Q.01

How do I use the EU CosIng database to look up a cosmetic ingredient's INCI name and its regulatory status under Regulation (EC) 1223/2009 (annex entries, restrictions, functions), and how reliable is CosIng legally?

CosIng is the Commission's reference tool for the Cosmetics Regulation. It is not the law. Use it to find the INCI name and the Annex entry, then check that entry against the consolidated text of Regulation (EC) 1223/2009 on EUR-Lex.

Approach

I read the current consolidated text of Regulation (EC) 1223/2009 (version dated 1 May 2026). That covered Articles 2, 19 and 33, the headers of Annexes II, III, V and VI, and recital 47 of the original 2009 act. I also checked the Commission's glossary under Decision (EU) 2019/701. None of the registries I can search holds CosIng itself. For CosIng's search features, its disclaimer and the glossary that replaced 2019/701, I used the Commission's own CosIng pages, its CosIng user guide and EUR-Lex.

Looking up an ingredient

  1. Find the INCI name. The Commission's guide says Simple Search takes an INCI name or a chemical name. Advanced Search lets you combine INN, chemical/IUPAC name, restriction, function, reference number and the regulation or directive reference.

  2. Tell the two kinds of record apart. Names in capital letters are "inventory" ingredients. Names in lower case are substances with an entry in the Regulation's Annexes. Only the lower-case records tell you anything about legal status.

  3. Read the Annex entry column by column. In the Regulation, Annexes III, V and VI use the same columns:

    • a: Reference number
    • b: Chemical name/INN
    • c: Name of Common Ingredients Glossary
    • d: CAS number
    • e: EC number
    • f: Product type, body parts
    • g: Maximum concentration in ready for use preparation
    • h: Other
    • i: Wording of conditions of use and warnings

    [1][2][3]

    Annex II (prohibited substances) lists only the reference number, name, CAS and EC number [4].

  4. Read the Annex preamble and footnotes as well as the entry. This is where cross-entry rules and transition dates sit. Two examples:

    • Annex V: any finished product containing a formaldehyde-releasing preservative must carry the warning "releases formaldehyde" if total released formaldehyde exceeds 0.001% (10 ppm). Compliant stock under the old rules could be placed on the market until 31 July 2024 and made available until 31 July 2026 [2].
    • Annex VI: where a UV filter is also listed in nano form, the combined total of both forms must stay within the column g limit [3].

  5. Treat "function" carefully. CosIng's function field is descriptive. The legal effect comes from the Regulation's definitions of preservatives, colorants and UV filters, which depend on what the substance is "exclusively or mainly intended" to do [5]. That intended use decides which Annex applies. For example, benzalkonium chloride's Annex III entry applies "for purposes other than inhibiting the development of micro-organisms in the product", and that purpose must be apparent from how the product is presented [1].

  6. Check the Official Journal text. Confirm the entry in the current consolidated version on EUR-Lex, and look for any amending regulation adopted after that consolidation date.

How far you can rely on CosIng legally

  • The Commission says it is not binding. Its CosIng page calls it a non-legally binding information database. Only Regulation (EC) 1223/2009 and its Annexes decide whether, and under what conditions, a substance may be used, and the Commission accepts no liability for CosIng's content.
  • An INCI name is not an approval. Having an INCI name in the CosIng inventory does not mean the ingredient is approved for cosmetic use.
  • The Regulation says the same about the glossary. Article 33 says the glossary of common ingredient names "shall not constitute a list of the substances authorised for use in cosmetic products" [6]. Recital 47 says it is not a "limitative list" [7].
  • The glossary name is binding for labelling. Under Article 19(6), the ingredient list must use the common ingredient name from the glossary. Where there is none, a term from a generally accepted nomenclature is used [8]. That glossary is adopted as a Commission decision:
    • Decision (EU) 2019/701 was repealed by Implementing Decision (EU) 2022/677. EUR-Lex gives 29 April 2023 as the date the new decision applied from.
    • The glossary data I hold is the repealed 2019/701 version [9], so for current label names use 2022/677.
  • SCCS opinions in CosIng may be incomplete. CosIng only links SCCS opinions that have been published online.

I can pull the full Annex III/V/VI entry for a specific ingredient from the consolidated Regulation next, if you give me a name or CAS number.

Sources:

Q.02