What the law says and what we do at Banbu
When we talk about safe cosmetics, one of the most important concepts —and one often unknown to the consumer— is that of CMR substances: those classified as carcinogenic, mutagenic, or toxic for reproduction. In other words, substances that can alter DNA, induce cancer, or affect fertility and embryonic development.
At first glance, one might think that these substances are totally prohibited in cosmetic products. And, indeed, Regulation (EC) No 1223/2009 establishes this in its Article 15. However, the reality is more complex: there are legal exceptions, and some of these substances can be present in trace amounts —especially in natural ingredients such as essential oils or plant-based perfumes.
Today we want to explain this situation to you clearly, based on legal and scientific grounds, and tell you how at Banbu we decided to go beyond what the regulations require, to guarantee cosmetics that are truly free of controversial ingredients.
What are CMR substances and how are they regulated?
CMR substances are grouped into three categories:
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C1, M1, R1: Sufficient evidence of carcinogenicity, mutagenicity, or reproductive toxicity in humans.
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C2, M2, R2: Limited evidence in humans but sufficient in animals.
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C3: Possible risk, still under evaluation.
The Regulation (EC) No 1223/2009, which governs cosmetic products in the European Union, expressly prohibits the use of substances classified as CMR in cosmetic products (Art. 15.1). Nevertheless, the same article opens the door to exceptions:
“A substance classified as a CMR may be used in cosmetic products if it has been evaluated by the Scientific Committee on Consumer Safety (SCCS) and is considered safe for cosmetic use, and if there is no suitable alternative” (Art. 15.2).
In other words, “official” safety is based on case-by-case evaluations, which implies that a CMR substance can be legally present if it has been authorized by the SCCS.
And what about impurities?
Although the law prohibits the intentional use of CMRs, it does not address their presence as impurities or unwanted residues, which is legal as long as they remain below certain thresholds.
This occurs especially in ingredients of natural origin, such as essential oils or complex extracts. In these, traces of substances such as the following have been identified:
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Benzene
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Toluene
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Formaldehyde
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Furans
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Nitro musks
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Polycyclic aromatic hydrocarbons (PAHs)
These traces can come from synthesis, the type of extraction, or the cultivation itself, and are not declared on the INCI because they are not an active part of the formula.
Even in natural or organic cosmetics, these accidental presences are common and are permitted by current regulations if they are found below the established limits.
The “cocktail effect”: a problem still without regulation
One of the great current scientific challenges is the combined effect or “cocktail effect”: the cumulative interaction of multiple substances at low doses, each within the legal threshold, but which together can have an unforeseen biological effect, especially on the endocrine system.
According to the European Commission report (Kortenkamp et al., 2007) and numerous subsequent studies, this phenomenon is not adequately considered in current regulations, which implies that the real risk could be underestimated.
📚 Key references:
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Kortenkamp, A., et al. (2007). State of the Art Report on Mixture Toxicity. European Commission.
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Vandenberg, L. N., et al. (2012). Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses. Endocrine Reviews, 33(3), 378–455.
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WHO/UNEP (2013). State of the Science of Endocrine Disrupting Chemicals.
What does Banbu do in the face of this scenario?
At Banbu, we do not settle for the legal minimum. Our philosophy starts from the precautionary principle and a formulation ethic that is stricter than what is required by law.
What does this mean in practice?
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✅ We do not use any ingredient classified as CMR, even if it is authorized by the SCCS.
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✅ We demand technical data sheets and purity analyses that guarantee the total absence, even in traces, of CMR substances.
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✅ We reject ingredients suspected of containing dangerous impurities, even if they are natural.
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✅ We apply cumulative toxicology criteria to avoid ingredients that may contribute to combined effects.
In addition, our formulas are aligned with stricter regulations such as COSMOS and we follow expanded safety guidelines that include:
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Green Chemistry.
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Environmental and social impact assessment of ingredients.
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Compatibility with sensitive skin, pregnancy, and hormonal conditions.
Why do we say we are a CMR-free brand?
Our claim of being CMR-free is not just based on compliance with Regulation 1223/2009. It is based on:
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Exhaustive control of every raw material, not just the final product.
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Active review of the database of substances classified by ECHA (European Chemicals Agency).
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Constant updates regarding new toxicological classifications.
Conclusion
The presence of CMRs in cosmetics is not a myth, even though their intentional use is prohibited. Traces, residues, and combined effects are a documented reality, although they receive little visibility in the sector.
At Banbu, we believe that the consumer deserves complete, honest, and technically sound information to make truly conscious decisions. For this reason, our commitment is clear: to offer you safe, ethical cosmetics with scientific—not just legal—criteria.
