The demand for natural and organic cosmetics has surged over the past two decades, driven by consumers’ growing preference for sustainable, transparent, and ethical products. In fact, the global natural personal care market is projected to show 4.9% compound annual growth rate, with revenues reaching $16.7 billion by 20281. This growth is largely fueled by consumers hazard avoidance linked to their perception of conventional chemicals in consumer products and their interest to seek out alternatives including natural and organic personal care products.
Consumers today receive their information from multiple sources, which can impact and influence their decision-making processes. Nowadays, besides any perceptions about safety – albeit unsupported by legislation where all cosmetic products must be safe for human health – consumers do not just check the ingredient list on a cosmetic product, but want to understand the story behind the brand, its values, and its real commitment. However, creating natural cosmetics comes with significant challenges, especially in a regulatory landscape that is complex and constantly changing. For manufacturers and brands, staying ahead by understanding and adapting to these shifts is essential for success. By 2025, consumers expect not only effective natural ingredients but also to support their decision-making they increasingly expect greater transparency – including qualifiable characteristics and claims like to environmental sustainability or social factors such as ethical sourcing. Yet behind this green promise lies a complicated maze of regulatory obstacles and economic realities that manufacturers must navigate carefully.
Regulatory shifts in the European Union: A closer Look
In early 2025, the European Commission (EC) launched a public consultation2 to evaluate the effectiveness of EU Cosmetics Regulation (EC) No. 1223/2009 (CPR). This review aims to ensure the regulation remains fit for purpose in the context of the EU’s green and digital transitions. Key topics under consideration include digital labelling, bulk and online sales, professional product use, and the regulation’s impact on international trade and competitiveness3 – now key topics under the new EU political mandate.
The evaluation is based on the Better Regulation Guidelines4, examining aspects such as CPR’s effectiveness, efficiency, coherence, and relevance. It also considers how the CPR aligns with other legislative frameworks, including chemical safety laws (like REACH and updates to CLP5), sustainability initiatives (such as the CS3D6, CSRD7, ESPR8 or PPWR9), and rules on environmental claims (like ECGT10 and Green Claims Directive11).
The consultation period runs until July 2025, with the review expected to conclude by mid-2026. In parallel, the European Commission is reviewing how simplification of the CPR may offer a route to clarifying and streamlining the regulatory framework, particularly easing the burden on SMEs, without weakening standards.
The role of the bioeconomy in expanding natural ingredient access
One of the most critical factors for the continued growth of natural cosmetics is having access to a wide variety of bio-based raw materials. However, this path is not without its obstacles. For starters, natural ingredients often come with higher production costs when compared to fossil-based alternatives, which frequently benefit from government subsidies. As a result, this cost disparity creates a significant hurdle that makes it difficult for bio-based materials to compete on an even playing field.
Moreover, these economic challenges are compounded by regulatory uncertainties and the absence of harmonized definitions and certification standards across markets. This inconsistency does not just risk slowing down innovation, but it can also limit market entry, especially for smaller companies that might struggle with the complexities of scaling up production. Recognizing these intertwined challenges, the European Commission has recently launched a consultation aiming to promote a more competitive and circular bioeconomy12. The goal here is clear: to foster sustainable growth while ensuring that producers of natural ingredients can thrive without being held back by unnecessary barriers.
At the same time, natural complex substances (NCSs), such as essential oils and plant extracts, are facing increased scrutiny under current regulations. Many of the increasingly- significant number of substances entering the harmonized classification (CLH) process under CLP as carcinogenic, mutagenic, or toxic to reproduction (CMR) or endocrine disruptors (ED) are used in natural cosmetics. Notable examples include talc, sodium fluoride, heliotropin, tea tree oil (TTO), para-cymene (p-cymene), cuminaldehyde, and geraniol. Take tea tree oil, for example – a natural extract made up of over a hundred individual compounds. The European Chemicals Agency’s Risk Assessment Committee (RAC)13 recently recommended a stricter CMR 1B classification for tea tree oil, which understandably raised concerns within industry.
In response, stakeholders came together to present evidence supporting the safe use of tea tree oil, but only under specific concentration limits, a preliminary opinion from the Scientific Committee on Consumer Safety (SCCS) has been adopted14. Specifically, the Opinion supports the safe use of TTO in cosmetics under (a) used at or below 2.0% in shampoos; (b) 1.0% in shower gels and face washes; (c) 0.1% in face creams. The SCCS also emphasized the need to conform to ISO 4730:2017 and to ensure its chemical stability in formulations to prevent degradation. Following the finalization of the SCCS opinion, the European Commission will continue with risk management provisions.
Similarly, constituents like p-cymene – present in various essential oils such as cumin, thyme oil, tea tree, oregano – have been proposed as CMR 1B15 by Sweden, raising concerns about the potential ban on numerous natural cosmetic formulations. Like the case of TTO, this raises red flags because such classifications could effectively lead to bans on a wide range of natural ingredients and impact a broad diversity of natural cosmetic products. The problem is that reformulating or removing these substances is often not a straightforward option. Given their complex chemical nature and the lack of suitable alternatives, such restrictions risk undermining the diversity and richness of natural cosmetic formulations.
