The EU requirements for eyelash growth serums are becoming increasingly stringent and complex alongside the refined development of the global beauty and personal care market. As a fast-growing niche category, eyelash growth serums are facing comprehensive, in-depth compliance challenges under the EU regulatory framework—ranging from core ingredient bans to claim substantiation. Understanding and meeting the EU requirements for eyelash growth serums in 2026 and beyond is a decisive factor for products to legally enter and establish a foothold in this high-value market. This article systematically outlines key current and future compliance points to provide clear guidance for brands and manufacturers.
Quick Overview of EU Requirements for Eyelash Growth Serums
Before delving into the details, the table below summarizes the core compliance requirements for eyelash growth serums intended for the European market, which are the mandatory “checkpoints” that products must pass before launch.
| Requirement Dimension | Summary of Core Content | Key Impacts and Timelines |
| Core Ingredient Ban | Prostaglandin analogues (such as bimatoprost, etc.) have been evaluated as unsafe by the EU SCCS and are prohibited for use. | The use of such potent ingredients in cosmetics is completely prohibited. |
| CMR Substance Control | Pursuant to Regulation (EU) 2026/78, a new and updated set of bans and restrictions on CMR (carcinogenic, mutagenic, toxic for reproduction) substances has been introduced. | Full enforcement starting May 1, 2026; non-compliant products must be removed from the market. |
| Safety Assessment and Notification | A Product Safety Assessment must be completed, a Product Information File established, and notification submitted via the CPNP portal. | It is a mandatory prerequisite step for the legal launch of the product. |
| Labeling & Claims | Claims (such as “growth”, “strengthening”) must be supported by scientific evidence; false or misleading claims are strictly prohibited. | Non-compliant claims will face severe penalties and the risk of product removal from the market. |
| Packaging and Sustainability | Must comply with the requirements on recyclability and reduction set out in the Packaging and Packaging Waste Regulation (PPWR). | Impacts the selection and design of packaging materials and is a long-term compliance priority. |
| Contaminant Limits | Must comply with strict limits on emerging contaminants such as PFHxA (perfluorohexanoic acid) and its salts. | Starting October 10, 2026, the content of PFHxA and other substances in cosmetics must be below the specified limits. |
1.Regulatory Cornerstone
Lash serums are explicitly defined as cosmetics in the EU, so their primary prerequisite is full compliance with Regulation (EC) No 1223/2009 on cosmetic products. This regulation serves as the fundamental basis for all European requirements for lash serums.
Responsible Person System and Safety Assessment
The regulation establishes a strict Responsible Person (RP) system, which requires a legal entity established within the EU to take full responsibility for the product’s compliance. Before placing the product on the market, the Responsible Person must ensure that a qualified individual completes a comprehensive Cosmetic Product Safety Report (CPSR) and establishes a Product Information File (PIF) that is available for inspection by the authorities at any time.
Mandatory Market Notification
Before a product is placed on the EU market, a unified notification must be submitted via the Cosmetic Products Notification Portal (CPNP). This is a statutory market access procedure to ensure that regulatory authorities have access to product information.
2.Core Ingredient Bans
For eyelash growth serums, the most direct and critical EU Requirements for Eyelash Growth Serums relate to core active ingredients. Currently, the EU Scientific Committee on Consumer Safety (SCCS) has explicitly determined that the use of prostaglandin analogues as eyelash/eyebrow growth-promoting ingredients in cosmetics is unsafe.
- Impact: This means all lash serums containing prostaglandins or their analogues (such as bimatoprost, travoprost, etc.) as active ingredients are prohibited from being sold as cosmetics on the EU market.
- Compliance Path: Brands must completely abandon the use of such ingredients and instead develop or select other EU-approved safe alternatives (e.g., certain peptides, vitamins, plant extracts, etc.) to support lash care claims.
3.Ingredient Safety Updates
In addition to specific ingredient bans, the EU Requirements for Eyelash Growth Serums also extend to the dynamic control of a broader range of hazardous ingredients. Through the “Omnibus” procedure, the EU continuously updates the cosmetic ban or restriction list with substances newly classified as carcinogenic, mutagenic, or toxic for reproduction (CMR) under the Classification, Labelling and Packaging Regulation (CLP).
Key Regulation 2026: (EU) 2026/78
Commission Regulation (EU) 2026/78, which entered into force on 1 May 2026, is one of the most important recent amendments. It introduces the following changes:
- Newly banned substances: Substances such as N,N’-methylenebisacrylamide are explicitly added to the list of prohibited cosmetic ingredients (Annex II).
- Updated restrictions: More detailed concentration limits and product category restrictions are set for substances like hexyl salicylate (fragrance) and o-phenylphenol (preservative).
