Free from claims are among the most common things printed on a cosmetic pack, and among the least informative. The reason is simple. A product can advertise being free from something it would never have contained in the first place, given what it is and how it is made. The absence is real. It just was never a decision.
Take the general shape of it. A water based product advertising the absence of an ingredient only ever used in oil based products is telling you something true and useless. So is a product advertising the absence of a material that is not used in that category by anyone. The claim reads as a considered choice, and functions as one in the mind of the reader, while describing nothing that distinguishes the product from its competitors.
There is also a regulatory line here that is worth knowing. Under the common criteria that govern cosmetic claims in the European Union, a claim cannot be based on legal compliance. Following the law is the baseline for every product on the shelf, so it cannot be presented as a feature of one of them. In practice that means advertising the absence of an ingredient that is not permitted in cosmetics is not allowed, because every compliant product on the shelf is in exactly the same position.
It is important to be careful about what all this does and does not imply. Nothing here suggests that any legally permitted ingredient is a problem. Ingredients permitted for use in cosmetics have been assessed for that use, and a product containing them is not lesser for it. The issue with free from claims is not the ingredients they name. It is that the claim is doing persuasive work without carrying information.
The same logic applies to our own decisions. Our first product contains no fragrance and no alcohol. Those are real absences with practical consequences, and we can explain why each one was decided. That is different from assembling a list of absences chosen because they sound reassuring, and it is a difference worth holding onto even when the longer list would be easier to print.
The test we apply is whether the absence changes what the product is, and whether we can explain the reason without implying anything about products that made the other choice. If it fails either half, it does not go on the label.
We would rather tell you what is in it than list what is not.