Will retinol be banned in the EU in 2020?!

Let’s have a look at all the facts and rumours floating around. Find the 2023 update here!

Lately, a lot of (especially German) skincare blogs I read started discussing the following: both Paula’s Choice and Deciem have (somewhat, maybe) announced (here and here) to not sell retinol products over 0,3% in the EU from some point in 2020 onwards. Skinceuticals has implemented that strategy already: you can buy only their 0,3% retinol products in the EU, while in the US the 1% version is still available.

The European Union has concerns

Asked why, both companies (PC and Deciem) cited a document from the EU’s Scientific Committee on Consumer Safety from 2016 (!!!). (There was a similar one from 2013.) I skimmed the document (healthcare background ftw!) which proved a demanding read. I can only say: if you’re an animal lover, deciding on the toxicity of retinol is not a field you should look into.

The document, though, is concerned with the general Vitamin A intake and how much might be too much. Retinol, as a form of Vitamin A, is fat soluble and might build up in the body’s fat depots and MIGHT lead to bone and birth defects.

(There’re different opinions, citing different studies, on if it’s possible that retinol actually penetrates the skin. I’m not a scientist, I don’t know. The only sure thing seems to be that retinol will be absorbed if you’re applying it to mucous membranes. Don’t do that.)

Retinol? Vitamin A? What?

Let me quote the document:

“Vitamin  A  (CAS  n.  68-26-8  /  11103-57-4/  116-31-4)  constitutes  a  group  of  lipid-soluble  compounds  including  retinol,  retinyl  palmitate,  retinyl  acetate,  retinyl  linoleate  and  retinal.  Vitamin  A  is  a  lipophilic-soluble  Vitamin  and  as  such  a  micronutrient  essential  for  most  of  mammalian species.”

Huh?

For a skincare junkie, the following is important: there’re three forms of retinoids: retinol esters (Retinyl Palmitate, Retinyl Linoleate), the most gentle forms,  retinol and tretinoin (retinoic acid) that is a drug and is therefore not grouped with the cosmetic ingredients like retinol esters and retinols. It’s also potent af and has serious side effects.

The European Union, alas, isn’t composed of skincare junkies, though.

Will retinol be banned in the EU?!

The document decides that products, no matter if they include retinol or retinyl palmitate, are safe if the dose of retinoids doesn’t surpass 0,3%. Yay!?

So, what it’s concerned about, then?

“The  SCCS  has  also  estimated  that  exposure  to  Vitamin  A  (retinol,  retinyl  palmitate,  and  retinyl  acetate)  from  all  cosmetic  products  (including  lip  products)  may  lead  to  a  daily  systemic dose of 4855 IU for an adult. This exposure could constitute up to 97% of the UL of 5000 IU/day of Vitamin A. Excluding lip products, the daily systemic dose is estimated at 4256 IU for an adult, which constitutes up to 85% of the UL of 5000 IU/day of Vitamin A.”

I added this quote for you to see that the whole shebang has absolutely nothing to do with skin concerns and reactions due to retinol. The document is concerned with the Tolarable Upper Intake Level (IU) of Vitamin A per day.

It’s about Vitamin A intake, baby!

Apparently, the dose is already quite high due to cosmetics without regarding what you orally digest (i.e. eat) each day. There’s been an assumption that high levels of Vitamin A intake will diminish bone density, a concern especially for menopausal women – coincidentally also the main target of anti-aging products including retinol.

Rumours…

The EU will ban all retinol products!

No, they won’t. The document cited above stated that skincare products up to a concentration of 0,3% are safe to use.

Even though there’re apparently a lot of rumours floating around that the topic is fresh on Brussels’ agenda, there’s no reason to start stockpiling your favourite retinol products. It usually takes quite some time for laws to get applied, with transition periods and whatnot.

There’re valuable insights and concerns, ‘kay?

Let me also digress and say this: it’s very easy to throw a strop and claim that there’re much worse things out there than retinol that should be banned (very true): retinol is a very, very potent ingredient with A LOT of potential side effects. It is very easy to harm yourself when using it.

Will tretinoin be banned, too?

I have no idea. Tretinoin is banned to be used in cosmetics in the EU, though – it’s classed as a drug and therefore, there’re a whole different set of laws regulating drugs.

Ok, no problem: I’ll just use a product with retinal instead!

Sorry buddy, retinal is a retinol aldehyde and will probably fall under the same law. (If they decide to turn it into a law.)

All retinol products will be changed to include bakuchiol instead of retinol!

Maybe, maybe not. Look at Michelle’s post about the new, hip ingredient for more info on what it can, and what it can’t do. Paula’s Choice apparently has a new product including it in the works, which doesn’t surprise me one bit: even without a possible new law PC is very keen to jump on new skincare trends lately.

The end: what now?

So, here’s my attempt to unravel all rumours and facts floating around out there regarding a possible retinol ban by the European Union. My own, personal conclusion is that it might be a good idea to start to have a look at my Vitamin A intake, although I use and love a 1% retinol product, and my skin benefits from it. I’m also quite confident that the skincare industry will come out with great new products, even if 1% retinol products will be banned. But let’s see if that will happen at all!

Please note that I’m not a chemist/biologist/dermatologist/nutritionist nor a doctor, but a former healthcare editor and skincare enthusiast. If you’ve got health concerns, talk to your doc!

If you’ve got insights or corrections, I’m happy to include them here.