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- Cosmetic toxicologist at Euverify, specialising in cosmetic product safety, PIF and CPSR preparation, and regulatory compliance with EU and UK Cosmetic Regulations. Conducts toxicological assessments of cosmetic ingredients and formulations, reviews product safety reports and manages CPNP and SCPN product notifications. Dedicated to supporting brands in achieving compliance with EU and UK cosmetic standards.
1% and Done: Understanding the New Kojic Acid Limit in EU and UK Cosmetics Law
Kojic acid has been a go-to ingredient in brightening and tone-correcting skincare for years. However, recent regulatory changes have reshaped how brands can use it in both the EU and the UK. After reviewing concerns about its potential endocrine effects, regulators in both regions introduced new rules under Regulation (EU) 2024/996 and UK SI 2024/1334. As a result, kojic acid is now limited to a maximum concentration of 1% in face and hand products.
These updates mark one of the most significant changes to cosmetic ingredient rules in recent years. They align EU and UK requirements, strengthen consumer safety, and increase oversight of skin-lightening ingredients. For manufacturers, importers, and Responsible Persons, understanding and applying the 1% limit is essential. It affects not only product safety but also compliance, market access, and overall brand trust.
In this article, we explain what the new limit means in practical terms, outline the legal basis in both regions, and offer a clear checklist to help you keep your formulas, documentation, and product claims fully compliant with the updated cosmetics rules.
The 1 % Rule: What It Means for Cosmetic Brands
Kojic acid has not been banned in the EU or the UK, but it is now subject to much stricter rules. Under the latest updates to both the EU and UK Cosmetics Regulations, it can only be used in face and hand products, and only at concentrations of up to 1%. Anything above that level is no longer allowed on the market.
For brands, the message is clear. The limit is 1%, and every product containing kojic acid must follow that rule. Even though the transition deadlines have already passed, compliance is not something you complete once and then forget. Regular formula reviews, updated documentation, and close monitoring of product claims are all essential to keep your products approved for sale in both regions.
2. EU Update: Commission Regulation (EU) 2024/996 Explained
In April 2024, the European Commission introduced one of the year’s most significant cosmetic regulatory updates: Regulation (EU) 2024/996. This amendment revised the main EU Cosmetics Regulation (EC No. 1223/2009) by adding Kojic Acid (CAS 501-30-4) to Annex III, the section that lists restricted substances.
Kojic acid remains permitted in the EU, but the conditions are now very clear. It may only be used in face and hand products, and the concentration cannot exceed 1%. Any product formulated above that level no longer meets EU safety requirements.
To help companies update their formulas, documentation, and supply chains, the regulation introduced two transition dates:
- 1 February 2025 — after this date, non-compliant products could no longer be placed on the market.
- 1 November 2025 — after this date, non-compliant products could no longer be sold or made available to consumers.
The amendment officially took effect on 23 April 2024, which was 20 days after it was published, and it became binding across all EU Member States.
In practical terms, any face or hand product containing more than 1% kojic acid should already have been removed from the EU market and fully withdrawn from sale by late 2025. For brands, this firmly establishes the 1% limit as the standard they must follow moving forward.
UK (Great Britain) Update on Kojic Acid Limit: Same Rules, Different Timing
The UK has adopted a position that is very similar to the EU’s, but it follows its own regulatory process and timeline. Kojic acid was officially restricted through The Cosmetic Products (Restriction of Chemical Substances) (No. 2) Regulations 2024 (SI 2024/1334), which was presented to Parliament in December 2024 and came into effect on 31 January 2025.
“Regulation 2(3) amends Annex 3 to the Regulation to restrict the use of kojic acid in cosmetic products following advice from the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products that there is a potential risk to human health from its use.”
This amendment adds kojic acid to Annex III of the UK Cosmetics Regulation (UKCR), bringing Great Britain in line with the EU’s approach. As in the EU, kojic acid is still allowed in cosmetics, but only in face and hand products and only up to a maximum of 1%.
The UK introduced its own transition dates:
- 20 June 2025 — any product placed on the GB market after this date must meet the 1% limit. Anything above this is considered non-compliant.
- 1 November 2025 — all remaining non-compliant products already on shelves must be removed.
There is one major exception: Northern Ireland still follows the EU Cosmetics Regulation (EC) 1223/2009 under post-Brexit arrangements, which means EU rules and EU deadlines apply there.
For brands selling in Great Britain, the message is straightforward: no face or hand product with more than 1% kojic acid can be placed on the GB market after 20 June 2025, and any leftover non-compliant stock should be fully cleared out by November 2025.