An overarching element to address will be the multiplication factor of CLH dossiers impacting naturals – whether they are intended, submitted or adopted. Furthermore, operators will have to account for forthcoming legislation from the One Substance, One Assessment (OSOA) package16 and how grouping under the revised CLP Regulation (EU) 2024/2865 could further accelerate wave of dossiers. Moreover, for naturals, with CLP refocussing on chemicals in consumer products – including constituents of NCSs – together with a higher number of substances are being classified as CMR 1b, there is a rising level of complexity regarding the impact of their regulation according to the provisions of Article 15(2) of the CPR that needs to urgently be addressed.
All things considered, these challenges highlight the delicate balancing act faced by regulators and industry alike: how to safeguard consumer safety without stifling innovation or diminishing the availability of natural ingredients that consumers increasingly desire.
Legal clarity and Support needed for Natural Cosmetics Manufacturers
As regulatory scrutiny intensifies, the complex classification of certain natural ingredients has become a growing hurdle–particularly for small and medium-sized enterprises (SMEs), which often lack the resources to navigate or challenge restrictive assessments. In some cases, product launches may be delayed or cancelled altogether due to future uncertainty around ingredient status. Others may consider channelling limited budgets into costly R&D efforts to reformulate with compliant botanical alternatives, despite a lack of viable substitutes.
To ensure continued innovation and ingredient diversity, clearer legal frameworks are urgently needed. This includes well-defined derogations, realistic transition periods, and greater clarity on potential bans of key constituents of NCSs. Equally important is the development of accessible technical guidance, centralized ingredient databases, and more transparent, ongoing dialogue between regulators and industry stakeholders.
The European Commission is actively pursuing reforms to streamline the regulatory landscape through its evaluation of the CPR, possible amendments to its guidance documents, and its exercise in simplification of the legislation – aiming to reduce complexity while maintaining robust consumer protections. Achieving this balance will be essential to safeguard the future of natural cosmetics and support a thriving, innovation-driven sector aligned with consumer expectations.
Future-Proofing Natural Beauty: Sustainability meets Science
Looking ahead, the natural cosmetics sector stands at a pivotal intersection: balancing the preservation of existing product formulations with the push for innovation. While full, global regulatory harmonization may still be a long-term goal, several universal trends are already shaping the future: sustainability, traceability of ingredients, and science-based safety assessments are now non-negotiable.
To stay competitive, many brands are increasingly turning to AI-powered formulation tools and digital twin technologies to simulate product performance, ensure regulatory compliance, and enhance sustainability reporting. These digital innovations are proving especially valuable as expectations for complete transparency – from sourcing to shelf – continue to rise.
At the same time, these technological advances are converging with major policy milestones, such as the EU Biodiversity Strategy for 203017 and the recently adopted Deforestation-Free Products Regulation18. Under these frameworks, brands will need to verify that their botanical ingredients do not contribute to deforestation or ecosystem degradation, raising the bar for ethical and sustainable sourcing.
In the short term, upholding a strong, science-based risk assessment approach remains critical to protect consumer health and safety. Nevertheless, long-term success will depend on the sector’s ability to align with broader EU ambitions: empowering the bioeconomy, enabling digital transformation, and embracing sustainable innovation. Despite uncertainty surrounding the finalization of the Green Claims Directive in 2024, companies will have to continue to embed sustainability and traceability into every stage of the product lifecycle. Although the regulatory environment is undeniably complex, it presents a powerful opportunity for brands to shape–not just survive–the future of natural beauty.
In this evolving landscape, those who successfully align innovation with compliance will not simply keep up–they will define what the future of sustainable beauty looks like.
References:
1 https://www.ecoviaint.com/7004-60-the-global-market-for-natural-organic-personal-care-products/
2 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14433-Cosmetic-Products-Regulation-evaluation_en
3 https://commission.europa.eu/topics/eu-competitiveness/competitiveness-compass_en
4 https://commission.europa.eu/law/law-making-process/better-regulation_en
5 https://eur-lex.europa.eu/eli/reg/2024/2865/oj/eng
6 https://eur-lex.europa.eu/eli/dir/2024/1760/oj
7 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464
8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1781&qid=1719580391746
9 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202500040&pk_campaign=todays_OJ&pk_source=EUR-Lex&pk_medium=X&pk_content=Environment&pk_keyword=Regulation
10 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202400825
11 https://environment.ec.europa.eu/topics/circular-economy/green-claims_en
12 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14555-Towards-a-circular-regenerative-and-competitive-bioeconomy_en
13 https://echa.europa.eu/fr/registry-of-clh-intentions-until-outcome/-/dislist/details/0b0236e18571231a
14 https://health.ec.europa.eu/publications/sccs-scientific-opinion-tea-tree-oil-casec-no-68647-73-4-285-377-1_en
15 https://echa.europa.eu/pl/registry-of-clh-intentions-until-outcome/-/dislist/details/0b0236e188d24acd
16 https://www.consilium.europa.eu/en/press/press-releases/2025/06/12/council-and-parliament-agree-on-simplified-and-more-efficient-handling-of-chemical-assessment-data/
17 https://environment.ec.europa.eu/strategy/biodiversity-strategy-2030_en
18 https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
Dr. Mark Smith
Director General, NATRUE, Brussels, Belgium, www.natrue.org