What the new retinol rules mean for beauty brands

This article is part of our Vogue Business membership package. To enjoy unlimited access to our weekly Beauty Edit newsletter, which contains Member-only reporting and analysis, the Beauty Trend Tracker and Leadership Advice, sign up for Vogue Business membership here. “Everyone’s always talking about retinol because it helps with acne, hyperpigmentation, skin texture, skin tone and even wrinkles,” says mega influencer Dermdoctor in a TikTok to his 18.1 million followers. Retinol — a form of vitamin A used in skin products — has become one of the beauty industry’s biggest buzzword ingredients thanks to its proven effectiveness. But as its use has spread like wildfire, it has sparked safety concerns — and regulators have stepped in. The problem is that Vitamin A is also in food and food supplements, which means consumers may be absorbing too much of it without realising. While safe in recommended doses, some research suggests that overexposure to vitamin A over many years may affect the bones, making them more likely to fracture in old age. In skincare, too much retinol can cause irritation, redness, peeling and swelling, also known as ‘retinol burn’; acne flare-ups known as ‘retinol purging’; or, in very rare, extreme cases, vitamin A toxicity, with symptoms including nausea, headaches, vomiting, blurred vision and dizziness. After studying its effects, the European Union’s Scientific Committee for Consumer Safety (SCCS) concluded that “there is a potential risk to human health arising from the use of vitamin A in cosmetic products when its concentration exceeds certain levels”. As a result, in June 2023, the European Union drafted a regulation to restrict the concentration of Vitamin A in cosmetics (namely retinol and its less potent cousins retinyl acetate and retinyl palmitate). The EU has ruled that the use of retinol, retinyl acetate and retinyl palmitate should be restricted to a maximum concentration of 0.05 per cent in body lotion and 0.3 per cent in other leave-on and rinse-off products. Additionally, products will have to include a visible warning label: “Contains vitamin A-related compounds, which contribute to your daily intake of vitamin A.” These restrictions will come into force in the EU and Northern Ireland over a 36-month period. From 1 November 2025, no new products can enter the market unless they comply with the regulations and from 1 May 2027, all non-compliant products will be removed from shelves. The UK authorities have not yet begun a review of retinol in cosmetic products but are expected to follow suit in the near future. What it means for brands Retinol can be found in a wide range of formulas across a gamut of price points, from Q+A’s retinol 0.2 per cent facial serum (£12) to La Roche-Posay’s 0.3 per cent retinol B3 anti-ageing serum (£48) and, at the luxury end, Augustinus Bader’s 0.06 per cent intense renewal serum (£280). Currently, 1 per cent retinol is the maximum strength available without a prescription, but between 0.03 to 0.3 per cent is deemed moderate, according to Caroline Rainsford, director of science at the Cosmetic, Toiletry and Perfumery Association (CTPA). There are several products currently available online that have the maximum concentration, including Paula’s Choice 1% Retinol Booster, The Ordinary’s Retinol 1% in Squalane and Medik8’s Intelligent Retinol 10TR. However, most products contain much lower amounts. “Many brands are unlikely to need to make changes to the concentration of retinol compounds in their products,” says Rainsford. Those with products that are no longer compliant are weighing up next steps. The Inkey List currently stocks three retinol-based products, one of which — a scar, mark and wrinkle solution — is not compliant with the new EU rules. The brand plans to shift the stock to North America, where it can still be sold. Co-founder Mark Curry says the EU regulations feel overcautious but stresses: “We will, of course, adhere to the regulations and withdraw this from the EU market accordingly.” It’s going to cost: “Moving unsold stock out of the region will be an expensive exercise,” he says. “The strategy will be to minimise and run down stocks.” Medik8 will discontinue two of its six retinol-based products in the EU and redirect this stock to other markets. This discontinuation will not be communicated to consumers; instead, Medik8 will push an alternative that is “superior to retinol”, says Daniel Isaacs, Medik8 chief product officer. This push will be done via both the brand’s core marketing strategy and through dermatologist-turned-social-media-influencer ambassadors. “Globally, 82 per cent of our retinoid units sold are from our Crystal Retinal Franchise vs 15 per cent of our retinol products. Due to this, we will be redistributing a small amount of stock, but don’t foresee a business impact,” Isaacs adds. “Retinaldehyde and retinyl retinoate are not being restricted in skincare because they act differently on the skin to retinol,” says Isaacs. “The majority of our consumers already use retinaldehyde in our Crystal Retinal range; therefore, the restrictions will not impact them.” Those who search for discontinued retinol products will be redirected to the Crystal Retinal range. The new regulations apply only to off-the-shelf products. Brands like And Begin, which works with dermatologists to prescribe a tailored skincare regime for customers following a three-minute online consultation, are therefore exempt. “If you’re working with a doctor or dermatologist who has prescribed you specialist retinol products, your regime shouldn’t be affected as these products are exempt from the new cosmetic regulation,” says Horatio Cary, And Begin founder. Will the regulations prompt a customer backlash? So far, it seems unlikely. Brand owners and experts note that many customers aren’t aware of the impending changes, and may never be given many existing retinol products are already compliant with the new limits. “Skincare junkies are aware of the regulatory changes, but many normal folks (aka the majority) are still going about their lives and skincare routine as normal, so changes are not hitting consumers as yet,” says Curry. “They may know retinol, but perhaps not intimately enough, and so when they do care or are struck by an aha moment to use retinol, they will purely act on what’s there [on the market at the time],” he adds. Brands could turn the new regulations into an advantage. “Regulatory changes, such as retinol restrictions, pose opportunities as well as challenges for brands,” says Susanne Krenz, principal research analyst for beauty and personal care at Mintel. Consumers increasingly prioritise active ingredients and seek proof of efficacy, Mintel research shows. “Brands that stay abreast of such legislation, ideally while striving to improve product stability and efficacy, will be able to keep consumers engaged in a highly saturated market.” She adds that the regulations may spur more innovation. For example, more brands may experiment with bio-retinol, a non-vitamin A-derived retinol alternative made from plants such as bidens pilosa, bakuchiol and some algaes. It mimics the effects of retinol without the harsh side effects, and is not included in the new EU regulations. Brands already using bio-retinols include Espa’s tri-active regenerating bio-retinol sleeping serum, Bondi Sands Fountain of Youth bakuchiol serum and Algenist’s green microalgae retinol + regenerating serum. Pai Skincare has seen success with its bio-retinol skin renovating booster, it says, which already features the new Vitamin A warning label. Despite only launching in October 2023, it’s the second bestselling booster in the collection of seven and is one of the first naturally derived true retinoids available. The brand continues to “educate our consumers on key actives and how to incorporate them correctly and confidently into a skincare routine at the right dosage, time of day, and with the right regularity”, says Sarah Brown, Pai Skincare CEO. “Ingredients can fall in and out of trend, but key actives, such as retinol (vitamin C would be an example of another), tend to stand the test of time and have staying power thanks to their proven efficacy,” she adds, noting that most retinol products on the market will fall under the new restrictions with only a “minority of brands needing to reformulate or change their consumer comms for their retinol products”. Ultimately, “changes to how ingredients are regulated in cosmetics are published several times per year in the EU and UK,” says Rainsford, the new retinol restrictions being just one example. New restrictions will simply prompt an acceleration in innovation when it comes to ingredients and formulas. “Retinol certainly won’t be going anywhere, of that we can be sure,” says And Begin’s Cary. Comments, questions or feedback? Email us at feedback@voguebusiness.com.

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