UV Filters in Cosmetics: Annex VI & Sunscreen Rules

Sun protection is one of the most tightly regulated areas of cosmetics. The only UV filters you can use are those on Annex VI of the cosmetic regulation, and sunscreen claims bring extra responsibilities on top. This guide explains how UV filter rules work, why sunscreens demand particular care, and what makers should know before adding SPF to a product.

Annex VI is one of the positive lists from our pillar guide to cosmetic ingredient annexes. Here we focus on UV filters and sun protection.

What is Annex VI?

Annex VI is the positive list of UV filters permitted in cosmetics. As with preservatives and colourants, only the substances on this list may be used to filter ultraviolet light, each within a maximum concentration and any conditions of use. A UV filter not on Annex VI cannot be used for sun protection in a UK or EU cosmetic, regardless of how it performs or where else in the world it is approved.

This last point matters because UV filter approvals differ significantly between regions. A filter widely used in one part of the world may not be on the UK or EU list, so you cannot simply copy a formula or import a product from another market and assume the sunscreen actives are permitted here.

Why sunscreens are so tightly controlled

Sunscreens sit at the sensitive intersection of cosmetics and public health. People rely on them to prevent sunburn and reduce skin-cancer risk, so the protection they claim has to be real and reliable. That is why both the ingredients (the UV filters) and the performance claims (such as SPF) are tightly controlled a sunscreen that under-delivers on its SPF is not just non-compliant, it can leave people genuinely unprotected.

In some parts of the world sunscreens are regulated as over-the-counter medicines rather than cosmetics. In the UK and EU they are cosmetics, but cosmetics held to a high standard, with established methods expected behind any protection claim. This makes SPF products one of the more demanding categories for a small brand to enter.

SPF and protection claims

If you make a sun-protection claim, you must be able to back it up. SPF (sun protection factor) measures protection against UVB, and broad-spectrum claims also require adequate UVA protection, with recognised testing methods used to substantiate the figures. Claims are expected to follow established conventions for example labelling protection in standard categories so that consumers can compare products meaningfully.

Substantiation is the crux. An SPF number is a performance claim, and like any claim it must be supported by appropriate evidence rather than estimated. This testing is specialised and adds cost and time, which is part of why SPF products are a bigger undertaking than a standard cosmetic. The claim rules connect to the wider labelling requirements in our label warnings guide.

Mineral versus chemical filters

UV filters are often grouped loosely into “mineral” filters, such as certain forms of titanium dioxide and zinc oxide, and “chemical” (organic) filters. Both types must appear on Annex VI to be used, and both come with their own conditions. Mineral filters in particular are frequently used in nano form to improve their feel and appearance, and nano grades carry specific assessment and labelling requirements including the “[nano]” marker in the ingredient list.

The mineral-versus-chemical distinction is more about marketing and consumer preference than a difference in regulatory status: what matters legally is that each specific filter, in the specific form and grade you use, is listed and used within its conditions. Assuming a “natural” mineral filter is automatically exempt from the rules is a common misunderstanding.

Borderline: when is it a cosmetic?

Adding UV filters to a product can affect how it is classified. A day cream with an incidental SPF for protecting the formula or giving light coverage is generally still a cosmetic, but a product whose primary purpose is sun protection sits firmly in sunscreen territory with all the substantiation that implies. The function you claim shapes both the rules that apply and the evidence you need.

This is one of several borderline questions in cosmetics, where presentation and claims determine the regulatory pathway. If you are unsure whether adding SPF tips your product into full sunscreen requirements, it is worth resolving before you formulate and make claims, because the testing burden differs significantly.

After-sun, tanning and 'SPF boost' products

Sun care covers more than sunscreen, and the adjacent products each have their own pitfalls. After-sun lotions are generally ordinary cosmetics, since they soothe rather than protect, but any protection claim creeping onto the label would pull them toward sunscreen rules. Self-tanning products colour the skin and do not provide sun protection at all, so they must not imply they do a common and risky labelling error. And “SPF-boosting” claims, suggesting a product increases another product's sun protection, are difficult to substantiate and should be approached with great caution.

The thread running through all of these is that sun-protection claims carry real weight because people make health decisions based on them. Implying protection a product does not deliver or that has not been tested is both non-compliant and genuinely unsafe, because a consumer may skip real protection believing they are covered. The rule of thumb is to claim only the protection you have actually substantiated, and to be careful that soothing or cosmetic products do not accidentally imply sun protection they do not provide.

If your range spans several of these categories, it is worth mapping which products make protection claims and which do not, so each is labelled and tested appropriately. Mixing the categories carelessly is an easy way to end up with a non compliant claim on an otherwise simple product.

UV filter compliance checklist

• Use only Annex VI-listed UV filters, within their limits.

• Don't assume filters approved elsewhere in the world are permitted here.

• Substantiate any SPF or broad-spectrum claim with recognised testing.

• Treat nano mineral filters as a special case, with the [nano] marker.

• Consider whether SPF tips your product into full sunscreen requirements.

• Have the formulation and claims assessed in your CPSR.

Frequently asked questions

Which UV filters can I use in cosmetics?

Only those listed in Annex VI of the cosmetic regulation, within their maximum concentrations and conditions. A filter not on Annex VI cannot be used for sun protection in a UK or EU cosmetic.

Are UV filters the same worldwide?

No. Approved UV filters differ significantly between regions, so a filter used elsewhere may not be on the UK or EU list. You cannot assume an imported sunscreen formula is compliant here.

Do I need to test my SPF claim?

Yes. SPF and broad-spectrum claims must be substantiated with recognised testing methods. An SPF figure is a performance claim that requires supporting evidence, not an estimate.

Are mineral UV filters exempt from the rules?

No. Mineral filters such as titanium dioxide and zinc oxide must also be on Annex VI and used within their conditions, and nano grades carry extra assessment and the '[nano]' label marker.

Does adding SPF make my product a sunscreen?

It depends on the product's primary purpose and claims. An incidental SPF in a day cream may remain an ordinary cosmetic, but a product sold primarily for sun protection carries full sunscreen substantiation requirements.

Are after sun and self tan products sunscreens?

No. After-sun soothes and self-tan colours the skin; neither provides sun protection, and they must not imply they do. Any protection claim would pull them into sunscreen rules and testing.

Can I claim my product boosts another product's SPF?

Such 'SPF boost' claims are difficult to substantiate and should be approached with great caution. Only claim sun protection you have actually tested and can support with recognised methods.

References: Regulation (EC) No 1223/2009, Annex VI (EUR-Lex); ISO SPF and UVA test methods; Commission Recommendation on sunscreen efficacy; UK Cosmetics Regulation as retained. General information only, not legal advice.