Why 2%? The UK limit on salicylic acid in cosmetics

In the UK version of the Cosmetics Regulation, which covers Great Britain, salicylic acid used for purposes other than as a preservative is capped at "2,0 %" in most cosmetic products, the regulation's own way of writing 2%. Its use as a preservative is dealt with separately, in Annex V. Rinse-off hair products may go to "3,0 %", and a short list of products is held to "0.5%". A limit is a ceiling set by law, not a measure of how well a product does anything. The Glowness 2% BHA Serum contains 2% plant-derived salicylic acid.

What the regulation says

Product type (Annex III, entry 98)	Maximum concentration in ready for use preparation
(a) Rinse-off hair products	3,0 %
(b) Other products except body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant	2,0 %
(c) Body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant	0.5%

This page covers Great Britain: England, Scotland and Wales. Cosmetics sold there are covered by Regulation (EC) No 1223/2009 on cosmetic products, in the UK version published on legislation.gov.uk. Its Annex III lists substances that may be used only within limits. Salicylic acid is entry 98, and the limit depends on the product type. The table above gives the regulation's wording, as printed, under its column heading "Maximum concentration in ready for use preparation".

A legal ceiling, not a grade

The regulation sets the highest concentration allowed for each product type. It is a ceiling, not a target and not a grade: the law does not say that a product at the limit does more than one below it, and neither do we.

The entry also says the limit is for salicylic acid used "For purposes other than inhibiting the development of micro-organisms in the product. This purpose has to be apparent from the presentation of the product." Its use as a preservative is dealt with elsewhere: "For use as a preservative see Annex V, No 3."

The conditions and the warning wording

Entry 98 also sets conditions. In the regulation's words:

Not to be used in preparations for children under 3 years of age.
Not to be used in applications that may lead to exposure of the end-user's lungs by inhalation.
Not to be used in oral products.

The Glowness 2% BHA Serum (50 ml) is a leave-on exfoliant with 2% plant-derived salicylic acid, made for oily and combination skin*.

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*Based on a 28-day dermatologist-assessed study of 20 women aged 18-35 when used as part of a skincare routine. Individual results may vary.

Where the "children under 3" line comes from

Under "Wording of conditions of use and warnings", entry 98 gives the words "Not to be used for children under 3 years of age", with a note: "Solely for products which might be used for children under 3 years of age."

The Glowness product page carries the same words in its warnings: "Not to be used for children under 3 years of age." The full warnings are quoted at the end of this page.

The Glowness 2% BHA Serum

The product page lists "2% Plant-derived Salicylic Acid (BHA)": for what that number means on a label, see what does 2% mean on a salicylic acid label.

Who looks after the rules in Great Britain

GOV.UK guidance from the Office for Product Safety and Standards explains the regulation for Great Britain. It says: "All cosmetic products available to consumers must have a 'Responsible Person' who makes sure safety measures are followed and legal obligations are met." On ingredient limits, it says: "Details on restrictions for substances can be found in Annex 3."

The guidance also notes: "This guide does not cover making cosmetic products available in Northern Ireland (NI), for which the Responsible Person must be established in NI or the EU."

That guidance was published on 4 October 2021 and still refers to the Northern Ireland Protocol. This page does not cover Northern Ireland.

This page describes the regulation as published on the day we read it. It is not legal advice.

How to use the Glowness 2% BHA Serum

Follow the directions on the pack. New to a BHA? Patch test it first.

Cleanse: start with a fresh, clean face.
Dispense 2-3 drops of Glowness Serum onto your fingertips, then gently massage the product onto your skin using upward motions. Do not rinse. Avoid eye contour, lash line, and eyelids.
Allow the serum to absorb for 15-20 minutes. For best results, follow up with a moisturiser.
Use SPF, wear protective clothing, and limit sun exposure while using this product and for a week afterward.

Where to go next

For what salicylic acid is, see what is salicylic acid. To compare bottles before you buy, see how to choose a salicylic acid serum, and for everything in ours, the full Glowness ingredient list.

Warnings (from the product page)

External use only. Patch-test before first use. In the event of contact with eyes, rinse immediately with plenty of water and seek medical advice if you experience irritation; rinse skin and discontinue use. Consult a physician if you are pregnant, nursing, or allergic to salicylic acid. Not to be used for children under 3 years of age. Keep out of reach of children.

Use SPF, wear protective clothing, and limit sun exposure while using this product and for a week afterward.

Sources

Frequently asked questions

Is 2% the maximum salicylic acid allowed in UK skincare?

For most cosmetic products, yes. The UK version of the Cosmetics Regulation sets "2,0 %" for "Other products except body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant". Rinse-off hair products may go to "3,0 %", and body lotion, eye shadow, mascara, eyeliner, lipstick and roll-on deodorant are held to "0.5%".

Is 2% a legal limit or a recommended strength?

A legal limit. The regulation sets the highest concentration allowed for each product type. It does not recommend a strength, and it does not say that a product at the limit does more than one below it.

Where does the "not to be used for children under 3" warning come from?

Annex III entry 98 gives "Not to be used for children under 3 years of age" as the warning wording for salicylic acid, with the note "Solely for products which might be used for children under 3 years of age." The Glowness product page carries the same words in its warnings.

Does this guidance cover Northern Ireland?

No. The GOV.UK guidance says: "This guide does not cover making cosmetic products available in Northern Ireland (NI), for which the Responsible Person must be established in NI or the EU."

How often should I use the Glowness 2% BHA Serum?

Follow the directions on the pack.