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Can I regsiter a product as a cosmetic if it contains hemp terpenes, lemon oil or peppermint oil?

Limonene in cosmetics CBD products

Limonene is a common terpene present in hemp extracts, it can also be found if your product contains added hemp terpenes or other flavourings.

You need to clearly state on the label the presence of Limonene and that certain people with allergies or sensitive skin should avoid it. 

Our cosmetics consultants have advised us not to register products as cosmetics that contain hemp terpenes just due it’s complexity and the risks you expose yourself to if you ever get controlled by the cosmetics authorities. 

26 Known Allergens in Cosmetics

The Cosmetics Regulation 1223/2009 lists the 26 most-known allergenic substances. These substances must appear on the label of your cosmetic product when present in the finished formula at certain thresholds.

If one of the 26 substances listed in the  26 Known Allergens in Cosmetics is present in your finished formula, you have to comply with the labelling requirements of the European Regulation. You must comply with the following rules:

The allergenic substances must appear on the label if:

  • The concentration is higher than 0.01% in a rinse-off product, e.g. a shampoo.
  • The concentration is higher than 0.001% in a leave-on product, e.g. a night cream.

Note: If an allergen is contained in different ingredient of your product, you have to add up all the concentration to verify the threshold and label your product in accordance with the rule above.

In addition to these specific requirements you must comply with all the requirements set up by the Cosmetics Regulation, especially labelling requirements.

In order to ensure that consumers are adequately informed, the presence of these substances should be mentioned in the list of ingredients and consumers’ attention should be drawn to the presence of these ingredients. This information should improve the diagnosis of contact allergies among consumers and should enable them to avoid the use of cosmetic products which they do not tolerate.



Limonene in Terpenes and lemon Oil / peppermint

We add hemp terpenes, lemon oil and peppermint to some of our food supplement products. You need to be aware that if registering as a cosmetic they will contain Limonene  

Limonene is a chemical constituent of many natural fragrant ingredients, notably citrus oils such as lemon (d-limonene) and pine trees or species of the mint family (l-limonene). 

Like most volatile fragrance components, limonene also has strong antioxidant benefits and has also been shown to calm skin; however, when exposed to air these highly volatile antioxidant compounds oxidize and become capable of sensitizing skin.

According to a 2013 safety evaluation published in the Journal of Toxicology and Environmental Health, skin irritation or sensitizing potential was reported following the use of this agent in various products. In experimental animals and humans, by-products of d-limonene were shown to act as skin irritants. Other than the irritation and sensitivity no other issues such as toxicity or carcinogenicity were noted. Based on this information, it is often recommended to those with sensitive skin or skin conditions like eczema, psoriasis, or rosacea to avoid products containing limonene.

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