Are product type conditions for Face cream legally binding?

Yes. Product type conditions in Annex III are legally binding under EU Cosmetics Regulation 1223/2009. A product that does not comply with product type conditions for a restricted ingredient is non-compliant, regardless of whether concentration limits are met.

How do I verify product type compliance for my formula?

Use the INCI Checker on CosIng Checker to scan your ingredient list against all Annex II–VI entries. For each flagged ingredient, open its record to review the product type conditions, maximum concentration and any applicable warnings.

Product type 2 records

Face cream

2 EU annex records carry product type conditions for Face cream cosmetics under Regulation 1223/2009. Conditions may include concentration limits, warnings and usage restrictions.

INCI Checker All product types

Records mentioning Face cream

2 total

Annex

III

Entry

377

Alpha-Arbutin

4-Hydroxyphenyl-alpha-D-glucopyranoside

Hydroquinone levels shall remain as low as possible in formulations containing alpha-Arbutin and shall not be higher than the unavoidable trace level. From 1 February 2025 cosmetic products containing that substance an…

CAS

84380-01-8

617-561-8

Max concentration

Annex

III

Entry

378

Arbutin

4-Hydroxyphenyl-beta-D-glucopyranoside

CAS

497-76-7

207-850-3

Max concentration

How Face cream conditions affect compliance

There are 2 EU annex records on this page that mention the Face cream product type category. Product type wording is where the regulation tells you whether a substance may, may not, or may only conditionally be used in that cosmetic category.

Reviewing records by product type is useful when your finished product clearly falls into the Face cream category and you need to check whether maximum concentrations, warnings or annex placement change for that use case.

Frequently asked questions

For substances listed in Annex III of EU Cosmetics Regulation 1223/2009, the product type field specifies which cosmetic categories the substance is permitted or restricted in. A substance with a restriction tied to Face cream products may be permitted at a different concentration, or prohibited altogether, in other product categories. Each entry should be read individually.

Yes. Product type conditions set out in Annex III are legally binding under EU Cosmetics Regulation 1223/2009. A cosmetic product that does not comply with the product type conditions for a restricted ingredient is not compliant, regardless of whether other conditions (such as concentration limits) are met.

Use the INCI Checker tool to scan your ingredient list against all Annex II–VI entries. For each flagged ingredient, open its individual record to review the product type conditions, maximum concentration and any applicable warnings to confirm they are compatible with your intended product category.

Open INCI Checker

A prohibited substance (Annex II) may not be present in any cosmetic product at any concentration. A restricted substance (Annex III) may be used but only under specific conditions — such as product type limitations, maximum concentrations and mandatory warnings. Both types of records appear in the list above if they carry a product type field.

Tools & next steps

Check your formula

Scan a full INCI list, then check whether flagged substances carry conditions for Face cream products.

INCI Checker

All product types

Browse all cosmetic product-type categories and compare how Face cream sits against neighbouring use cases.

View all product types

Browse Annex III

View all restricted substances in Annex III, including their product type conditions.

Open Annex III