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EU vs. US Cosmetics: Why European Skincare Is Held to a Higher Standard

by Nana Latta on Aug 25, 2026
Handmade Nana Latta tallow skincare range in a basket, made in Belgium under EU cosmetic law

Imagine picking up a jar and knowing — without decoding a single syllable on the back — that everything inside it has already been checked, signed off and legally vouched for before it ever reached you. That is what buying European skincare actually buys you. The EU bans more than 1,700 substances from cosmetics and requires a qualified safety assessment of every product before it can be sold; the US federal list of prohibited or restricted cosmetic ingredients runs to roughly a dozen. Same shelf, same pretty jars — very different homework behind them.

Tallow + Jojoba Minimalist Butter, unscented, handmade in Belgium

The whole label, in two words

Tallow + Jojoba Minimalist Butter

Grass-fed Belgian tallow and jojoba. That is the entire ingredient list — no fragrance, no preservative, nothing to look up. It melts in like a second skin and quietly replaces the shelf. Award-winning, made by hand, safety-assessed under EU law before a single jar was sold. €28,90.

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Handmade in Belgium

Ships worldwide · free shipping available

Prices in your own currency · calculated at checkout

The gap, in one number

Annex II of the EU Cosmetics Regulation (EC) No 1223/2009 is the list of substances that simply may not go into a cosmetic sold in Europe. It is updated several times a year by omnibus amendments, and it now runs to more than 1,700 entries — carcinogens, mutagens, reproductive toxicants and anything else the EU's independent Scientific Committee on Consumer Safety has flagged.

The comparable American list is short. The FDA states plainly that with the exception of color additives and a few prohibited ingredients, a cosmetic manufacturer may use almost any raw material as a cosmetic ingredient and market the product without an approval from FDA, and names bithionol, mercury compounds, vinyl chloride, halogenated salicylanilides, zirconium complexes in aerosols, chloroform, methylene chloride, chlorofluorocarbon propellants and hexachlorophene (FDA, Prohibited Ingredients).

That is the headline difference, and it is real. But the count of banned ingredients is only the visible tip. The deeper difference is when the safety work happens.

1,700+ banned

Substances prohibited outright in EU cosmetics under Annex II — versus roughly a dozen restricted or prohibited at US federal level.

Signed off first

Every EU product needs a Cosmetic Product Safety Report written by a qualified assessor before it goes on sale. Not after a complaint.

No animal testing

Banned for ingredients since 2009 and for marketing since March 2013 — including products tested outside the EU.

Claims must be provable

If a European brand says it, it has to be able to show the evidence in a file an inspector can ask for.

★★★★★✓ Verified

“The best product I've ever purchased for my skin — I'm 35, with sensitive, acne-prone, rosacea-prone skin.”

Danielle · review via Judge.me

What has to happen before a European jar can be sold

This is the part almost nobody outside the industry knows, and it is where the real protection lives. Under Regulation 1223/2009, a cosmetic cannot legally be placed on the EU market until four things exist.

A named Responsible Person. Every product has a real, identifiable legal person inside the EU who answers for it. Not a brand name — a person or company with an address, reachable by an inspector.

A Cosmetic Product Safety Report. A qualified safety assessor — someone holding a degree in pharmacy, toxicology, medicine or a comparable science — reviews the formula, the exposure, the intended user and the toxicological profile of every ingredient, then signs a document taking responsibility for its safety. This happens before the first jar sells.

A Product Information File. The full dossier — formula, method of manufacture, safety report, stability and preservation testing, and the evidence behind every claim — kept available to authorities for ten years.

Notification to the CPNP. The product is registered in a central EU portal so poison centres and market-surveillance authorities know exactly what is in circulation and what is in it.

None of that is optional, and none of it scales down for small brands. A two-ingredient jar made by hand in a Belgian workshop goes through the same gate as a global launch. It is slow and it is expensive — and it is the single best reason to trust what you are putting on your face.