Why the Restriction? The Science Behind the 1% Limit
The move to restrict kojic acid didn’t happen overnight. It followed a detailed scientific review. Between 2021 and 2022, the EU’s Scientific Committee on Consumer Safety (SCCS) assessed the ingredient and concluded that kojic acid can be used safely, but only at lower concentrations. Their findings pointed to possible risks at higher exposure levels, especially related to thyroid function and potential endocrine-disrupting effects.
On the basis of this assessment, the European Commission stated in Regulation (EU) 2024/996 that kojic acid should be limited to a maximum of 1% in cosmetic products to ensure consumer safety.
The UK reached the same conclusion. Its Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS) reviewed the evidence and supported aligning with the EU’s position. Their advice led to the UK’s amendment, SI 2024/1334.
In simple terms, regulators in both the EU and the UK reached the same conclusion: kojic acid does not need to be banned. However, it should only be used within clear safety limits, which means face and hand products at concentrations up to 1%.
Compliance Audit: What to Check Before & After
Deadlines snapshot
- EU: no placement of non-compliant products after 1 February 2025; no making-available after 1 November 2025.
- UK (GB): no placement after 20 June 2025; off-shelf no extension past 1 November 2025.
Common pitfalls
- Using kojic acid above 1% in a hand cream or face serum and selling it after the deadline.
- Forgetting to differentiate between EU and GB timelines (especially if selling cross-border).
- Relying on an old CPSR version (pre-2024) that doesn’t reflect the new restriction.
- Letting “old stock” exceed the off-shelf deadline (many brands assume “old stock” can persist indefinitely).
- Marketing claims implying “skin lightening” as a medical effect, which may trigger different regulatory scrutiny.
Future Outlook: What’s Next After Kojic Acid
The new 1% limit for kojic acid is now firmly in place, but it likely won’t be the last major change to cosmetic ingredient rules. In many ways, this update signals a broader shift in how both the EU and UK are approaching cosmetic safety.
For example, Regulation (EU) 2024/996 also addressed other brightening ingredients like arbutin and alpha-arbutin, showing that regulators are paying much closer attention to skin-lightening agents as a whole. On top of that, authorities on both sides of the Channel are increasing their scrutiny of ingredients that may have endocrine-disrupting effects. More reviews and potentially more restrictions are expected in the future.
It’s not just ingredients that are evolving. Cosmetic claims such as “brightening,” “even tone,” and “pigment correcting” are being examined more carefully, which means brands need to make sure their formulas, documentation, and marketing stay fully aligned with the rules.
In short, cosmetics compliance isn’t something you check off once and forget about. It’s an ongoing responsibility. Brands that regularly monitor regulatory updates and review their product lines will be in a much stronger position as more ingredient evaluations and rule changes come into effect.
To help you stay informed, we’ve created dedicated resources that outline:
- Banned and restricted cosmetic ingredients in the UK
- Upcoming cosmetic ingredient bans and potential restrictions in the EU
These guides provide clear, up-to-date insights that can help you plan ahead, adjust your formulations early, and maintain compliance as regulations evolve.
How Euverify Can Help with Cosmetics Compliance
Now that the 1% limit for kojic acid is fully in effect across both the EU and the UK, many brands are still working through the practical steps. This includes adjusting formulas, revising safety files, and making sure all documentation is up to date. It can feel like a lot to manage, but you don’t have to handle it on your own.
Euverify offers end-to-end support to help you stay compliant, including:
- Regulatory gap analysis to pinpoint any issues in your formulations, supplier information, documentation, or market deadlines
- CPSR and PIF updates so your safety assessments align with the latest EU and UK rules, plus complete label reviews to make sure your packaging and claims are compliant.
- Responsible Person services for both regions, ideal for brands operating across multiple markets
- Setting up and maintaining company accounts on the CPNP (EU) and SCNP (UK) notification systems
Whether you need help with a single update or ongoing regulatory support, Euverify makes it easier to keep your products safe, compliant, and ready for market.
Conclusion: “1% and Done” Doesn’t Mean Finished
The 1% limit for kojic acid in face and hand products is now set in both the EU and the UK, but reaching that limit is only the beginning. Cosmetic rules keep changing, ingredient reviews continue, and claims around brightening and tone correction are being looked at more closely. Because of this, compliance is something that needs regular attention, not a one-time update.
If brands treat this change as a single task, they may fall behind future requirements. Keeping formulas, documents, notifications, and marketing claims up to date is key to staying compliant and protecting your reputation.
A steady, ongoing approach to compliance is now essential. With support from Euverify, you can keep ahead of new rules and stay confident that your products are ready for the market.
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