- Form-based regulation: Differentiated bans or restrictions are applied to substances like silver and CI 77820 based on their particle size (e.g., nano, micron scale).
Implications for eyelash growth serums: Formulators must conduct a thorough screening of raw materials to ensure they do not contain any substances newly listed in Annex II, and strictly verify the concentrations of restricted substances (e.g., certain preservatives and fragrances).
4.Safety & Evidence
Considering that eyelash growth serums may be used by sensitive populations such as women of childbearing age, and that impurities may be introduced during the manufacturing process, the following two requirements are also critical.
Child Exposure Risk Assessment
The EU SCCS continuously conducts specific safety assessments of commonly used ingredients for the pediatric population. For example, the safe concentration limits for ingredients such as butylparaben and salicylic acid in leave-on products (to which eyelash growth serums belong) when used on children have been significantly lowered. Although eyelash growth serums are not children’s products, this trend reflects the EU’s conservative stance on ingredient safety, and brands should adhere to higher safety standards when formulating.
Emerging Contaminant Limits
The EU REACH regulation is imposing increasingly strict controls on per- and polyfluoroalkyl substances (PFAS). Among them, the content of PFHxA (perfluorohexanoic acid), its salts, and related substances in cosmetics must comply with extremely low limit requirements (e.g., total concentration below 25 ppb) starting October 10, 2026. Enterprises must ensure that such contaminants in raw materials and finished products do not exceed the limits.
5.Claims & Labeling: Scientific, Truthful, and Verifiable
The EU Requirements for Eyelash Growth Serums also extend to the external claims of products. EU regulations mandate that all cosmetic claims must be legal, truthful, evidence-based, honest, and fair.
- “Lash growth” claims: If a product claims benefits such as “promotes growth” or “adds density,” it must be supported by corresponding in vitro tests, clinical studies, or other reliable scientific data, which must be documented in the product safety assessment report.
- Prohibition of absolute terms: Absolute and misleading claims such as “100% effective” or “never falls out” are strictly prohibited.
- Allergen labeling: If the formulation contains specific fragrance allergens regulated by law and their concentrations exceed the threshold, they must be clearly indicated in the ingredient list.
6.Packaging & Sustainability
The EU Requirements for Eyelash Growth Serums in 2026 concern not only the product itself but also its packaging. The EU’s Packaging and Packaging Waste Regulation (PPWR) sets clear sustainability targets.
- Recyclability design: Packaging must meet recyclability requirements, and a certain percentage of recycled plastic will be required in the future.
- Reduction and refillability: The use of packaging materials is to be reduced, and refillable packaging solutions are encouraged.
- Extended Producer Responsibility (EPR): Brands are financially responsible for the disposal of packaging waste.
7.Response Strategies and Compliance Recommendations
Faced with the increasingly complex EU Requirements for Eyelash Growth Serums, companies should adopt a proactive and systematic compliance strategy.
- Formulation First, Safety Above All
- Immediately discontinue the use of prostaglandin analogues and all newly listed CMR substances in Annex II.
- Conduct a thorough review of formulations to ensure all ingredients (especially preservatives, fragrances, and nanomaterials) comply with the latest restrictions in Annexes III, V, etc.
- Prioritize ingredients with robust safety data that are not classified as CMR or potential endocrine disruptors.
- Build a Complete Evidence Chain
- Engage professional bodies to conduct a comprehensive product safety assessment based on the final formulation, and prepare a detailed Product Information File (PIF).
- Prepare corresponding scientific evidence or test reports to support any efficacy claims (e.g., “strengthening,” “nourishing”).
- Embrace Sustainable Packaging
- Integrate PPWR requirements from the early design stage, select eco-friendly, recyclable packaging materials, and optimize designs to minimize waste.
- Monitor Regulatory Changes Dynamically
- Subscribe to authoritative regulatory updates or engage professional regulatory services to closely follow SCCS scientific opinions, CLP classification updates, and subsequent amendments to cosmetic regulations.
Summary
The EU Requirements for Eyelash Growth Serums in 2026 are characterized by a clear trend: “core ingredients are explicitly banned, and general regulations are becoming comprehensively stricter.” With the complete prohibition of prostaglandin analogues, market competition will shift towards products based on safer ingredients and supported by solid scientific evidence. Meanwhile, companies must simultaneously address multi-dimensional compliance challenges, including the dynamic update of the CMR substance list, packaging sustainability reforms, and pollutant control.
The key to successfully entering the European market lies in deeply integrating compliance into the entire product development lifecycle—from initial ingredient screening, formulation design, and safety verification, to final claim formulation and packaging selection. Only by thoroughly understanding and systematically meeting these comprehensive requirements can brands establish long-term, robust competitiveness in this high-value segment.
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