New EU Restriction on Dihydroxyacetone or DHA


The European Commission published an amendment to the Cosmetics Regulation (EC) No. 1223/2009 including 1,3-dihydroxy-2-propanone (INCI: Dihydroxyacetone or DHA), in applications for skin conditioning and tanning, adding the substance as a new entry to Annex III, at Commission Regulation (EU) 2021/1099 of 05 July 2021.

Dihydroxyacetone (or DHA) is primarily used as an ingredient in sunless tanning products. It is often derived from plant sources such as sugar beets, sugar cane, and also by the fermentation of glycerin.

DHA was first recognized as a skin colouring agent by German scientists in the early 1920s. Through its use in the X-ray processes, it was noted as the substance was causing the skin surface to turn brown when spilled.

This skin browning effect is non-toxic and is a result of a Maillard reaction. DHA reacts chemically with the amino acids in the protein keratin, the major component of the skin surface. Different amino acids react to DHA in different ways, producing different tones of coloration from yellow to brown. These are similar in coloration to melanin, the natural substance in the deeper skin layers which brown or “tan” from the exposure to UV rays.

The first consumer sunless tanning lotion was introduced into the marketplace in the 1960s. Today, DHA is the main active ingredient in many sunless tanning skincare preparations, and can be used alone or combined with other tanning components such as erythrulose. DHA is considered the most effective sun-free tanning additive.

Self-tanning products in the EU will now be limited to a maximum of 10% DHA based on the SCCS safety evaluation. The regulation also set a limit of 6.5% for use in non-oxidative hair-dye products.

Consumer products are not likely to be affected because the concentration used at cosmetic products is much lower than the indicated at the new entry of the Regulation (EC) 1223/2009 to gradually develop colour. Concentrations greater than 10% used for faster tanning and darker skin tones will no longer be permitted in the EU in early 2022, triggering reformulation for these cosmetic products.

Sunless tanners may be an effective alternative to UV-induced tanning but bear in mind that they do not provide sun protection! They should never be used in place of sunscreens. IF you are going to stay under the sun please use a proper sunscreen product with a very high protection level.

If you have any question about the compliance of your products in the EU or in the UK market please contact us, we will be glad to help!

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