BUTTER-C
Signature ingredients
White willow bark toner OEM/ODM manufacturing
White Willow Bark Toner · Signature Ingredients · OEM/ODM
Willow bark has a long history as a herbal material: taken by mouth, it is used as a herbal medicine or dietary supplement for pain and fever — a medical setting, not cosmetics. Because willow bark contains salicin, white willow (Salix alba) bark extract is often promoted as a “natural BHA” for oily skin. In fact, salicin is a glycoside with no acid group, not salicylic acid; its conversion to salicylic acid has been described only after it is SWALLOWED, through gut bacteria and metabolism in the body. On the skin, the CIR scientific literature review (September 2025) found no toxicokinetic study on Salix alba-derived ingredients, and we have not found any study measuring salicin conversion to salicylic acid or any exfoliating effect of the extract. The human studies found are all small, mostly test multi-ingredient formulas and include company-affiliated authors — limited evidence. A white willow bark toner is therefore a hydrating, alcohol-free water toner with claims at the level of “gently cleanses, helps skin feel moisture-balanced” (sensory, to be tested on the finished product), in which willow bark extract is the signature ingredient — the right species and plant part, with salicin and free salicylic acid content on the certificate of analysis (COA). Butter-C offers full-service OEM/ODM manufacturing, from formula development and testing to labeled finished product with its notification dossier.
Formula base
White willow bark extract in an alcohol-free hydrating toner base
A toner is almost all water, so every ingredient shows; hydration, clarity and microbial stability are decided by the base, while willow bark extract is the signature ingredient. Unlike the general toner page, this page focuses on the issues that come from the willow bark raw material itself.
White willow bark extract with cyclodextrin
The raw material on file at Butter-C is a blend declared as “Salix Alba (Willow) Bark Extract (and) Hydroxypropyl Cyclodextrin”: the percentage in the formula is the percentage of the commercial raw material, not of dry extract or of salicin, and the label must list both INCI names. The ratio of the two components, extraction solvent, salicin content and the role of the cyclodextrin come from the technical data sheet (TDS) and COA; the internal file currently records both “liquid form” and “powder carrier”, so the actual form must be confirmed with the TDS before formulating.
Hydration and comfort
Glycerin, Butylene Glycol and Betaine hold water in the stratum corneum; Panthenol and Allantoin add comfort; Sodium Hyaluronate or Xanthan Gum give the slightly thickened version. This part carries the product's moisturizing and softening function.
Preservation and pH
Phenoxyethanol (maximum 1.0% — Annex VI Ref 29) with Ethylhexylglycerin; Disodium EDTA because the internal raw material file notes that metal ions discolor the extract; Citric Acid and Sodium Citrate adjust and buffer pH. The general toner page keeps hydrating toners at pH 5.0–6.0; there is no checked source on pH, heat or light for willow bark extract, so the pH is fixed by stability testing.
Points to weigh when choosing
Alcohol-free and fragrance-free for a gentle positioning. Salicylic acid is not added “to justify the BHA wording” and then credited to willow bark: a genuine BHA toner is a different product, with all the conditions of Annex III Ref 98 (see the BHA toner page). This page does not cover mist sprays; CIR notes that the neat extract is predicted to be an eye irritant, so the label says to avoid the eye area.
Key technical points
Four points specific to putting white willow bark into a toner
The issues below come from the raw material itself: salicin is not salicylic acid, composition varies by source, the regulatory position and the impurities to test.
Salicin is not salicylic acid
According to PubChem, salicin (C13H18O7, 286.28 g/mol) is glucose linked to saligenin — 2-(hydroxymethyl)phenol, a phenolic alcohol — so it has no carboxyl group and is not a hydroxy acid; salicylic acid (C7H6O3) is 2-hydroxybenzoic acid. In rats, swallowed salicin is hydrolyzed by gut bacteria to saligenin, which is converted to salicylic acid after absorption (Akao et al., 2002); in 10 healthy volunteers who swallowed an extract equivalent to 240 mg salicin, the serum salicylic acid area under the curve matched only what would be expected from 87 mg of aspirin (Schmid et al., 2001). These are oral data and do not apply to a toner applied to the skin.
Variable composition — the COA decides
The INCI Dictionary (via CIR) lists the bark extract as a hair and skin conditioning agent (occlusive); the “exfoliant” function is listed only for dried, ground bark (Salix Alba (Willow) Bark Powder), not for the extract. CIR cites one methanol bark extract with total salicylates of 1.80 mg/g dry weight, while one supplier states its powdered extract is standardized to 53–65% salicylates. CIR also gives the same CAS number 84082-82-6 for the bark extract and the leaf extract, so the COA must state the species Salix alba, bark as plant part, solvent and the salicin or total salicylate content (HPLC).
