- The EU Cosmetics Regulation has no list of "approved" ingredients. What it has are lists of prohibited substances (Annex II), restricted substances (Annex III), and positive lists for colorants, preservatives, and UV filters (Annexes IV, V, and VI).
- Being listed in the CosIng database does not mean an ingredient is authorised: inclusion in the inventory carries no legal weight.
- The correct approach is a 4-step process that follows the logic of the Annexes to Regulation 1223/2009.
- The BD-API CosIng search tool lets you run this check in seconds, without downloading any file.
1. The right question is not "is it approved?"
When someone asks "can I use this ingredient in an EU cosmetic?", the first common mistake is to look for an "approved ingredients" list. That list does not exist.
The legal framework established by Regulation (EC) No 1223/2009 works differently: rather than listing what is permitted, it defines what is prohibited or restricted, and establishes positive lists only for three specific functional categories. For all other ingredients, the operating principle is that they may be used, provided the responsible person demonstrates their safety through a safety assessment report.
The European Commission's CosIng database is the reference tool for consulting that information. However, there is a critical point the Commission itself makes clear: the inclusion of an ingredient in the CosIng inventory is not an indication of authorisation. Only Regulation 1223/2009 and its amendments have legal value.
This distinction matters in practice. An ingredient may appear in the CosIng inventory — which covers more than 30,000 entries — and still be in Annex II (prohibited) or Annex III (restricted). Real verification means checking the Annexes, not just searching the name in the inventory.
2. The 4-step method
This process follows the logical structure of the Annexes to Regulation 1223/2009. Applying the steps in order ensures no restriction is overlooked.
Step 1: identify the ingredient by INCI name or CAS number
The first step is to obtain a precise identifier. The INCI name (International Nomenclature of Cosmetic Ingredients) is the standardised name used in labelling and regulatory records. The CAS number is even more precise, because it is unique to each chemical substance and eliminates ambiguity from synonyms or spelling variants.
For example, salicylic acid may appear as "Salicylic Acid" (INCI), "2-Hydroxybenzoic acid" (IUPAC), or under the CAS number 69-72-7. For regulatory searches, using the CAS number reduces the risk of confusion.
The BD-API search tool accepts both INCI names and CAS numbers directly.
Step 2: check whether it is in Annex II (prohibited)
Annex II currently contains 1,758 entries in our synchronised database. These are substances that cannot be present in any cosmetic product marketed in the EU, at any concentration or under any condition.
If the ingredient appears in Annex II, the check ends here: it cannot be used.
This list covers a wide range of substances: certain heavy metals, some fragrance derivatives, hormones, pesticides, and other materials whose scientific assessment has determined they are incompatible with cosmetic use. For CMR substances (carcinogenic, mutagenic, or reprotoxic), Regulation 1223/2009 establishes prohibition as the default, with very specific exceptions. The CMR page in our database explains that mechanism in detail.
Step 3: check whether it is in Annex III (restricted)
Annex III contains 381 entries: substances that may be used, but only under defined conditions. Each entry specifies:
- The cosmetic product type in which it may be used (or from which it is excluded).
- The maximum permitted concentration.
- Mandatory labelling warnings, where applicable.
- Additional conditions, such as restrictions on use in products for children.
If the ingredient appears here, it may be used — but exclusively within those conditions. Formulating above the maximum concentration, or in an excluded product type, constitutes non-compliance even if the concentration is low.
The article Restricted substances in EU cosmetics: Annex III explained describes in detail how to read each column in this list.
Step 4: if it is a colorant, preservative, or UV filter, it must appear in its positive list
For these three functional categories, the logic is inverted: instead of "permitted unless prohibited," the rule is "prohibited unless listed."
- Annex IV — Authorised colorants: 154 entries.
- Annex V — Authorised preservatives: 58 entries.
- Annex VI — Authorised UV filters: 34 entries.
If an ingredient functions as a colorant, preservative, or UV filter and does not appear in the corresponding list, it cannot be used for that function in EU cosmetics. The post Allowed preservatives in EU cosmetics: Annex V explained develops this point with practical examples.
Outcome of the process: if the ingredient does not appear in any of Annexes II, III, IV, V, or VI with an applicable restriction, its use is not specifically limited by Regulation 1223/2009 — although the obligation to demonstrate its safety through the required report still applies.
3. Three real examples
Example A: Butylphenyl Methylpropional / Lilial (CAS 80-54-6) — prohibited
This compound, widely used as a fragrance ingredient for decades, was prohibited in 2022 by Regulation (EU) 2021/1099. It now appears in Annex II. If you search for CAS 80-54-6 in CosIng with Status=Active, you will not find it in the use inventory — you will find it directly in the list of prohibited substances.
This case illustrates an important point: the longevity of an ingredient in the market is no guarantee of its current regulatory status. Any new product formulated with this ingredient cannot be placed on the EU market.
