Ingredient Compliance — Knowing What Can Go In Your Product, and at What Level

The ingredient lists are long. The restrictions are specific. And UK and EU lists are diverging. Ingredient compliance is where formulation decisions become legal decisions.

Cosmetics ingredient regulation is one of the areas where post-Brexit divergence between the UK and EU is most pronounced and most consequential. The UK is maintaining and updating its own Annexes to the retained Cosmetics Regulation. The EU continues to implement SCCS opinions. The two are no longer moving in lockstep.

A formulation that is compliant in both markets today may not be compliant in both markets in 18 months. Brands that are not monitoring this are building on a foundation that is quietly shifting beneath them.

What It Costs to Get This Wrong

A product containing a prohibited substance cannot legally be sold. It does not matter how long it has been on the market, how well it sells, or how many batches have already been shipped. When an authority finds the non-compliance, the product comes off shelf. In some cases, the Responsible Person faces legal liability.

In some cases, products remain on the market after regulatory changes without being reassessed against updated annexes. This can lead to compliance gaps if ingredient restrictions or conditions of use have changed.

What the UK and EU Ingredient Frameworks Cover

Annex II: Prohibited substances. Substances listed in Annex II are not permitted for use in cosmetic products in that market, subject to the specific scope and conditions set out in the regulation.
Annex III: Restricted substances. These substances may be used only under defined conditions, including concentration limits, product type restrictions, and specific labelling requirements.
Annex IV: Permitted colourants. Only colourants listed in Annex IV may be used in cosmetic products, subject to any conditions of use.
Annex V: Permitted preservatives. Preservatives used in cosmetic products must be listed in Annex V and comply with the specified conditions, including maximum concentration limits and product-type restrictions.
Annex VI: Permitted UV filters. UV filters used in cosmetic products must be listed in Annex VI and used in accordance with defined concentration limits and conditions of use.
Scientific assessments. In the EU, the Scientific Committee on Consumer Safety (SCCS) issues opinions on individual ingredients, which inform regulatory decisions and updates to the annexes. Ingredients under review may be subject to future restrictions or amendments.

What Arcus Does

We review product formulations against current UK and EU ingredient requirements, identifying restricted or prohibited substances and advising on applicable concentration limits, conditions of use, and labelling requirements.

We also monitor regulatory developments. Where ingredients are under scientific review or subject to potential regulatory change, we provide early visibility to support forward planning.

Review Your Formulation