Are product type conditions for Soap 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 1 record

Soap

1 EU annex record carries product type conditions for Soap cosmetics under Regulation 1223/2009. Conditions may include concentration limits, warnings and usage restrictions.

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Evidence overview

Records

Annexes

CAS identified

Concentration limits

Warnings

Annex III · 1

Records mentioning Soap

1 total

Annex

III

Entry

Etidronic acid

(1-Hydroxyethylidene)diphosphonic acid and its salts

(a) Hair product (b) Soap

CAS

2809-21-4

220-552-8

Max concentration

These product-type values occur on the same annex records and help interpret the source wording in context.

Hair product · 1

How Soap conditions affect compliance

There is 1 EU annex record on this page that mentions the Soap 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 Soap 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 Soap 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

An Annex II substance is prohibited as an intentionally added cosmetic ingredient, subject to the narrow Article 17 exception for technically unavoidable unintended small quantities and the Article 3 safety requirement. An Annex III substance may be used only under specified conditions such as product type, concentration and warnings.

Tools & next steps

Check your formula

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

INCI Checker

All product types

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

View all product types

Browse linked annexes

Open the annex collections that actually contain the evidence summarised on this page.

Annex III