Example B: Salicylic Acid (CAS 69-72-7) — restricted (Annex III, entry III/98)
Salicylic acid is listed in Annex III as entry III/98. The restriction varies by product type: the maximum concentration differs for hair products, facial products, and body products. When used in products that may come into contact with children, a specific labelling warning is mandatory.
It is an ingredient that can be used, but whose compliance depends not just on concentration, but on the product type and the target consumer. Without reviewing the complete conditions in Annex III, it is impossible to determine whether a specific formulation is compliant.
Example C: a preservative not listed in Annex V
Consider an ingredient with well-documented preservative properties that does not appear in Annex V. Regardless of its efficacy and safety record in other markets, it cannot be used as a preservative in EU cosmetics. This is the effect of positive lists: absence from the list equals prohibition for that function.
In practice, this affects formulators bringing references from non-European markets where authorised preservative lists differ. Verifying against Annex V is an indispensable step before transferring any formula to the EU market.
4. The shortcut: BD-API's CosIng search tool
The process described above can be done manually by downloading the official CosIng .xls file and reviewing each Annex separately. That works for one-off checks, but it has two concrete limitations:
- The file may be out of date. The
.xlsyou downloaded three months ago reflects the state of CosIng at that time. If the Commission has published an amending regulation since then, your file does not include it. - Manual searches across multiple Annexes are slow and error-prone. Checking one ingredient against six relevant Annexes in separate spreadsheets takes time and can miss entries.
The BD-API CosIng search tool addresses both problems. Enter the INCI name or CAS number of the ingredient and the tool returns, on a single screen:
- Whether it is in Annex II (prohibited).
- Whether it is in Annex III (restricted), with the applicable conditions.
- Whether it appears in Annexes IV, V, or VI, with its status in the positive list.
- Whether it does not appear in any restrictive list.
The database is automatically synchronised with the official CosIng file. When the Commission publishes an update, the system detects it and incorporates it without manual intervention.
For broader exploration by Annex, the CosIng database pages allow you to browse each complete list: Annex II, Annex III, Annex IV, Annex V, and Annex VI.
5. Common mistakes in ingredient verification
Confusing "listed in CosIng" with "permitted"
The CosIng inventory contains more than 30,000 entries and describes ingredients in use, but it is not an authorisation register. An ingredient can be in the inventory and simultaneously in Annex II. A search in the general inventory and a search in the Annexes are two distinct queries.
Ignoring the conditions in Annex III
Finding that an ingredient "is in Annex III" and assuming it can be used freely is another frequent mistake. Annex III permits use only under specific conditions. Being on that list does not remove the restrictions — it defines them.
Working with outdated data
The Annexes to Regulation 1223/2009 are modified through regulations published in the Official Journal. Working with a .xls file downloaded months ago, or with a tool that does not synchronise automatically, introduces the risk of making formulation decisions based on data that no longer reflects the current regulatory state.
The guide How to read the CosIng Annexes explains column by column how to interpret each Annex entry and avoid these reading errors.
6. Frequently asked questions
Is there an official list of "approved" cosmetic ingredients in the EU? No. EU cosmetics regulation does not have an "approved ingredients" register. What it has are lists of prohibited substances (Annex II), restricted substances (Annex III), and positive lists for specific functional categories — colorants, preservatives, and UV filters in Annexes IV, V, and VI. Any ingredient not covered by those lists may be used, provided it passes the safety assessment required by Regulation 1223/2009.
Does appearing in the CosIng database mean an ingredient is allowed? No. The inclusion of an ingredient in the CosIng inventory is not an indication of authorisation. CosIng is a consultation tool, not a legal register. Only Regulation (EC) No 1223/2009 and its amendments have legal value.
What is the difference between Annex II and Annex III? Annex II lists substances that are completely prohibited in cosmetics: they cannot be used in any product, at any concentration, under any condition. Annex III lists restricted substances: they may be used, but only under specific conditions of maximum concentration, product type, and labelling warnings.
What happens if a preservative does not appear in Annex V? It cannot be used as a preservative in EU cosmetics. Annexes IV (colorants), V (preservatives), and VI (UV filters) are positive lists: only ingredients included in them may perform that function. If a substance with preservative activity is not in Annex V, its use as a preservative is not permitted.
How do I know whether the Annex III conditions apply to my product type? Each Annex III entry specifies the product type, the maximum permitted concentration, and any mandatory labelling warnings. You can consult the complete entry for any ingredient using the BD-API search tool, which displays all conditions on a single screen.
How often do the Annexes to Regulation 1223/2009 change? The Annexes are updated when the European Commission publishes an amending regulation in the Official Journal. There is no fixed cycle. This is why working with a synchronised data source that picks up changes as soon as they are published matters more than relying on manually downloaded files.
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