Laura, founder of Nana Latta

When I was pregnant, I became so conscious of what I was putting on my baby's skin. It looked so fragile and soft — I couldn't imagine those plastic bottles full of unreadable ingredients belonged anywhere near it. That's when I switched to only natural skincare myself. It was impossible to find here, so I ordered it online from a small company abroad. Just a few years later I was making my own tallow balm. — Laura, founder

The American system — and what MoCRA did and didn't change

The US is not unregulated. It is regulated differently: the Federal Food, Drug, and Cosmetic Act makes it illegal to sell a cosmetic that is adulterated or misbranded, and the FDA can act when a product causes harm. The distinction is that the American model has historically been post-market — the agency steps in after a problem, rather than requiring proof of safety beforehand.

The Modernization of Cosmetics Regulation Act (MoCRA), signed at the end of 2022, was the biggest expansion of FDA cosmetics authority since 1938, and it genuinely narrows the gap. It requires facility registration and product listing, mandatory serious-adverse-event reporting, records access, safety substantiation, good manufacturing practice rules and — for the first time — mandatory recall authority.

What MoCRA did not do is create a European-style pre-market gate. There is still no requirement for an independent qualified assessor to sign off each formula before sale, no central notification of full composition, and no mechanism that automatically bans an ingredient the way an EU omnibus amendment does. Two different philosophies: prove it is safe first, or prove it is harmful later.

Worth being fair about: a longer ban list is not by itself a safety guarantee, and plenty of American brands formulate beautifully and voluntarily to EU standards. The EU approach is precautionary — it removes substances on the basis of hazard classification, sometimes before real-world harm is demonstrated. That is a philosophical choice rather than proof of superiority for every single product. It does, however, mean the burden of proof sits with the brand instead of with you.

EU vs US cosmetics rules at a glance

What matters to you European Union United States
Prohibited ingredients 1,700+ substances (Annex II), updated several times a year Roughly a dozen restricted or prohibited by regulation
Safety check before sale Mandatory safety report by a qualified assessor No pre-market assessment; safety substantiation under MoCRA
Full formula filed with authorities Yes — CPNP notification + 10-year Product Information File Product listing under MoCRA; no EU-style dossier
Animal testing Banned; marketing ban since March 2013, including testing done abroad No federal ban (several state-level sales bans exist)
Marketing claims Must meet six common criteria and be backed by evidence on file Must not be false or misleading; no equivalent evidence-file rule
Fragrance allergens on the label 82 named allergens declared on new products from 31 July 2026 Fragrance may be listed as a single word

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Short ingredient lists, made by hand in Belgium. Join us for 10% off your first order and first access to our small-batch restocks.

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New in 2026: 82 fragrance allergens, named on the label

Here is a change worth knowing about, because it lands this summer. Commission Regulation (EU) 2023/1545 expands the list of fragrance allergens that must be individually named on a cosmetic label from 24 to roughly 82. From 31 July 2026, every new product placed on the EU market has to declare any of them present above 0.001% in a leave-on product or 0.01% in a rinse-off one. Products already on shelves have until 31 July 2028.

In practice, a European label is about to get dramatically more honest about what parfum was covering. If you have reactive skin, or you have ever broken out from a cream and never worked out which part did it, this is the rule that will finally let you name the culprit.

It is also the clearest argument for keeping a formula short in the first place. Our Minimalist Butter and Tallow Soap Bar contain no fragrance at all — there is nothing on that list of 82 to declare, this year or any year.

Animal testing: the line Europe drew and never crossed back over

The EU phased out animal testing for cosmetics in stages under what is now Article 18 of Regulation 1223/2009: finished products from 11 September 2004, ingredients from 11 March 2009 and — the decisive one — a full marketing ban from March 2013. Since then it has been illegal to sell a cosmetic in the EU that relied on animal testing for its safety data, even if that testing happened outside Europe. That last clause is what gives the ban teeth.

There is no equivalent federal ban in the United States. A number of individual states have passed their own sales bans, and many American brands are certified cruelty-free by choice — but there it is a company decision, whereas in Europe it is the floor everyone stands on.

Why European brands can't just say anything

The rule that quietly shapes every word on a European jar is Commission Regulation (EU) No 655/2013, which sets six common criteria for cosmetic claims: legal compliance, truthfulness, evidential support, honesty, fairness and allowing informed decisions. Every claim — text, image, trademark or implication — must be backed by adequate and verifiable evidence kept in the Product Information File (European Commission technical document on cosmetic claims).

