Regulatory disclosure methodology — EU Reg. 1223/2009 — disclosure v2.0

1. Purpose of disclosure

BeautyGuard discloses the regulatory status of each INCI ingredient under Regulation (EC) 1223/2009 — it is not a product safety assessment nor a placing-on-market decision. The result is a regulatory descriptor (banned, restricted, fragrance allergen, no regulatory issues, incomplete data), not a value-judging "safety score". It is informational only — it does not constitute medical, toxicological, allergological or legal advice. The placing-on-market decision rests exclusively with the responsible person within the meaning of art. 4 of Regulation (EC) 1223/2009. We do not produce our own toxicity indicators — we rely solely on official EU legal acts and public European Commission databases. This publication fulfils the transparency obligation under art. 27(1) of Regulation (EU) 2022/2065 (DSA) and the due diligence requirement of online intermediaries under art. 22 of Regulation (EU) 2023/988 (GPSR).

2. Data sources

The disclosure is grounded in the following publicly available sources:

• Regulation (EC) 1223/2009 — Annexes II (banned substances), III (restricted), IV (colorants), V (preservatives), VI (UV filters) EUR-Lex ↗
• CosIng — European Commission ingredients database (~28,500 substances with INCI names and CAS numbers) CosIng ↗
• EU Safety Gate — the EU-wide dangerous products alert system Safety Gate ↗
• CIR (Cosmetic Ingredient Review) — recognized ingredient safety assessments cir-safety.org ↗

3. How the algorithm works

The system classifies a product using first-match-wins on a decision tree: (1) any Annex II ingredient → status "banned" (red), (2) Annex III/V/VI concentration limit exceeded → status "violation" (red), (3) Annex III/V/VI ingredients within their limits present → status "regulated" (orange), (4) only Annex III fragrance allergens present → status "allergens" (yellow), (5) more than 70% of ingredients unrecognised at ≥4 ingredients → status "incomplete" (gray), (6) otherwise → status "ok" (green). Active EU Safety Gate alerts are shown next to the product as a separate signal — they do NOT change the regulatory status, they are a second layer of information. No INCI data → status "noData" (gray). The specific thresholds for alert matching are a trade secret of the Service Provider within the meaning of art. 11(2) of the Polish Act on Combating Unfair Competition.

4. Status categories

Green ("ok") — no regulatory issues. Yellow ("allergens") — presence of Annex III fragrance allergens (mandatory label declaration). Orange ("regulated") — Annex III/V/VI restricted ingredients within their limits. Red — Annex II banned substance ("banned") or detected concentration limit overrun ("violation"). Gray — no INCI data ("noData") or majority of ingredients unrecognised ("incomplete"). EU Safety Gate alerts are shown as a separate signal and do not change the regulatory status colour. Each result carries a citable reference to a specific legal act or alert identifier.

5. Limitations and integrity

The algorithm does not account for individual user sensitivity or interactions between ingredients. The INCI list does not contain percentage values, so verification of Annex III/V/VI concentration limits is only possible when the manufacturer separately declares concentrations (Business Customer context). Matching a barcode to a Safety Gate alert is automatic and may cover a different batch, variant or version of the product. Absence of an alert does not constitute a safety guarantee, and the administrator of the BeautyGuard website accepts no liability for any adverse effects of product use. The system detects and flags as a risk signal inconsistencies in declared INCI, in particular: missing required fragrance allergens despite "parfum/fragrance" being declared, use of unrecognised synonyms outside CosIng, and violation of the decreasing-concentration order rule from art. 19(1)(g) of Regulation (EC) 1223/2009. The BeautyGuard result does not replace the obligations of the manufacturer or responsible person; nor is it an alternative to dermatologist consultation or market surveillance authority decisions. Errors and incorrect matches can be reported via the "Report" button on the product card or — for formal manufacturer objections — via the /legal/notice form.

The list of 26 Annex III fragrance allergens of Regulation (EC) 1223/2009 (positions 45–71 and supplements) is implemented mechanically based on declared INCI names. The system does not detect allergens occurring under non-standardised synonyms, in essential oils declared generically (e.g. "Parfum", "Fragrance", "Aroma"), or ingredients not declared by the manufacturer on the label. Persons with confirmed contact allergy must always read the full ingredient list on the packaging themselves — the application does not replace this verification. The absence of an allergen annotation in the application does not constitute a statement that the product is free of that allergen.

INCI typo suggestions (e.g. "GLYCERN" → "GLYCERIN") are a BeautyGuard heuristic based on edit-distance-1 comparison against the CosIng database, NOT a regulatory determination. The suggestion is auxiliary only and does not replace verification against the original label. Suggestions are not generated for numeric tokens or names shorter than 3 characters.

Alert-to-product matching threshold for end users: matches with confidence below 0.7 (on a 0–1 scale, where 1.0 is an exact EAN/UPC barcode match) are NOT shown to consumers. This decision limits the risk of incorrectly associating a manufacturer with an alert based on a weak name match. Lower-confidence matches remain in the database for administrative review and may be manually verified. Exact barcode matches always score 1.0 and are shown without threshold filtering. This disclosure fulfils the transparency obligation under art. 27(1) of Regulation (EU) 2022/2065 (DSA).

6. Transparency, versioning and archive

Source data (EU Safety Gate, CosIng, EUR-Lex) is updated automatically. Each BeautyGuard result is recorded with the algorithm version number, computation date and data source identifier — historical methodology versions are published in the archive available at /legal/methodology/changelog. Manufacturers and responsible persons may request a historical report for a specific product (how the regulatory status evolved over time) by sending a request to legal@beautyguard.eu — we respond without undue delay. Implementation details not covered by trade secret are available on request: privacy@beautyguard.eu. The BeautyGuard result does not replace the obligations of the manufacturer, responsible person or distributor under Regulation (EC) 1223/2009 and Regulation (EU) 2023/988 (GPSR).

Methodology version archive

7. Sources of the consumer scan database

The product database available in the scanning feature is sourced from:

• Open Beauty Facts (OBF) — daily synchronization. openbeautyfacts.org ↗
• End-user contributions — approved by an administrator.
• Business Customer contributions — currently internal and invisible to consumers (MVP phase). May be activated in the future only with the explicit consent of each company.