Regulation: not listed, not converted to salicylic acid
We searched ASEAN Annexes II, III, VI (version 2026-1) and VII (version 2025-2) for “Salix”, “willow”, “salicin” and CAS 84082-82-6: there is no entry. Annex III Ref 98 names only “Salicylic acid” (CAS 69-72-7), with the sentence “These levels are inclusive of any use of salicylic acid”; Annex VI Ref 3 lists only salicylic acid and six of its salts. Salicin is neither salicylic acid nor one of its salts, so the internal regulatory rule table does not convert the extract's salicylates to salicylic acid. If the COA shows free salicylic acid, that part is added to the Ref 98 limit — a cautious reading that needs regulatory confirmation.
Heavy metals, microbiology and stability
CIR notes that willow trees accumulate heavy metals such as cadmium and lead — the COA should include heavy metals, plus microbiology because the raw material goes into an all-water system. The internal file records the extract as heat- and light-sensitive, added in the cool-down phase, prone to darkening and to discoloration with metal ions — data not independently verified, so Butter-C adds the raw material in the cool-down phase, runs a light-exposure test on the first sample, checks against the TDS, and runs a preservative efficacy (challenge) test to ISO 11930 on the finished product.
Three formulation directions
Three white willow bark toners for three customer groups
Alcohol-free, fragrance-free willow bark – panthenol liquid toner
Water-clear; willow bark extract, glycerin, betaine, panthenol, allantoin. Applied with a cotton pad after cleansing or patted in by hand — for normal and combination skin wanting a light toner with a botanical story.
Slightly thickened willow bark – hyaluronate toner
A low level of Sodium Hyaluronate or Xanthan Gum gives a more nourishing feel for layering. For dry or dehydrated skin in air-conditioned rooms; the trade-off is slower absorption than the liquid version.
Willow bark – niacinamide toner for combination and oily skin
Niacinamide 2–5% as on the general toner page, in an acid-free base; “helps reduce the look of shine” is claimed only once tested on the finished product, and it is a function of the whole formula, not of willow bark. Niacinamide is incompatible with strong acids and alkalis — the pH is fixed by stability testing with niacinamide assay.
Packaging is designed with the formula
Screw caps or small-orifice flip caps limit contamination from fingers; tinted bottles limit light, and clear bottles are used only once the sample has passed light-exposure testing. This page does not cover mist sprays.
Parameters we monitor
What our R&D lab measures on every sample
Below are the parameters Butter-C monitors during formula development and scale-up to production. Specific limits are agreed with you on the approved sample, then written into the product's in-house specification.
- Incoming raw material
- COA of each willow bark lot: species Salix alba, bark as plant part, solvent, extract-to-carrier ratio, salicin or total salicylate content (HPLC), free salicylic acid, heavy metals, microbiology; color and odor against the retained sample.
- Appearance & clarity
- Color, odor and clarity against the reference sample; tracking darkening or haze of the extract across stability checkpoints, including light-exposed samples.
- pH
- Measured directly at 25 °C on every batch; pH drift tracked over time.
- Density & conductivity
- Two quick batch-identity checks for an all-water system, catching mixing errors.
- Stability
- Accelerated aging at 40 °C, freeze–thaw cycling, storage at 4 °C and light exposure in the final packaging; tracking haze, precipitation, color and odor change.
- Niacinamide content
- For the niacinamide version: HPLC assay at the start and after stability testing.
- Microbiology & challenge test
- Finished product tested at a GLP / ISO 17025-accredited laboratory; preservative efficacy (challenge) test to ISO 11930 — mandatory for an all-water system.
- Tolerance
- Patch testing and in-use testing on volunteers before the formula is locked — the CIR literature review has no human patch-test data, while three in vitro tests (on different bark extracts) predicted a sensitization potential.
- Packaging compatibility
- Filled into the actual bottle and cap; tracking seal integrity, material odor, weight loss and light transmission.
Claims
Writing claims within the cosmetic scope
The human studies found are all small: an emulsion with niacinamide, lentil seed extract and white willow bark extract in 30 people with oily skin over 56 days (no control group stated in the abstract; authors from a company R&D center — Yang et al., 2024); a cleanser with hops extract, willow bark extract and disodium cocoyl glutamate versus an SLES cleanser in 21 people, randomized, blinded, half-forehead comparison, with a significant sebum reduction on day 17, after a 48-hour break (Weber et al., 2019 — a multi-ingredient rinse-off product; with a company-affiliated co-author); and a cream with 2% Salix alba bark extract in 29 people over 8 weeks, on under-eye dark circles (no control group stated in the abstract; company authors — Jeon et al., 2023). Results of combination formulas belong to the whole formula; no controlled trial has shown that willow bark extract alone unclogs pores, exfoliates or acts on acne. Annex 03-MP of Circular 06/2011/TT-BYT does not accept drug-like claims. Below are the wordings Butter-C proposes.
Gently cleanses, helps skin feel moisture-balanced
A sensory claim when used with a cotton pad after cleansing; used once tested on the finished product. Instead of: “natural BHA”, chemical exfoliation, loosens dead skin cells, unclogs pores.
Moisturizes, helps skin feel soft
A function of the hydrating base (glycerin, betaine, panthenol, hyaluronate); hydration figures only when measured on the finished product. Instead of: restores skin, mends skin.
