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The EU Capped Retinol in 2024. Retinal, Bakuchiol, and 20+ Other Retinoids Still Have No Limit.

Retinal serums sell at 0.05%, 0.1%, and 0.2%. Bakuchiol is marketed as a plant-based retinol alternative. Granactive Retinoid appears on ingredient lists as hydroxypinacolone retinoate. All are vitamin A derivatives or stand-ins, all are sold as retinol's gentler or stronger relatives, and none has a concentration limit in any of the 10 countries we track.

In an earlier post, we covered how the EU set the first hard limits on retinol in 2024. This time we checked every other retinoid in our database to see which ones those limits actually reached. Of the 26 retinoid compounds we track, only three are restricted anywhere — retinol, retinyl acetate, and retinyl palmitate. The other 23, including retinal, which is more potent than retinol, carry no concentration limit in any market we cover.

Why retinal is the stronger one

Every vitamin A derivative has to convert to retinoic acid before skin can use it. The number of conversion steps sets both potency and irritation.

Retinyl esters (retinyl palmitate, retinyl acetate) sit furthest from the active form and need the most steps. Retinol is one step closer. Retinal — retinaldehyde — sits just one conversion away from retinoic acid, the form skin actually uses. Fewer steps means faster, stronger action. Dermatology sources describe the over-the-counter order the same way: retinyl esters are the least potent, retinol is in between, and retinaldehyde is the most potent of the three. The proximity that makes retinal stronger also makes it harder to formulate, since it degrades quickly and needs stabilization.

Of the retinoids a consumer can buy over the counter, retinal is the most potent. It is also the one with no regulatory limit.

What the EU actually capped

In April 2024, the EU adopted Regulation 2024/996. It set the first concentration limits on vitamin A in cosmetics: 0.05% retinol equivalent in body lotion, 0.3% in other leave-on and rinse-off products. Products also have to carry a warning — "Contains Vitamin A. Consider your daily intake before use." The limits apply to new products from November 2025 and to existing stock from May 2027.

The regulation names three substances: retinol, retinyl acetate, and retinyl palmitate, collectively the INCI "Vitamin A." The reasoning was cumulative vitamin A exposure from diet plus skincare, not skin irritation — we covered the full timeline in our earlier post on the EU retinol limits.

Our database reflects this. Retinyl acetate and retinyl palmitate carry explicit restriction entries in two markets: the EU, and Canada, which caps both at 1.0%. Retinol is flagged as restricted to reflect the EU rule. No other country in our 10-market set — Korea included — restricts any of the three.

What slipped through

The other 23 retinoids in our database are listed as unregulated in all 10 markets. Several are among the most marketed actives in skincare right now:

  • Retinal (retinaldehyde) — The most potent over-the-counter retinoid, one step from retinoic acid. Sold at 0.05–0.2%. No limit anywhere in our data.
  • Hydroxypinacolone retinoate (HPR) — Marketed as Granactive Retinoid. A modified retinoic-acid ester that acts on retinoid receptors without the conversion retinol needs. No limit.
  • Retinyl retinoate — A hybrid molecule combining retinol and retinoic acid fragments. No limit.
  • Retinyl propionate, retinyl linoleate, retinyl oleate — Ester variants beyond the two the EU named. No limit.
  • A dozen peptide-bound retinoids — retinoyl tripeptide-1, retinoyl pentapeptide-4, and others. No limit.

We also track bakuchiol, a plant compound marketed as a natural retinol alternative. It is not a vitamin A derivative and works differently, but it sells in the same category, and it carries no restriction in any market.

Why the gap exists

Cosmetic restrictions are written substance by substance. The EU's 2024 rule names retinol, retinyl acetate, and retinyl palmitate because those were the vitamin A forms its Scientific Committee on Consumer Safety assessed. The cap is expressed as retinol equivalent — a measure of cumulative vitamin A exposure — and applies to the three named substances.

Retinal is not on that list. Neither are HPR, retinyl retinoate, or the peptide-bound retinoids. A rule that names specific substances does not extend to chemical relatives, even more potent ones, until a regulator assesses them and adds them. The classic three have been in cosmetics for decades; retinal and the newer conjugates are more recent, and the assessments that would bring them under a cap have not been published.

What this means

For an EU-market formulator, the effect is concrete. A product reformulated to drop retinol below the new cap can switch to retinal and face no concentration limit, even though retinal is the more potent molecule. Because retinal is used at lower percentages and is easier to keep within a vitamin A budget, the switch is already happening — trade press has documented brands discontinuing non-compliant retinol lines and steering customers toward retinaldehyde products that the restriction does not cover.

For a consumer, "retinol-free" on a label does not mean "no retinoid" or "gentler." A retinal or HPR product can be stronger than the retinol product it replaced.

What the data does not show

Our database tracks regulatory status, not safety. An ingredient being unregulated means no authority has set a concentration limit — not that it has been judged safe at any level. The reverse also holds: the EU capped retinol on cumulative-exposure grounds, not because retinol harms skin.

We track 10 markets: the EU, Korea, Japan, China, Taiwan, ASEAN, Brazil, Argentina, the US, and Canada. A retinoid unregulated across all 10 may still be restricted in a market we do not cover. Regulations also change — whether retinal or the newer derivatives come under future review is not something the current data answers.

Methodology and Sources

Ingredient and regulatory data: K-Beauty Cosmetic Ingredients database, covering 21,796 ingredients across 10 countries.

We searched the database for INCI names containing "retin" and reviewed each result, excluding coincidental matches such as licorice-derived glycyrrhetinic acid compounds and the plant fiber reticulin. Bakuchiol was added manually, since it is marketed as a retinol alternative despite not being a vitamin A derivative. The resulting set is 26 retinoid compounds plus bakuchiol.

EU regulatory detail: Commission Regulation (EU) 2024/996, via EUR-Lex. The retinoid potency order and the documented shift toward retinaldehyde were cross-checked across dermatology references and cosmetics trade press.

For the EU retinol limits in detail, see our earlier post: Retinol Had No Limits in Most Countries Until the EU Set Them in 2024.

For the underlying data, see K-Beauty Cosmetic Ingredients on RapidAPI.

Important Notice: This article is for informational purposes only. It is not legal, regulatory, or medical advice. Cosmetic regulations and ingredient restrictions change and vary by market. Anyone making formulation or compliance decisions should consult the current text of the relevant regulation and a qualified professional. For full terms, see our Disclaimer.

Decoded Korea publishes data-driven analysis of Korean cosmetic ingredients, chemical regulations, and safety data.

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