Retinol in pharmacies: what will change by May 2027

There is a deadline that directly affects dermocosmetics shelves and that most pharmacies have not yet added to their calendars: by May 1, 2027, retinol cosmetics that exceed the new limits can no longer be made available on the market. This does not mean a recall, nor does it mean the product is unsafe. It means these products need to be sold beforehand, and after that date they can no longer be sold.

Let's lay out what the regulation says, what it means for stock, and how to answer a customer asking why her 1% serum has disappeared.

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What Regulation (EU) 2024/996 establishes

Commission Regulation (EU) 2024/996 of April 3, 2024, amends Regulation (EC) No 1223/2009 and introduces concentration limits for vitamin A in its cosmetic forms: Retinol, Retinyl Acetate and Retinyl Palmitate.

• 0,05% of retinol equivalent in body lotions;
• 0,3% of retinol equivalent in other cosmetic products, including serums and face creams.

There is also a labeling requirement: products containing these substances must indicate the presence of vitamin A, because the legislator's reasoning concerns a person's total vitamin A intake, taking cosmetics, food, and supplements together. The risk of concern is hypervitaminosis A, not skin irritation.

A clarification that is useful at the counter: retinoic acid, or tretinoin, is not covered by this regulation. It is not a cosmetic and never has been: it is a pharmaceutical active ingredient, available only by prescription. If a customer confuses it with cosmetic retinol, it is worth explaining the difference right away.

The two dates that matter

The regulation distinguishes between two stages, and the difference is exactly what matters to anyone with stock on hand.

1. November 1, 2025: ban on placing non-compliant products on the market. From that date, companies can no longer introduce a non-compliant cosmetic product to the EU market. This date affects manufacturers.
2. May 1, 2027: ban on making available on the market. This is the date that affects pharmacies, because selling to the public counts as making a product available. After this date, the product can no longer be sold.

Between the two dates, there is a window for clearing stock. At the time of writing, just over a year and a half remains, which is less time than it may seem for a slow-moving product.

What to do with your stock, specifically

Three steps, in order.

1. Identify the affected products

There’s no need for a full audit: focus on products that advertise a retinol concentration above 0.3%, typically anti-aging serums at 0.5%, 1% or 2%, and body lotions that list retinol. These products are easy to identify precisely because the percentage is their selling point.

2. Check the production date, not just the PAO

A product placed on the market before November 2025 can legally remain on sale until its 2027 expiry date, but it’s also the product at risk of reaching that date with little shelf life left. There are two practical criteria: the regulatory deadline and the product’s expiry date; whichever comes first applies.

3. Reduce restocking, not recommendations

The temptation is to clear the shelf and end the conversation about retinoids. That would be a commercial mistake: demand for this active ingredient isn’t going down; it’s changing shape. Customers who asked for 1% will ask what to use now, and that question comes to the counter, not the shelf.

How to respond to customers

The question customers ask is almost always some version of this: “It used to be available at 1%, but I can’t find it anymore. Does that mean it was harmful?”

The honest answer is that the limit isn’t based on any harm detected on the skin, but on a calculation of overall vitamin A exposure. In the meantime, dermatological literature agrees on one point that’s useful at the counter: above a certain threshold, a higher concentration doesn’t improve results; it just increases irritation. Many customers who used 1% applied it poorly, using it every other day and stopping repeatedly because of burning and peeling. They got less out of it than they would have from a lower concentration used every night.

It’s a shift in the conversation that the counter can support, but the shelf can’t: you stop selling a percentage and start selling tolerability over time.

Alternatives to recommend instead

None can replace retinol, but they are all worth considering for anyone who can't tolerate it or wants a more gradual approach: bakuchiol, peptides that target expression lines, and niacinamide for renewal with good tolerability. For reactive skin, they are often the most sensible choice, regardless of the regulation.

Why this deadline is an opportunity for pharmacies

A regulation that makes the percentage on the label unusable as a selling point shifts the competitive advantage to those who know how to explain. On supermarket shelves or in an e-commerce store, "1%" was a self-explanatory message. Once that message is gone, the only thing that guides the choice is advice from a knowledgeable person.

That's why we distribute exclusively through pharmacies: our formulas are designed to be explained, not to shout a number.

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Sources for this article

Commission Regulation (EU) 2024/996 of 3 April 2024 amending Regulation (EC) No 1223/2009 as regards the use in cosmetic products of vitamin A, alpha-arbutin and arbutin, and certain substances with potential endocrine-disrupting properties: Annex III, entries relating to Retinol, Retinyl Acetate and Retinyl Palmitate. Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products, Article 2 for the definitions of placing and making available on the market.

On our website: retinol in our ingredient glossary · EU Regulation 2026/78 and CMR substances · cosmetic expiry dates and PAO · average discounts and margins in dermocosmetics.

Working together on consultations

Our products are distributed exclusively through partner pharmacies. In response to a regulatory change like this, we make formulation data for our products available so pharmacists can advise customers with the facts at hand.