We feel that rule constantly, and we are glad of it. Our Tallow Sun Balm contains 20% zinc oxide, and we could sell a great deal more of it if we were willing to put an SPF number on the pot. It has not been SPF-tested, so we make no protection claim — we describe what it is and let you decide. That is the standard the law asks for, and the standard we would want anyway.

What this means for your skin type

Dry skin

Fewer ingredients, more lipids. The Minimalist Butter gives your barrier the fats it recognises, with nothing extra to react to.

Oily skin

Skip the long oil-free ingredient decks. Tallow and jojoba both mirror your own sebum, so skin settles instead of overproducing.

Sensitive skin

The 2026 allergen rules exist for you. Until then the safest label is a short one — Family Daisy with chamomile and raspberry is our gentlest face cream.

Acne-prone skin

Fragrance and heavy waxes are the usual troublemakers. Cleanse with the unscented Tallow Soap Bar and finish with the Minimalist Butter.

Mature skin

Fancy Rose pairs bakuchiol and rosehip with a tallow base — gentle renewal, on a formula that had to be signed off before it reached you.

We love our international clients 🌍

Reading from the US or Canada? We ship worldwide from Belgium, with free shipping available and prices shown in your own currency. Every jar is handmade under EU cosmetic law — the same rules described above, applied to a two-ingredient butter made in small batches. If you have ever wanted to buy skincare without doing your own toxicology homework, this is the shortest route to it.

Bring the European standard home

Short labels, signed off before they shipped

Handmade in Belgium under EU cosmetic law. Prices shown in your own currency at checkout.

Tallow + Jojoba Minimalist Butter

Minimalist Butter

Two ingredients, no fragrance. The whole label fits on one line. €28,90

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Tallow Butter Family Daisy

Family Daisy

Chamomile and raspberry. Our gentlest face cream, from age three up. €36,90

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Tallow Minimalist Soap Bar, unscented

Tallow Soap Bar

Tallow and castor oil, cold process, unscented. Cleansing without the strip. €12,90

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Want the three face butters together? The Face Trio is €98,90.

Shop all tallow skincare

Frequently asked questions

How many ingredients are banned in EU cosmetics compared to the US?

The EU prohibits more than 1,700 substances in cosmetics under Annex II of Regulation 1223/2009, a list updated several times a year. At US federal level, roughly a dozen ingredients are restricted or prohibited by regulation, and the FDA states that a manufacturer may otherwise use almost any raw material without prior approval.

Does the FDA approve cosmetics before they go on sale?

No. With the exception of colour additives, cosmetics are not FDA-approved before marketing. MoCRA added facility registration, product listing, adverse-event reporting, safety substantiation and recall authority, but it did not introduce a European-style pre-market safety assessment.

What is a Cosmetic Product Safety Report?

It is the safety dossier the EU requires for every cosmetic before sale. A qualified assessor with a degree in pharmacy, toxicology, medicine or a similar science reviews the formula, the ingredients' toxicological profiles and realistic exposure, then signs off. It sits inside the Product Information File, which must be available to authorities for ten years.

Is European skincare always safer than American skincare?

Not automatically for every individual product — plenty of US brands formulate to European standards voluntarily. What differs is where the burden of proof sits. In the EU a brand must demonstrate a product's safety before selling it; the US system leans on acting once a problem appears. If you would rather not audit ingredients yourself, the EU model does more of that work for you.

What changes for cosmetic labels on 31 July 2026?

Under Commission Regulation (EU) 2023/1545, the number of fragrance allergens that must be named individually on the label rises from 24 to roughly 82. New products placed on the EU market from 31 July 2026 must comply; products already on the market have until 31 July 2028. Fragrance-free products such as our Minimalist Butter have nothing to declare.

Related reads

  • Choosing European Skincare: Why Clean Tallow Beats Synthetic Alternatives
  • The Truth About SLS in Soap — And Why Tallow Soap Is Different
  • The Best Natural Skincare Brands in Belgium 2026
  • Belgium's First Tallow Skincare Brand: Why We Grew Slowly, on Purpose
Laura, founder of Nana Latta

Laura, founder of Nana Latta

Formula Botanica-trained skincare formulator and health coach, founder of Belgium's first tallow skincare brand — grass-fed tallow, made by hand.

Tags: Belgium, clean beauty, EU cosmetics regulation, fragrance allergens, ingredient safety, MoCRA, natural skincare, tallow
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