Regulation (EC) No 1223/2009 on cosmetic products stipulates that cosmetic products placed on the EU market must be safe for human health when used under normal or foreseeable conditions of use. In this framework, the European Commission relies on the independent scientific advice of the Scientific Committee on Consumer Safety (SCCS) to assess substances used in cosmetics that may raise concerns for the health of consumers.
In recent years, questions have been raised about the potential for consumers to be over-exposed to salicylic acid (CAS: 200-712-3) from various salicylates, which may undergo metabolic conversion to salicylic acid after dermal application of cosmetic products. These esters used as UV filters, fragrances or emollients. The SCCS has previously issued opinions on several individual salicylates, noting in this regard that the potential exposure to salicylic acid derived from several esters could be relevant for the overall risk to consumers.
In order to gain a clearer understanding of the actual contribution of salicylic esters to the systemic exposure to salicylic acid and to assess whether the combined exposure resulting from their simultaneous use in different cosmetic products may reach levels of safety concern, the Commission launched a two-phase data collection exercise (in 2023 and 2024). Based on the information received through these data calls, as well as data available in the scientific literature and in previous SCCS assessments, the Commission considers that sufficient information is now available to request a structured and scientifically robust assessment by the SCCS.
Against this background, the Commission requests the SCCS to assess the overall exposure to salicylic acid resulting from the use of salicylic esters in cosmetic products and to determine whether such exposure is safe for consumers of different age groups under realistic conditions of use.
