Cosmética con criterio, no. 1 · By Rodrigo Folgueira, co-founder of Banbu
In short: there is no list of "prohibited endocrine disruptors" in cosmetics in the European Union. Every identified ingredient falls into one of three boxes: prohibited (it cannot be in any cosmetic sold legally), restricted (allowed only below a certain limit and in certain products), or under review (allowed while the European scientific committee evaluates it). Knowing which box each one falls into answers almost all questions when reading a label.
Before Banbu, I worked in engineering for almost ten years: materials testing, calculation, standards. That is where I learned that the question "is this safe?" almost never has a yes or no answer. It has a "under what conditions and up to what limit?".
The same applies to endocrine disruptors. When someone writes to us asking if a cosmetic "contains endocrine disruptors," the underlying question is usually different: is this prohibited?, am I being sold something illegal? Almost always the answer is no. What changes is which box that ingredient falls into.
Why there is no list of "prohibited endocrine disruptors"
Cosmetics in the EU are governed by Regulation (EC) 1223/2009. That regulation does not prohibit a substance simply because it is an endocrine disruptor as a category. The Scientific Committee on Consumer Safety (SCCS) evaluates each substance separately, and based on its opinion, the Commission decides whether to prohibit it or set limits for it in the annexes of the regulation.
The only automatic prohibition is for substances classified as carcinogenic, mutagenic, or toxic to reproduction (CMR). Since 2023, the European chemical classification regulation (CLP) also includes an "endocrine disruptor" category, and from November 1, 2026, it will also apply to substances already on the market. But the cosmetics regulation does not automatically prohibit what is classified as such, as it does with CMR substances.
The three boxes
1. Prohibited
It cannot be in any cosmetic sold in the EU. The 4-MBC (4-Methylbenzylidene Camphor) sunscreen cannot be placed on the market from May 1, 2025, and cannot be sold from May 1, 2026 (Regulation 2024/996). Five parabens (isobutyl-, isopropyl-, phenyl-, benzyl- and pentylparaben) have been prohibited since 2014 (Regulation 358/2014), as have DBP and DEHP phthalates. If you see one of them in something sold today in Spain, the problem is with the product, not you.
2. Restricted
It is legal below a limit and, sometimes, only in certain products. Benzophenone-3 has a maximum of 6% in products for the face, lips, and hands (Regulation 2022/1176). Homosalate, at 7.34% and only in products for the face (Regulation 2022/2195). Propylparaben and butylparaben cannot exceed 0.14% between the two or be used in leave-on products for the diaper area of children under 3 years old (Regulation 1004/2014). Within the limit, the product is legal and safe according to the current evaluation. The problem for the buyer is that the label does not state the concentration, so they cannot check it.
3. Under review
In 2019, the European Commission published a priority list of 28 substances used in cosmetics with possible endocrine-disrupting properties, in two groups of 14. Being on the list does not mean it is prohibited: it is the order in which they are evaluated. The second group contains very common ingredients, such as butylparaben, methylparaben, BHA, the octinoxate filter (Ethylhexyl Methoxycinnamate), and several benzophenones. Today they are legal.
What has happened in seven years
From the first group of 14, the EU has already prohibited 4-MBC and has set or revised limits for benzophenone-3, octocrylene, homosalate, BHT, genistein, daidzein, kojic acid, triclosan, and triclocarban. That is, most have gone from "under review" to "restricted" or "prohibited". Regulation moves slowly, but when it acts, it is usually to set limits, not to remove them.
How to use the three boxes when reading a label
- Look for the list of ingredients (INCI) on the packaging or on the online store product page.
- If you see a familiar name (BHT, Benzophenone-3, Butylparaben...), check which box it falls into. You have the complete table in our guide to endocrine disruptors in cosmetics, and the official source is the European Commission's CosIng database.
- Decide according to the box. Prohibited: it should not be for sale and you can report it to the AEMPS. Restricted or under review: it is legal, and choosing that product or not depends on how much precaution you want to apply.
What we do at Banbu
Our rule is to also exclude ingredients from the "under review" box, even if they are legal today: among others, butylparaben, BHA and BHT, and benzophenone-3. Not because the rest is dangerous, but because we prefer to get ahead of evaluations that are still ongoing. This forces us to look for alternatives and, sometimes, to discard entire formulas. The complete list is in ingredients we do not use.
What is coming
This is the first issue of "Cosmética con criterio". The next one, on Thursday, November 12: what the new European directive requires of environmental claims and what we have changed at Banbu. If there is an ingredient you want us to look at, tell me in the comments on LinkedIn.
Rodrigo Folgueira, co-founder of Banbu.
Frequently asked questions
Is there an official list of prohibited endocrine disruptors in cosmetics?
No. The 2019 list indicates which substances to evaluate first, not which ones are prohibited. Prohibited and restricted substances are in the annexes of Regulation (EC) 1223/2009, which can be consulted in CosIng.
Is an "under review" ingredient dangerous?
Not necessarily. It is legal and is being evaluated. If the SCCS sees a risk, the Commission limits or prohibits it.
What does "without endocrine disruptors" mean on a package?
There is no official European seal. Ask the brand what criteria it follows. At Banbu, we formulate without ingredients recognized as endocrine disruptors and explain it in our guide.
