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The cosmetics industry has seen an accelerated shift toward natural and organic formulations over the past two decades, driven by increasing consumer demand for naturals, sustainability, and supply chain transparency. However, formulating with natural ingredients is far from straightforward—especially in a global context where regulations vary widely and are frequently updated. For cosmetic brands and manufacturers, keeping up with these evolving regulatory landscapes requires vigilance, adaptability, and a proactive compliance strategy.
Evaluating frameworks: EU
In February 2025, the European Commission (EC) opened the call for evidence[1] to evaluate and assesses whether the EU Cosmetics Regulation (EC) No. 1223/2009 (CPR) remains fit for purpose more than a decade after entering into force. The evaluation comes at a time when discussions related to the joint green and digital transitions persist and aims to assess how the CPR works in today’s regulatory and social environment. It addresses aspects such as online and bulk sales, digital labelling, professional use of cosmetic products, as well as international competitiveness[2] and trade – now key topics under the new EU political mandate.
The criteria for the evaluation are closely linked to the Better Regulation Guidelines[3] and cover aspects such as effectiveness, efficiency, relevance, coherence, and added value of the CPR. A potent aspect of this review is how the CPR aligns with broader legislation affecting chemicals (e.g., the simplification of EU REACH and updates to CLP[4]), sustainability integration (PPWR[5], ESPR[6], CS3D[7], CSRD[8]) and green claims (e.g., ECGT[9] and Green Claims Directive[10]).
Whilst the process is on-going, with a public consultation open until the end of July 2025, the work is expected to continue through mid-2026. It remains clear that the joint successes of the CPR –setting strict safety requirements to ensure high protection for consumer health and supporting the functioning of the internal market – must be maintained. To this end, simplification does not mean deregulation; rather, it offers an opportunity to clarify the regulatory framework, correct outstanding issues and reduce the potential burden affecting operators, particularly SMEs.
Embracing the bioeconomy
A key touchstone to measure the success of naturals is the access to a wide palette of raw materials. However, the biobased sector faces notable challenges in reaching its full potential and in supporting the movement to defossilise raw material feedstocks.
- Primarily, these challenges are commonly associated with higher production costs for naturals compared with fossil fuels alternatives, which are commonly subsidised and therefore their price can distort the playing field.
- Equally, as with any product, naturals would have to achieve economies of scale to reduce the unit cost.
- Additional obstacles include regulatory uncertainty and/or inconsistencies, lack of harmonised definitions and/or certifications, scale-up limitations, maturity of technologies and the integration of new approaches into existing chemical infrastructure.
These barriers risk slowing marketing access and destabilising demand and investment in innovation. To tackle these issues, the EC has launched a public consultation aimed to ensure a competitive and circular bioeconomy in the EU[11].
Amid these larger changes, naturals – in particular natural complex substances (NCSs), such as essential oils and other plant extracts – are increasingly facing regulatory scrutiny. Notable examples include how substances, such as tea tree oil (TTO), or constituents of NCSs (e.g., p-cymene) will be regulated under Article 15 of the CPR.
TTO, for instance, contains more than 100 composites and is a substance with more than one constituent (MOCS), which are themselves subject to further examination as per Article 54a(1) of amended CLP Regulation (EU) 2024/2865. In 2023, following ECHA review on a harmonised classification, ECHA’s Risk Assessment Committee (RAC)[12] recommended classifying TTO as CMR 1B – a stricter classification than the original category 2 proposed by Poland. In response, in order to defend TTO, industry stakeholders submitted a dossier to defend its safe use in cosmetics. In June 2025, the Scientific Committee on Consumer Safety (SCCS) presented their preliminary Opinion[13] supporting the safe use of TTO in cosmetics under defined conditions: (a) used at or below 2.0% in shampoos; (b) 1.0% in shower gels and face washes; (c) 0.1% in face creams. The SCCS also emphasised the need to conform to ISO 4730:2017 and to ensure its chemical stability in formulations to prevent degradation. Following the finalisation of the SCCS opinion, the EC will continue with risk management provisions.
