Haircare formulation in New Zealand and Australia follows the same route as skincare — brief, bench work, stability testing, compliance, then small-batch manufacturing — but the chemistry is different. Shampoos are surfactant systems, conditioners are cationic emulsions, and both are judged on sensory performance. Expect 4–12 months and MOQs from 100–500 units.
What makes haircare formulation different from skincare?
Most indie founders arrive with skincare instincts and get surprised. A serum is judged on what it does over weeks. A shampoo is judged in the first fifteen seconds — how fast it lathers, how the foam feels, whether hair squeaks or slips when rinsed.
That changes what we optimise for at the bench:
- Shampoos are built around a primary surfactant (sodium coco-sulfate, sodium lauryl ether sulfate, or sulfate-free options like sodium cocoyl isethionate) plus a secondary surfactant such as cocamidopropyl betaine or decyl glucoside to soften the cleansing and boost foam.
- Conditioners are cationic emulsions — behentrimonium methosulfate or cetrimonium chloride paired with fatty alcohols like cetearyl alcohol. The positive charge is what makes conditioner deposit onto damaged, negatively charged hair.
- pH targets are tighter. Shampoos usually sit at pH 4.5–5.5; conditioners lower still, around 3.5–4.5, to help close the cuticle and keep cationics performing.
None of that is exotic, but it is a genuinely separate skill set from emulsion skincare. If your manufacturer has never run a salt curve, that is worth knowing before you commit.
Can you make a sulfate-free shampoo that actually works?
Yes — with honest expectations. Sulfate-free surfactants are milder and increasingly what NZ and AU consumers ask for. The trade-offs are real: lower flash foam, more expensive raw materials, and a system that will not thicken with salt the way a sulfate-based shampoo does.
Sulfate-free formulas usually need polymeric thickening — xanthan gum, hydroxyethylcellulose, or acrylates copolymers — which behaves differently under shear and takes longer to dial in. Budget extra bench time rather than extra disappointment. We would rather tell you this at the discovery call than at batch three.
What can you legally claim on a haircare product in NZ and Australia?
This is where haircare founders most often trip.
In New Zealand, cosmetics — explicitly including shampoo and hair dye — are regulated by the EPA under the Cosmetic Products Group Standard 2020. An updated version of that standard took effect on 1 January 2026, so any formula and label work should be checked against the current consolidated document rather than an older copy.
In Australia, ingredients are regulated as industrial chemicals by AICIS. If you import or manufacture, you must register your business with AICIS before you introduce product, and submit an annual declaration of the chemicals you introduced. "Natural" and "organic" ingredients are still industrial chemicals for this purpose.
Anti-dandruff products sit in a grey zone worth understanding. Under Australia's Therapeutic Goods (Excluded Goods) Determination 2018, an anti-dandruff hair product can be sold as a cosmetic if it is presented as controlling or preventing dandruff only through cleansing, moisturising, exfoliating or drying the scalp. Step beyond that — treatment claims, or actives outside the excluded scope — and you are into TGA territory, with a very different cost and timeline.
One more export consideration: zinc pyrithione, the classic anti-dandruff active, is now prohibited in cosmetics in the EU after its CMR classification, while remaining available in Australia and the US. If the EU is on your five-year map, choose your active accordingly. We cover the wider picture in our guides to cosmetic compliance for Australian brands and labelling requirements in NZ and Australia.
How is haircare tested before launch?
Shampoos and conditioners are high-water, nutrient-rich systems, which makes microbial control the first priority — and preservative choice harder, because many preservatives lose performance in anionic surfactant systems.
A launch-ready haircare product typically needs:
- Preservative efficacy (challenge) testing to ISO 11930 — NZ$1,200 per formula. Non-negotiable for anything water-based.
- Accelerated stability testing, usually across 12 weeks at multiple temperatures, watching for phase separation, viscosity drift and pH movement. See our stability testing guide.
- Packaging compatibility — surfactants are aggressive toward some closures and pumps, and fragrance can migrate into plastics.
Viscosity deserves a specific warning. A shampoo that is perfect at 500g on the bench can come out thin or gel-locked at 200kg, because salt curves and thickener hydration behave differently at scale. Scale-up trials are part of the process, not an optional extra.
How long does it take and what does it cost?
At The INCI Lab, haircare runs through the same pathways as the rest of our work:
- Ask The Chemist — a 30-minute consult, $150. Good for sanity-checking a supplier's formula or a claim before you spend more.
- The Accelerator — 4–6 months, starting from $2,000–$5,000. A semi-custom route for founders who want a strong shampoo or conditioner to market quickly.
- The Visionary — 9–12 months, starting from $4,000. Bespoke development from scratch, with full IP transfer to you before manufacturing.
Manufacturing MOQs start at 100–500 units depending on the route and packaging. We are cruelty-free, and can formulate vegan, fragrance-free and organic-capable haircare. You can compare all four routes on our services overview.
Frequently asked questions
Do I need separate compliance work for New Zealand and Australia?
Yes. New Zealand works to the EPA's Cosmetic Products Group Standard 2020, while Australia requires AICIS registration and annual declarations. The formula is often identical; the paperwork is not. We prepare documentation for NZ, AU, EU and US markets as part of the formulation process.
Can I make a shampoo bar instead of a liquid?
Yes, and they are a genuinely different formulation exercise — solid surfactant systems built around sodium cocoyl isethionate or similar, with binders and fatty materials. Bars avoid preservative challenges but introduce hardness, lather and dissolution-rate problems instead. Worth briefing early.
Can I claim my shampoo promotes hair growth?
Almost certainly not as a cosmetic. Hair growth and regrowth claims are therapeutic in both markets and move you out of cosmetic regulation. Cosmetic-acceptable language stays with appearance, condition, cleansing and scalp comfort.
Who owns the haircare formula at the end?
On The Visionary pathway, you do — full IP transfer before manufacturing. On The Accelerator, IP is shared and you own the finished SKU. We put this in writing before bench work starts, because it is the single thing indie founders most often discover too late.
Do you formulate haircare for pets?
We do — see our guide to pet grooming product formulation in NZ and Australia. The surfactant chemistry overlaps, but pH targets, fragrance limits and regulatory routes differ.
What should I bring to a first haircare conversation?
Hair types you are formulating for, three products you admire and why, your target price per unit, whether sulfate-free and silicone-free matter to your customer, and which markets you want to sell into. That is enough for us to give you a realistic route and timeline.
Where to start
Haircare is a category where indie brands can still differentiate on real formulation quality rather than packaging alone — most of the shelf is built on the same handful of templates. If you have a shampoo, conditioner or scalp product in mind, start a conversation with us and we will tell you honestly which pathway fits, what it will cost, and how long it will actually take.
