“Nano” on EU cosmetic labels: the bracket rule
In the EU, every ingredient present in the form of a nanomaterial must be followed by the word “nano” in brackets in the ingredient list (Regulation 1223/2009, Article 19(1)(f)). The US has no comparable cosmetic label rule.
Short answer: in the EU, every ingredient present in the form of a nanomaterial must appear in the ingredient list with the word “nano” in brackets right after its name — for example Titanium Dioxide (nano) (Regulation 1223/2009, Article 19(1)(f), consolidated 18.05.2026). The US has no comparable label rule for cosmetics.
The numbers
| Rule | EU | US |
|---|---|---|
| Label wording | Titanium Dioxide (nano) | No nano-specific label rule for cosmetics |
| Where it applies | Every ingredient in nanomaterial form, in the ingredient list | — |
| Extra duties | Nanomaterials also trigger a separate notification route (Article 16) | — |
The rule sits inside Article 19(1)(f), right next to the ingredient-order rules: all ingredients present in the form of nanomaterials must be clearly indicated, with “nano” in brackets after the name. The same article paragraph also confirms the under-1% ordering flexibility — both live in the same list of label requirements.
US vs EU
The US has no federal rule requiring a nano designation on cosmetic ingredient labels. A US sunscreen stick or powder with titanium dioxide shows Titanium Dioxide; the EU version of the same label must show Titanium Dioxide (nano) — and if the nanomaterial is not on the EU's allowed list for that use, the product cannot go to the EU at all. Titanium dioxide (Annex VI No 27) and zinc oxide are the two nanomaterial UV filters with their own conditions, including particle-size definitions.
Common mistakes
- Selling EU labels that say
Titanium Dioxidewhen the grade used is nano — missing bracket, failed label. - Assuming the bracket is optional “for readability”. It is a label requirement, not a suggestion.
- Forgetting that a nano grade also needs its own notification route before placing on the market.
- Mixing nano and non-nano grades and labeling only one. Each ingredient form is judged separately.
Do this now
Ask your supplier whether the grade you buy is a nanomaterial (particle size, typically with a specific diameter distribution). If yes, add “(nano)” after the INCI name on the EU label and check the Annex entry for that use.
FAQ
How do nanomaterial ingredients appear on an EU label?
With the word “nano” in brackets right after the ingredient name, e.g. Titanium Dioxide (nano) — Article 19(1)(f) of Regulation 1223/2009.
Is there a US nano label rule for cosmetics?
No. The US has no comparable federal nano designation for cosmetic labels.
Does using a nano grade trigger anything else?
Yes. Nanomaterials also follow their own notification route (Article 16) and the Annex entry for that use.
Sources
- Regulation (EC) No 1223/2009, Article 19(1)(f) — consolidated text 18.05.2026
- Regulation (EC) No 1223/2009, Article 16 (nanomaterials notification route) — consolidated text 18.05.2026
- 21 CFR 701.3, ingredient designation (no nano rule) — eCFR, issue 2026-11-06
Last verified: 2026-11-10.
Not legal advice, and not a guarantee of compliance or of acceptance by any authority.
Want this checked against your own formula? Run the free label check. It rebuilds the EU ingredient list with the nano brackets where the rule applies. It returns an issue list, not a print-ready label.
Related: UV filters: EU vs US · The under-1% ordering myth