One definition of a chemical is a substance that has had its molecular structure altered by a process. Therefore virtually any substance that has been extracted or mixed could be called a chemical. However, the common usage of the word chemical refers to something that has been synthetically manufactured or has been highly refined and is a long way from its natural state. That is not true of any of the ingredients we use.
Therefore, although we are not allowed to say our products are chemical-free, by all common usage of the word in this context, they are.