Besides the individual NCSs, an overarching risk to a multitude of NCSs is the case where a constituent would be classified as a CMR. This is already the case for p-cymene, a component found in numerous essential oils (e.g., cumin, thyme oil, tea tree, oregano). In 2022, Sweden proposed classifying this substance as a CMR 1B[14]. Similar to the case of TTO, according to Article 15(2) of the CPR, the impact for cosmetics of such classification would trigger a ban, potentially requiring reformulation or removal of a vast number of “natural” and essential-oil–based products. Yet, in practice, removing a single constituent from NCS without altering the substance’s overall properties is often technically and economically unfeasible. Equally, one constituent can impact multiple NCSs, amplifying the regulatory impact; and for naturals especially, suitable alternatives may not exist.
Current discussions among stakeholders aim to resolve this matter to avoid any regrettable restrictions, where the safety of NCSs can be adequately assessed. If unresolved, a domino effect may limit the palette of naturals, reduce the diversity of natural cosmetics on the market, go against a global consumer trend for natural products, and run contrary to the EU’s ambitions concerning the bioeconomy and sustainable substance use in the future.
A natural future?
The coming years will support further discussions between stakeholders concerning how to ensure the continuity of existing formulations, while fostering innovation for new natural product development. Although global harmonization is unlikely in the short term, trends such as sustainability, ingredient traceability, and data-driven safety assessments are becoming universal. Brands that invest in robust regulatory systems, ethical sourcing, and transparent communication will be best positioned to lead in the natural cosmetics space.
In the short-term, upholding a strong science-based, risk assessment approach to consumer protection and safety remains essential. Looking forward, the scope to support the needs of natural cosmetics sector, enhance the capabilities of the European bioeconomy, foster sustainable innovation, and accommodate digitalisation will remain essential to meeting evolving consumer expectations.
There are various key elements where manufacturers should stay ahead, including ingredient traceability, environmental claims and certifications, new allergen labelling[15], intellectual property, and biodiversity[16],[17]. As such, operators in the natural sector must prioritise ingredient vigilance and greater sustainability awareness across the lifecycle of a product – particularly in light of the expected conclusion of institutional trilogue on the Green Claims Directive file in 2024.
Therefore, while the path to global compliance for natural cosmetic products is fraught with complexity, it also offers immense opportunity. Natural brands that can successfully manage to align innovation with regulatory rigor are not just meeting compliance but contributing to building the future of beauty.
References
[1] https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14433-Cosmetic-Products-Regulation-evaluation_en
[2] https://commission.europa.eu/topics/eu-competitiveness/competitiveness-compass_en
[3] https://commission.europa.eu/law/law-making-process/better-regulation_en
[4] https://eur-lex.europa.eu/eli/reg/2024/2865/oj/eng
[5] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202500040&pk_campaign=todays_OJ&pk_source=EUR-Lex&pk_medium=X&pk_content=Environment&pk_keyword=Regulation
[6] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1781&qid=1719580391746
[7] https://eur-lex.europa.eu/eli/dir/2024/1760/oj
[8] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464
[9] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202400825
[10] https://environment.ec.europa.eu/topics/circular-economy/green-claims_en
[11] https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14555-Towards-a-circular-regenerative-and-competitive-bioeconomy_en
[12] https://echa.europa.eu/fr/registry-of-clh-intentions-until-outcome/-/dislist/details/0b0236e18571231a
[13]https://health.ec.europa.eu/publications/sccs-scientific-opinion-tea-tree-oil-casec-no-68647-73-4-285-377-1_en
[14] https://echa.europa.eu/pl/registry-of-clh-intentions-until-outcome/-/dislist/details/0b0236e188d24acd
[15] https://eur-lex.europa.eu/eli/reg/2023/1545/oj/eng
[16] https://www.cbd.int/dsi-gr
[17] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0511
Article written by Dr Mark Smith, NATRUE”s Director General, and originally published on CACHCA E-Journal – July issue (available in English here.)