Retinol’s popularity may be ageless, but the ingredient has courted regulatory scrutiny.
Following the signing of the Modernisation of Cosmetics Regulations Act (MoCRA), granting the Food & Drug Administration more oversight on beauty products in the US, the European Commission has put one of the beauty industry’s most popular ingredients under review. Under the purview of the European Union’s Scientific Committee on Consumer Safety (SCCS), the regulation is driven by recommendations that overexposure to Vitamin A can result in adverse health outcomes. If it passes, brands will have up to three years to reformulate over-the-counter retinol products sold in the EU or risk losing access to this market for products that go above the recommended limit.
Best used for its ability to treat pigmentation and acne as well as reduce signs of ageing, retinol has long been a skin care staple. The product has seen a wave of new interest in recent years: TikTok searches for retinol have increased by over 44 percent in the UK since 2022, according to beauty trend forecasting platform Spate.
This means the EU regulation will have an international effect on all retinol-based products, transforming the beauty industry’s approach around potent ingredients.
What’s behind the EU’s regulation?
By the end of the year, policy makers in the EU will vote to change existing policies on the use of Vitamin A, with new regulations active in early 2024. The regulation will limit the sale of over-the-counter retinol to a maximum of 0.05 percent concentration in body lotions and 0.3 percent in face and hand products.
Consumers in the EU can currently buy a up to a 2 percent concentration of retinol over the counter, according to Magda Starula, health consultant at Euromonitor. According to SCCS, overexposure to Vitamin A can lead to health outcomes such as skin disorders, weakened bones, nausea and vomiting. But beauty experts say the correlation of these side effects to the use of retinol compared to the consumption of food, including kale, sweet potatoes and eggs, is unclear.
For Mark Curry, co-founder of The Inkey List, the issue is more about digestible Vitamin A and how it increases the absorption of retinol in your bloodstream.
“Retinol is active only when it’s in the skin and most of the ‘juices’ that you get are not pure retinol, it’s some kind of compound that breaks down in the skin to its active version. But even that is broken down fairly quickly by your naturally producing hormones,” he said.
But for the SCCS, cosmetics contribute to the overall intake of Vitamin A which exceeds the European Food Safety Authority’s (EFSA) recommended limit of 3,000 milligrams for European adults. How this translates to the concentration of retinol products is also unclear.
Under this new regulation, affected brands will have 36 months to adjust formulations for existing products containing retinol, retinyl acetate, and retinyl palmitate. For new products entering the EU market, brands will have 18 months to reformulate their product offerings.
The EU Commission declined to provide further details.
How will the EU regulation impact the beauty industry?
For brands like Sunday Riley and Beauty Pie, retinol-based products are their hero products. The regulation will leave many of the industry’s biggest conglomerates thinking about how to navigate the regulation without compromising overall product efficacy. But industry players like Paula’s Choice and Neutrogena, for instance, have already taken steps towards reducing their retinol content. Both have recently launched products with a 0.3 percent concentration of retinol, said Starula.
Some brands are likely to turn to plant-based retinol alternatives such as bakuchiol, which has similar effects to retinol for its ability to increase cell turnover, said London-based medical and cosmetic doctor Ewoma Ukeleghe. But this ingredient is much less potent than retinol, she added.
“At a cellular level [retinol] does much more,” Ukeleghe said. “Not only does it increase skin cell turnover, it also assists with pigmentation, improves breakouts and acne, and it is the only topical that is clinically proven to treat and improve fine lines and wrinkles.”
While it’s possible for brands to offer different formulations of retinol-based products in different markets, this will be a costly approach, according to Curry. Similar to the EU ban of lilial, the ingredient formerly used in Olaplex’s No.3 Treatment, this regulation will likely lead to a global reformulation of industry best sellers like Drunk Elephant’s A-Passioni, The Ordinary’s Retinol 1%, and The Inkey List’s 1% Retinol Serum as brands consolidate formulas across key markets.
But ultimately, this regulation will not limit consumer access to higher concentrations of retinol. Companies such as Dermatica and Skin+ Me already distribute prescription strength skin care through their direct-to-consumer platforms.
Ukelegh expects to see beauty labels add 0.7 percent or 1 percent retinol to their portfolios.
What are the alternatives to retinol?
Under EU’s regulation of Vitamin A, brands will start to explore ingredients with similar anti-ageing effects, such as novoretin, for example, which activates the same pathway as retinol, according to Starula.
“Raw material suppliers are now increasingly looking at biotechnology and how they can do things that support similar pathways without having that [retinol] source active,” said Curry.
But as the rapid rise and fall of manufacturer-turned-beauty-conglomerate Amyris has shown, communicating the viability of bio-based ingredients in a way that resonates with consumers is challenging, particularly as the desire for more potent and active ingredients continues to rise.
As consumer expectations change, such regulations will not only have an impact on skin care products, the food supplement market will also start to see a shift as policy makers begin to consolidate efforts across different sectors in a bid to protect consumers from ingredients with potential health risks.
But when the virality of ‘skintellectuals’ is driving customers’ buying decisions, “this regulation intensifies one of the beauty industry’s biggest problems – confusing the consumer,” said Curry.