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The Reformulation Countdown: EU’s New Retinol Safety Rules Rapidly Approach

Published August 26, 2025
Published August 26, 2025
Sayan Majhi via Unsplash

Key Takeaways:

  • EU regulations demand reformulation of anti-aging and brightening products as deadlines fast approach. 
  • Endocrine disruptors remain central to evolving European cosmetic safety rules.
  • Agile brands leveraging alternatives strengthen compliance and consumer trust.

The European Union’s (EU) tightening of cosmetic safety rules has been on the industry radar since the adoption of Commission Regulation (EU) 2024/996 in April 2024. At the time, BeautyMatter reported on the sweeping changes targeting vitamin A derivatives, skin lightening agents, antimicrobial, and UV filters. With key compliance deadlines now fast approaching, here’s a recap and reminder for brands: what’s changing, when it takes effect (if not already), and why reformulation strategies can no longer be placed on hold.

Vitamin A: Retinol Reined In

Commonly used for anti-aging and acne treatment, retinol (and its “cousins” retinyl acetate and retinyl palmitate) are now tightly regulated.  

  • Limits: Maximum 0.05% retinol equivalent (RE) in body lotions and a maximum of 0.3% RE in all other leave-on and rinse-off products. 
  • Mandatory labeling: “Contains vitamin A. Consider your daily intake before use.”

As the Scientific Committee on Consumer Safety (SCCS) warned, although cosmetic contributions to vitamin A exposure are low, they can be meaningful for the 5% of consumers already near the upper intake limit from diets and supplements.

Bright Spot or Big Risk?

The EU is tightening control over popular brightening agents. 

  • Alpha-arbutin: Allowed a maximum of 2% in face creams and 0.5% in body lotions. 
  • Arbutin: Allowed a maximum of 7% in face creams, and hydroquinone (if present) must stay at unavoidable trace levels. 
  • Kojic acid: Restricted to 1% in face and hand products only. 

Endocrine Disruptors Join the List

The SCCS placed new limits on plant-derived isoflavones. 

  • Genistein: Allowed a maximum of 0.007%. 
  • Daidzein: Allowed a maximum of 0.02%. 

These isoflavones are now part of Annex III of the EU Cosmetics Regulation, meaning that they are strictly regulated across all EU cosmetic categories.

Complete Ban on 4-Methylbenzylidene Camphor (4-MBC)

The previously approved ultraviolet filter is now banned in EU markets. 

  • Ban began: May 1, 2025.
  • Market withdrawal deadline: May 1, 2026.

Antimicrobials: Triclosan and Triclocarban Curbed

Although not banned, these preservatives now face new limitations. 

  • Triclosan: Allowed up to 0.3% in certain products, including soaps and powders. However, it is not authorized for mouthwash or toothpaste for children under three and must carry label warnings. 
  • Triclocarban: Allowed a maximum of 0.2% in cosmetics (not including mouthwash) and up to 1.5% in rinse-off products if not used as preservatives. Prohibited in toothpaste for children under six, with warning labels required. 

Product Exit and Reformulation Scheduling

The industry faces phased deadlines. 

  • Retinol derivatives: The new limit applies from November 1, 2025, and products must be off the market by May 1, 2027. 
  • Alpha-arbutin and arbutin: The product deadline to comply was February 1, 2025, and all noncompliant versions must be pulled by November 1, 2025. 
  • Trisclosan/Triclocarban: Placement deadline of December 31, 2024, already passed, sold-through deadline of October 31, 2025, approaching. 

Industry Impact

Instead of outright banning retinol, the EU opted to dramatically lower the allowable concentrations. With current market offerings allowing up to 1%, come November, brands will have to face full reformulations to align with Regulation (EU) 2024/996.

Notably, some brands have already made a shift in order to prepare for the upcoming deadlines.  IINKEY confirmed to BeautyMatter it has begun offloading noncompliant retinol stock to North America; however, this has been described as an “expensive exercise." Additionally, the brand has been working on a solution for two years to not only align with regulations, but to increase current offerings performance.

Additionally, Medik8 discontinued two of six EU retinol products, redirecting consumers towards retinaldehyde alternatives, not covered by the restriction. Retinaldehyde (commonly known as retinal), a vitamin A derivative within the retinoid family, allows Medik8 to continue the sale of products, including its best-selling Crystal Retinal Serum.

The Bottom Line

The EU has raised the bar for cosmetic safety through Regulation EU 2024/996, and brands must move quickly to reformulate, relabel, or reposition products to stay in the EU market. For agile beauty players, this is a strategic pivot point where innovation, transparency, and regulatory foresight could become a business's most significant competitive edge. 

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