As summer approaches, brands and consumers alike are paying closer attention to what is actually inside a sunscreen.
Mineral UV filters, such as zinc oxide, and organic UV filters, such as oxybenzone, are both permitted under EU cosmetics legislation. However, consumer perception often differs between these categories, and the level of regulatory scrutiny may vary depending on the specific filter. In particular, certain filters may be subject to additional requirements when used in their nanomaterial form and, increasingly, to environmental considerations and assessments.
This article looks at what current EU rules actually say about mineral versus chemical UV filters, the requirements for nano ingredients, and why “reef safe” is a more complicated claim than it sounds.
Mineral vs Chemical: Types of UV Filters
From a regulatory perspective, the European Union does not distinguish between mineral and chemical UV filters, unlike some other jurisdictions such as Canada. In the EU, all authorised UV filters are listed in Annex VI of Regulation (EC) No 1223/2009 and are assessed individually for safety and efficacy by the Scientific Committee on Consumer Safety (SCCS), regardless of whether they are commonly referred to as “mineral” or “chemical” filters.
From a scientific perspective, however, there are some reported differences in the mechanism by which these filters protect the skin from UV radiation. The distinction is not related to the level of protection they provide, but rather to how they achieve that protection.
Chemical UV filters
Chemical UV filters protect the skin by absorbing UV radiation and converting it into a small amount of heat. Examples include avobenzone, homosalate, octocrylene, octisalate, octinoxate, and oxybenzone.
Mineral UV filters
Mineral UV filters, such as zinc oxide and titanium dioxide, are inorganic compounds that provide protection primarily by absorbing UV radiation, while also scattering and reflecting a small portion of the incoming UV light.
Many sunscreen products combine both mineral and chemical UV filters to achieve broad-spectrum UV protection and optimise product performance.
Is it Correct to Talk About “Chemical” and “Mineral” Sunscreens?
The terms chemical sunscreen and mineral sunscreen are widely used by consumers, but they are not entirely precise from a scientific perspective. Referring to a sunscreen as “chemical” is somewhat misleading, as all sunscreen ingredients – including mineral UV filters – are chemicals. A more accurate distinction would be between organic UV filters and inorganic (mineral) UV filters.
Similarly, extending the term mineral to the entire product can be imprecise. While a sunscreen may rely exclusively on mineral UV filters such as zinc oxide or titanium dioxide, the rest of the formulation typically contains a wide range of ingredients that not mineral.
Reef-Safe Sunscreen: An Environmental Question the EU Is Only Beginning to Regulate
“Reef safe” has no legal definition under EU cosmetics law. Regulation (EC) No 1223/2009 assesses UV filters for human safety, not for their impact on marine ecosystems. That gap is why jurisdictions such as Hawaii, Palau, and the U.S. Virgin Islands have banned oxybenzone, octinoxate, or octocrylene outright
TheEU is addressing the environmental side through a separate route: REACH. In 2025, the French agency ANSES submitted a restriction proposal to the European Chemicals Agency (ECHA) to cap octocrylene at 0.001% in cosmetic products specifically to limit its accumulation in aquatic environments. The public consultation runs until 24 March 2026, with a final decision expected in 2027. This is a proposal under discussion, not yet adopted law.
Marketing mineral sunscreens as inherently “reef safe” oversimplifies a complex scientific issue. While concerns regarding organic UV filters such as octocrylene are well documented, peer-reviewed studies have also reported potential aquatic toxicity associated with zinc oxide, particularly in certain particle sizes and environmental conditions. As “reef safe” has no universally accepted regulatory definition, environmental claims should be supported by robust scientific evidence and assessed on a case-by-case basis rather than relying solely on the mineral-versus-chemical distinction.
Sunscreen Nanoparticle Safety
Multiple UV filters in nano form have been approved for use in cosmetics. Both zinc oxide (nano) and titanium dioxide (nano) are authorised UV filters under Annex VI (entries 30a and 27a respectively), each capped at 25% and each carrying the same condition: not for use in applications that could expose the end user’s lungs to inhalation, such as spray sunscreens. The SCCS based this on dermal safety data, while leaving inhalation risk for nano particles unresolved.
- Nano zinc oxide and nano titanium dioxide are permitted in creams, sticks, and lotions, but not in sprayable formats.
- Cosmetic products containing nanomaterials require a separate notification to the European Commission under Article 16 of Regulation (EC) No 1223/2009, in addition to the standard CPNP notification under Article 13.
- The ingredient must be labelled with the suffix “(nano)” in the product’s list of ingredients.
How Obelis Can Help?
For sunscreen and skincare brands, staying ahead of Annex VI amendments and nanomaterial notification requirements can be challenging, especially as the EU continues to revise UV filter rules through periodic updates.
Obelis acts as Responsible Person for cosmetic brands across the EU, managing CPNP and monitoring regulatory changes such as the upcoming octocrylene restriction, so formulations and claims remain compliant as the rules evolve.
Contact Obelis today for expert guidance on regulatory compliance for your brand!
Frequently Asked Questions
Can a sunscreen combine mineral and chemical UV filters in the same formula?
Yes. Combination formulas are common and fully permitted, provided each filter stays within its own Annex VI concentration limit. Where two forms of the same substance are used together, such as zinc oxide and zinc oxide (nano). Annex VI requires the combined total not to exceed the single maximum limit.
Does an EU-compliant sunscreen automatically meet the rules of other markets, like the US or UK?
Not automatically. Each market authorises UV filters separately. The EU’s Annex VI list does not match the US FDA’s sunscreen monograph or the UK’s retained version of the EU rules one-to-one, so a formula compliant in the EU may need reformulation or additional testing to be sold elsewhere.
Is there a “reef safe” official certification?
No. There is no EU certification scheme behind the term. Several laboratories have developed methods to evaluate the potential effects of sunscreen products on coral reefs. However, there are currently no harmonised, standardised test methods that have been universally accepted for this purpose.
Sources:
Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products, Annex VI (UV filters), Articles 13 and 16 https://eur-lex.europa.eu/eli/reg/2009/1223/oj/eng
Commission Regulation (EU) 2016/621 of 21 April 2016 amending Annex VI (zinc oxide and zinc oxide (nano)). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0621&from=FR
Commission Regulation (EU) 2016/1143 of 13 July 2016 amending Annex VI (titanium dioxide (nano)). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R1143
Commission Regulation (EU) 2022/1176 of 7 July 2022 amending Annex VI (Benzophenone-3 and Octocrylene). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32022R1176
Commission Regulation (EU) 2024/996 of 3 April 2024 amending Annexes II and VI (4-Methylbenzylidene Camphor). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400996
European Chemicals Agency (ECHA), public consultation on the proposed REACH https://echa.europa.eu