Contains white willow (Salix alba) bark extract — a botanical ingredient containing salicin and polyphenols
An ingredient and story claim; the INCI names of the whole raw material blend are stated correctly. Instead of: “natural salicylic acid”, “BHA alternative”, citing multi-ingredient formula results (Yang 2024, Weber 2019) as results of willow bark alone.
Helps reduce the look of shine (niacinamide version)
Only when measured on the finished product itself, as a function of the whole formula. Instead of: oil control, reduces acne, claims to act on acne or bacteria.
Label advice
“Test on a small area of skin before use. Avoid the eye area. Stop use if skin becomes red or stings. People allergic to aspirin or salicylates should ask a doctor before use.” A single case of anaphylaxis has been reported in a person with a history of aspirin allergy after SWALLOWING a dietary supplement containing willow bark among several other active ingredients — the authors rated the link as “probable” (Boullata et al., 2003), and the United States Pharmacopeia (USP) has added a caution — not for children, pregnant or nursing women, or people with known sensitivity to aspirin — to its willow bark monograph for dietary supplement dosage forms (Oketch-Rabah et al., 2019). These are oral settings; exposure from topical use has not been measured — the advice is a precaution, not an ASEAN regulatory requirement.
Pregnancy, young children
For topical use, data are insufficient — the consultation advises asking a doctor. This page is a facial toner for adults. Instead of: safe for expectant mothers, suitable for children.
Manufacturing specifications
Our capabilities
- Texture
- Clear liquid or slightly thickened toner; colorless to the natural pale yellow-brown tint of the extract.
- Format
- Screw-cap or flip-cap bottle. Volume agreed when selecting packaging.
- Minimum order quantity
- Agreed per order — depends on the formula direction and format chosen.
- Testing
- Performed at a GLP / ISO 17025-accredited laboratory, with a certificate of analysis delivered with every batch.
- Documentation
- Product Information File (PIF) and notification dossier prepared by Butter-C, including the full INCI list of the willow bark raw material and the COA for salicin and free salicylic acid.
- Packaging
- Label design, printing and packing run in parallel with formula development; the note for people allergic to aspirin or salicylates is laid out from the first label draft.
Suggested product concept
Alcohol-free, fragrance-free white willow bark – panthenol toner for normal to oily skin
A product concept to help you picture the result, not a ready-made product for sale. The actual formula is developed around your brand's positioning and price range.
White willow bark extract
Raw material level per the TDS, related back to the salicin content on the COA; the CIR survey recorded the extract at 0.00003–0.5% in US formulas — a market reality, not an effective level.
Glycerin, Betaine, Panthenol, Allantoin
The hydrating and comfort group — the basis for moisturizing claims once tested on the finished product.
Alcohol-free, fragrance-free, no salicylic acid
A short ingredient list; the willow bark story is told accurately, without borrowing the word “BHA”.
150 ml screw-cap bottle
Used with a cotton pad or poured into the hand; the label carries the patch-test advice, avoid the eye area, and ask a doctor if allergic to aspirin.
Customization options
What you can specify
The same product type can serve very different customer groups. Tell us your requirements in the areas below and our pharmacists will develop the matching formula.
Texture and use
Water-thin or slightly thickened; cotton pad or patted in by hand.
Companion ingredients
Panthenol, Allantoin, Betaine, Sodium Hyaluronate, Niacinamide — chosen for the target skin type and pH range.
If you want a genuine BHA
Switch to the BHA toner direction: total salicylic acid ≤ 2.0% under Annex III Ref 98, with all the conditions attached to that entry; the effect on surface skin cells then comes from salicylic acid, and willow bark is only a story ingredient.
Willow bark story on the label
Willow branch imagery and the history of salicin as a story; growing region only when the supplier has documentation.
Target users
Normal, combination or oily skin — decides the formulation direction and the tolerance testing needed.
Ingredient positioning
Alcohol-free, fragrance-free, vegan — please state these at the start so suitable raw materials are selected; “organic” only with certification for the ingredients and the formula.
Further reading
Related knowledge
White willow (Salix alba) bark in cosmetics
How salicin differs from salicylic acid, limited evidence, safety and ASEAN regulation (in Vietnamese).
Toner manufacturing
General page: hydrating, balancing and exfoliating toners.
BHA salicylic acid toner manufacturing
A toner with genuine salicylic acid within the Annex III Ref 98 limit — the direction to choose when you want BHA performance.
Witch hazel toner manufacturing
A toner named after another botanical, with the same gentle-cleansing, sensory claim level.
Salicylic acid (BHA) in cosmetics
Mechanism, evidence, ASEAN Annex III limits and safety notes for genuine BHA (in Vietnamese).
Oily skin and enlarged pores
The role of sebaceous glands, ingredients with data and common misconceptions (in Vietnamese).
How we work
From idea to finished batch
Eight steps and three milestones signed off by both sides: approved sample, notification number, finished batch. Step-by-step details (in Vietnamese) →
Get started
Tell us about the product you plan to launch
Send us your product direction and expected volume. Our team will get back to you during business hours (Vietnam time, GMT+7).
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