Restricted Ingredients Compliance & Validation

What's included in your restricted ingredients check

Who this restricted ingredients check is for

• Formulators checking a specific ingredient or concentration
• Brands with a preservative, colourant or UV filter close to its limit
• Brands importing a third-party formula who want a quick legality check
• Sellers answering a retailer or marketplace query about a substance

What this restricted ingredients check does not include

• A whole-formula diagnosis or reformulation. This check is limited to the ingredients you name. Screening every ingredient and recommending fixes is a formulation review.
• Final sign-off of a finished formula. A documented pass of the complete formula before the safety assessment is a formulation validation.
• The CPSR. This check does not replace the safety assessment. Every product still needs a CPSR for a cosmetic product before it is sold.
• Fragrance allergen labelling. If your question is which allergens must be named on the label, the Allergen Compliance Check is the focused option.
• Laboratory analysis. We work from your formula and supplier data. Testing for impurities or traces is done separately by a laboratory.

How it works

1. Fill our Product Information Document Send your INCI list with percentages, the product type, how it is used and which ingredients concern you.
2. We identify each substance Every ingredient of concern is matched to its INCI name and CAS or EC number.
3. We check the GB and EU annexes Each substance is checked against Annexes II–VI for your product type, including maximum concentrations and required warnings.
4. You receive your validation table Your results arrive within 72, 48 or 24 hours of complete information, depending on the delivery speed you choose.

What is a restricted ingredients check?

A restricted ingredients check is a focused review of named ingredients in a cosmetic formula against the UK and EU lists of banned and restricted substances. It confirms that each ingredient is not prohibited under Annex II of Regulation (EC) No 1223/2009, and that any ingredient listed in Annex III, or any colourant, preservative or UV filter in Annexes IV–VI, is used within its maximum concentration, in a permitted product type and with the required warnings. Article 14 makes these restrictions binding in the EU and, under the GB version of the regulation, in Great Britain.

Which service do I need? Choose this check when your concern is a few named ingredients. If you want the whole formula screened and fixed while it can still change, choose a cosmetic formulation review; if your formula is finished and needs a documented final pass before the CPSR, choose formulation compliance validation.

Annex II prohibited and Annex III restricted substances: what we check

The annexes we check:

• Annex II — prohibited substances: We confirm none of the ingredients checked is banned. Under Article 15, substances classified as CMR (carcinogenic, mutagenic or toxic for reproduction) category 1A, 1B or 2 are also prohibited unless specifically allowed after a safety evaluation.
• Annex III — restricted substances: We verify the maximum concentration, the permitted product types and body areas, and the label warnings. Limits often differ by product type: hydrogen peroxide, for example, is limited to 12% in hair products but 4% in skin products.
• Annex IV — colourants: Permitted colourants, their field of application (for example, whether a colourant may be used near the eyes) and any purity criteria.
• Annex V — preservatives: Permitted preservatives, maximum concentrations and conditions. Methylisothiazolinone, for example, is allowed only in rinse-off products, at up to 0.0015%.
• Annex VI — UV filters: Permitted UV filters and their maximum concentrations.
• Ingredient identity: Correct INCI naming and CAS or EC numbers, so each ingredient is matched to the right annex entry.

Why a UK and EU concentration limit check matters:

• Separate amendments: Great Britain amends its annexes through UK statutory instruments, and the EU through Commission regulations, so the two lists do not always match. We check both and flag any difference.
• CosIng is a starting point, not the law: The European Commission states that its CosIng database is for information only and has no legal value. We check the annexes themselves.
• Traces of banned substances: Under Article 17, a small, technically unavoidable trace of a prohibited substance from impurities, manufacturing, storage or packaging is permitted only if the product is still safe.

How to read your validation table

For each ingredient checked you receive:

• Annex reference: The annex and entry number that applies, or confirmation that the substance is not listed
• Limit: The maximum concentration in the ready-for-use product for your product type
• Conditions and warnings: Any condition of use and the label wording required
• Status: A clear pass or flag
• Notes: For any flag, what is wrong and what would bring the ingredient within its limit

Legal framework for banned and restricted cosmetic ingredients

• Article 14, Regulation (EC) No 1223/2009 — cosmetics must not contain Annex II substances, and may contain Annex III–VI substances only within their conditions
• Annex II — prohibited substances
• Annex III — restricted substances, with maximum concentrations, product types and required warnings
• Annexes IV, V and VI — the only colourants, preservatives and UV filters allowed, with their limits
• Article 15 — CMR substances (category 1A, 1B or 2) are prohibited unless specifically allowed
• Article 17 — technically unavoidable traces of prohibited substances are permitted only if the product remains safe
• GB version of the regulation — Regulation (EC) No 1223/2009 as it applies in Great Britain, amended by Schedule 34 to SI 2019/696; GB annex changes are made by UK statutory instruments
• Cosmetic Products Enforcement Regulations 2013, Schedule 4 — breaching Article 14 or 15 is a criminal offence in Great Britain

Official sources:

• Annex II: Prohibited substances, UK version (legislation.gov.uk)
• Annex III: Restricted substances, UK version (legislation.gov.uk)
• Management of CMR substances under the UK Cosmetics Regulation (GOV.UK)
• CosIng cosmetic ingredient database (European Commission)

Why brands choose Phoenix for restricted ingredient checks

• Targeted — we check the ingredients you are worried about, without paying for a full formulation review.
• GB and EU checked — every ingredient is checked against both sets of annexes, with any difference flagged.
• Clear outcome — a pass or flag for each ingredient, with its annex reference, limit and conditions of use.
• Regulator-ready or we revise it free — our compliance guarantee.
• Trusted by 1,400+ brands over 14 years, including The Beard Struggle, The Essence Vault, Parfum Fabric and Junaid Jamshed.
• Fast delivery options — Standard 72 Hours, Fast 48 Hours or Priority 24 Hours.

Know exactly where your ingredients stand. Choose your delivery speed above, or message us on WhatsApp on +44 7346 009332 if you are unsure whether you need this check or a full formulation review.

Frequently asked questions