There is a deadline that directly concerns dermocosmetics shelves and that most pharmacies have not yet put on their calendars: by May 1, 2027, retinol cosmetics that exceed the new limits may no longer be made available on the market. This does not mean a recall, nor does it mean that the product is unsafe. It means that those products must be sold beforehand, and that after that date they will remain unsellable.
Let’s go through what the regulation says, what it means for inventory, and how to respond to a customer who asks 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% retinol equivalent in body lotions;
- 0.3% retinol equivalent in other cosmetic products, including face serums and 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 overall vitamin A exposure, combining cosmetics, food, and supplements. The risk being considered is vitamin A hypervitaminosis, 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 pharmacological active ingredient, available only by prescription. If a customer confuses it with cosmetic retinol, it is worth clearly distinguishing the two right away.
The two dates that matter
The regulation distinguishes between two moments, and the difference is exactly what matters to anyone holding inventory.
- November 1, 2025: ban on placing non-compliant products on the market. From that date, a company may no longer introduce a cosmetic that exceeds the limit into the EU market. This date concerns manufacturers.
- May 1, 2027: ban on making available on the market. This is the date that concerns pharmacies, because selling to the public constitutes making a product available. After that date, the product may no longer be sold.
There is a sell-through period for existing stock between the two dates. At the time of writing, a little over a year and a half remains—less than it may seem for a slow-moving product.
What to do with inventory, concretely
Three steps, in order.
1. Identify the products concerned
A full audit is not necessary: focus on products that state a retinol percentage above 0.3% in their communications, typically anti-aging serums with 0.5%, 1%, or 2%, and body lotions with declared retinol content. These products are recognizable 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 may legitimately remain on sale until the 2027 deadline, but it is also the product most likely to reach that date with little usable life remaining. The practical criterion is twofold: the regulatory deadline and the product’s expiry date, with the earlier one taking precedence.
3. Reduce replenishment, not advice
The temptation is to clear the shelf and close the chapter on retinoids. That would be a commercial mistake: demand for this active ingredient is not declining; it is changing form. Anyone who used to ask for 1% will ask what to use now, and that question will come to the counter, not the shelf.
How to respond to the customer
The question is almost always some variation of this: “There used to be a 1% product, but now I can’t find it. Does that mean it was harmful?”
The honest answer is that the limit does not arise from harm observed on the skin, but from calculating overall vitamin A exposure. And when it comes to the skin, dermatological literature is meanwhile consistent on one point that is useful at the counter: above a certain threshold, concentration does not add results—it adds irritation. Many customers who used 1% used it incorrectly, every other day, with repeated breaks due to burning and flaking, and achieved less than they would have with a lower concentration used every evening.
This is a shift in the conversation that the counter can support but the shelf cannot: you stop selling a percentage and start selling long-term tolerability.
Alternatives to consider
None replaces retinol, but all can be recommended to people who do not tolerate it or are looking for a more gradual approach: bakuchiol, peptides targeting 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 an unusable selling point shifts the competitive advantage toward those who know how to explain. On a mass-market shelf or an e-commerce site, “1%” was a self-sufficient message. When that message is no longer available, the only thing guiding the choice is advice from a knowledgeable person.
That is 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 April 3, 2024, amending Regulation (EC) No 1223/2009 with regard to 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 on the market and making available on the market.
On the website: retinol in the ingredient glossary · Regulation (EU) 2026/78 and CMR substances · cosmetic expiry dates and PAO · average discounts and margins in dermocosmetics.
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Our products are distributed exclusively through partner pharmacies. For a regulatory change like this, we provide the formulation data for our products so that advice at the counter can be given with the numbers at hand.
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