EU caps retinol at 0.3% face, 0.05% body, plus arbutin and kojic acid limits

The European Union’s Commission Regulation (EU) 2024/996 caps retinol (vitamin A) in cosmetics at 0.3% for most products and 0.05% for body lotion. It also limits three ingredients used in skin-tone products: alpha-arbutin at 2%, arbutin at 7% and kojic acid at 1%. This article sets out the numbers, the deadlines, and how to read a percentage on a label so you know how much is actually in the bottle.

What the regulation covers

Dated 3 April 2024, the regulation amends several annexes of the EU’s main cosmetics law (1223/2009) at once.

Substance	Where	Limit
Retinol, Retinyl Acetate, Retinyl Palmitate	body lotion	0.05% RE
	other leave-on and rinse-off products	0.3% RE
Alpha-Arbutin	face cream	2%
	body lotion	0.5%
Arbutin	face cream	7%
Kojic Acid	face and hand products	1%
Genistein	all products	0.007%
Daidzein	all products	0.02%
4-Methylbenzylidene Camphor (UV filter)	all products	banned

RE stands for Retinol Equivalent: every substance in the group is counted as the amount of retinol it represents. An ester such as retinyl palmitate has to be converted before it’s compared with the limit, so you can’t read the ester’s percentage straight off against 0.3%.

The regulation also tightens conditions for the preservatives triclosan and triclocarban, making six substances in all that were reviewed over possible endocrine effects (4-MBC, genistein, daidzein, kojic acid, triclosan, triclocarban).

Why the limits

Vitamin A. In its 2022 revised opinion, the SCCS found retinol in cosmetics safe up to 0.05% RE in body lotion and 0.3% RE in other products. But it noted that the 5% of people with the highest vitamin A intake from food and supplements could end up with too much overall. So every product containing these three substances must carry the warning:

Contains Vitamin A. Consider your daily intake before use.

Body lotion gets the lower ceiling because it covers far more skin than a face product.

Arbutin and alpha-arbutin. A 2023 SCCS opinion confirmed both are safe at the levels above. Both are linked to hydroquinone, so the rule also requires hydroquinone in these formulas to stay as low as possible, no higher than unavoidable traces.

Kojic acid. The SCCS concluded in 2022 that it’s safe as a skin-lightening agent at up to 1%. The rule caps it there and allows it only in face and hand products.

The deadlines, and where we are now

The regulation uses two kinds of dates: when non-compliant products can no longer be placed on the market (launched), and when they can no longer be made available (sold from shelves).

Group	No new launches from	Off shelves by
arbutin, alpha-arbutin, kojic acid, genistein, daidzein	1 Feb 2025	1 Nov 2025
4-MBC UV filter	1 May 2025	1 May 2026
retinol and its esters	1 Nov 2025	1 May 2027

As of late 2026 the arbutin group and 4-MBC deadlines have fully passed. For retinol, new products must already comply, but older stock can be sold until 1 May 2027. The EU gave retinol longer because there was no immediate health concern and most products on the market were already within the levels the SCCS considers safe.

Worked example: percentages into milligrams

Cosmetic percentages are weight for weight. 1% = 1 g in 100 g of product = 10 mg per gram.

A 30 g face serum at 0.3%

1. 0.3% = 3 mg per gram.
2. 30 g × 3 = 90 mg of retinol in the whole bottle (if it’s at the limit).

A 200 g body lotion at 0.05%

1. 0.05% = 0.5 mg per gram.
2. 200 × 0.5 = 100 mg in the whole bottle. That’s close to the serum even though the percentage is six times lower, because you use much more over the whole body.

A label that says “1% retinol”

1. If that means 1% pure retinol in a face product, it’s 1 ÷ 0.3 ≈ 3.3 times the EU limit.
2. Some products mean 1% of a ready-made blend that contains only some retinol, so the number on the box doesn’t always tell you the real amount. If you want to know, ask the seller what percentage of pure retinol it contains.

The number on the front of the box and the percentage of the pure substance may not be the same thing. Ask before comparing it with the limit.

What this means outside the EU

This rule covers products sold in the EU. Products sold elsewhere, Thailand included, follow their own national rules. The EU numbers are still a useful reference for what one major safety body considers a sensible level.

• Using several vitamin A products at once, such as a serum, an eye cream and a night cream, adds up.
• Start one new product at a time and test it first: see Patch test new products first.
• Daily sunscreen is a basic step anyway; see how much to use in Sunscreen SPF vs PA.

Common mistakes

• Assuming higher is better. The EU limit is a level assessed as safe, not a “too weak” level.
• Stacking several vitamin A products. Each may be within the limit while the total keeps rising.
• Not telling your doctor about vitamin A supplements. That’s exactly why the label warning exists.
• Assuming a face-cream percentage is fine on the body. Alpha-arbutin in body lotion is capped at 0.5%, four times lower than in face cream.
• Pushing through persistent stinging, redness or peeling. Stop the product and ask a doctor or pharmacist.

Sources

• Commission Regulation (EU) 2024/996 on Vitamin A, Alpha-Arbutin, Arbutin and certain substances with potential endocrine disrupting properties — EUR-Lex
• Regulation 2024/996: restrictions on vitamin A, Arbutin and 6 endocrine disruptors — CosmeticOBS
• Navigating new Annex III restrictions on vitamin A in cosmetics — Exponent