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Salicylic acid limits: EU vs US for cosmetics

The EU caps salicylic acid at 3.0%, 2.0% or 0.5% depending on product type (Annex III No 98). The US sets no cosmetic limit but treats acne claims as a drug at 0.5–2%. Side-by-side table and label rules.

Short answer: the EU limit depends on the product: 3.0% for rinse-off hair products, 2.0% for most other products, and 0.5% for body lotion, eye shadow, mascara, eyeliner, lipstick and roll-on deodorant (Annex III No 98, consolidated 18.05.2026). The US sets no federal cosmetic limit.

The numbers

Product typeEU limitUS
Rinse-off hair products3.0%No federal cosmetic limit
Other products, except the list below2.0%No federal cosmetic limit
Body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant0.5%No federal cosmetic limit
Used as a preservative0.5% as acid (Annex V No 3)No federal cosmetic limit
Acne treatment claimNot a cosmetic claim in the EU either; medicinal route may applyOTC drug: 0.5–2% salicylic acid, Drug Facts required

Conditions attached to Annex III No 98:

  • Not for children under 3 years of age.
  • Not in oral products.
  • Not in applications that may expose the user’s lungs by inhalation.
  • Only for purposes other than inhibiting micro-organisms in the product; that purpose must be apparent from the presentation.
  • The levels are inclusive of any use of salicylic acid. Salts and other forms count toward the same number.

US vs EU: the difference that catches brands

The EU has one number per product category and a list of forbidden uses. The US has no cosmetic number at all, which makes people assume “any percentage is fine”.

That reading breaks the moment the label says acne. A product claiming to treat acne with salicylic acid is an over-the-counter drug in the US, and the monograph range is 0.5–2% (21 CFR 333.310(d)). Below 0.5% or above 2% the product is outside that monograph. The label then needs Drug Facts, with salicylic acid as the active ingredient, not just a cosmetic ingredient statement.

So a 2.5% salicylic acid serum is:

  • a cosmetic in the US if it makes no drug claim, and
  • over the EU limit for a face serum (2.0%) and outside the US acne monograph if it claims acne treatment.

Common mistakes

  1. Using 2% as a universal EU cap. It is not: body lotion and lip products are 0.5%.
  2. Missing the “inclusive of any use” line when the formula contains a salicylate salt.
  3. Writing “treats acne” on a 2.5% product with a cosmetic label.
  4. Forgetting the age restriction when the product is a baby or family line.

Sources

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 returns an issue list, not a print-ready label.

Related: Is salicylic acid a drug in the US? · The EU 1% phenoxyethanol limit