Prohibited vs Restricted Cosmetic Ingredients

Short Answer

Prohibited and restricted are different regulatory states. A prohibited entry closes a use case under the applicable rule; a restricted entry requires the reviewer to test the actual product and conditions against the source before deciding whether the use fits.

Key Takeaways

• Read the category and source wording before interpreting the result.
• Keep product type, use context and conditions in the decision record.
• Never transfer an annex entry between markets without a separate source check.

Who This Applies To

This article is for regulatory reviewers and formulators comparing EU and ASEAN ingredient restrictions. The source and jurisdiction must remain explicit for every decision.

Regulatory Background

EU and ASEAN official materials distinguish rule categories and publish them in their respective regulation or annex structure. A review must cite the source that governs the selected market rather than infer a status from a different list. [20][27][30__annex-ii][30__annex-iii]

Key Requirements

The reviewer must preserve the exact category, source section and conditions that support the decision. A shortened label such as “restricted” is not enough when the entry contains product or use qualifiers. [20][30__annex-ii][30__annex-iii]

• Confirm the exact substance identity.
• Identify the governing annex or list.
• Match product type and use to the entry.
• Capture conditions, warnings and scope limits.
• Record reviewer decision and unresolved questions.

Step-by-Step Review

Resolve identity and market first. Read the governing annex in context, including category and conditions. Compare those conditions with the actual formula and label plan. Finish with a decision that names the source locator and evidence still needed for launch.

Common Mistakes

• Using a restricted entry without checking its conditions.
• Treating a prohibited entry as a concentration question.
• Combining EU and ASEAN annexes into one universal ingredient status.

Practical Checklist

• Rule category is explicit.
• Governing annex and locator are cited.
• Product and use conditions are matched.
• Cross-market transfer is separately reviewed.
• Open points have a reviewer and date.

How EasyComply Can Help

EasyComply can keep rule category, conditions and market-specific evidence visible in one review record, so a team knows whether the next action is to stop, adjust, document or escalate.