge test on a water-diluted sample.
3. Ask your exfoliant supplier for a written statement that the particles are not synthetic polymer microparticles.
4. Check that the particle size and hardness suit the body area on your label.
5. Add a slip warning and "avoid broken or irritated skin" to your label artwork.
6. Get the fragrance IFRA certificate and allergen breakdown, and check them against the EU list if you sell there.
7. Match the jar size to a realistic period after opening.

Frequently asked questions

Official sources and legislation

• Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
• Regulation (EC) No 1223/2009, Annex I: Cosmetic Product Safety Report, GB version (legislation.gov.uk)
• Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, Schedule 34 (legislation.gov.uk)
• Cosmetic Products Enforcement Regulations 2013 (legislation.gov.uk)
• Commission Implementing Decision 2013/674/EU: guidelines on Annex I (EUR-Lex)
• SCCS Notes of Guidance for the testing of cosmetic ingredients and their safety evaluation, 12th revision
• Commission Regulation (EU) 2023/2055: REACH restriction on synthetic polymer microparticles (EUR-Lex)
• Commission Regulation (EU) 2023/1545: fragrance allergen labelling (EUR-Lex)
• Environmental Protection (Microbeads) (England) Regulations 2017 (legislation.gov.uk)
• Environmental Protection (Microbeads) (Scotland) Regulations 2018 (legislation.gov.uk)
• GOV.UK: microbeads ban comes into force
• OPSS: Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 in Great Britain (GOV.UK)
• FDA: Microbead-Free Waters Act FAQs