There are no requirements for cosmetics to list "active ingredients", because they do not normally contain ingredients that must be labelled in this way. Only medicinal devices are required to list the active ingredients that they contain. Conversely there are no regulations to say that manufacturers cannot list some of their active ingredients as "active ingredients", even when they are not, and manufacturers sometimes do so in order to make their product appear to be better than a competitor's product.
For example, we were presented with a face cream which listed rose water as an active ingredient and were asked if this meant that the other ingredients were inactive. The answer is that all the ingredients play some role in the formulation, but none of them would have a therapeutic or medical effect and, therefore, none of them, including the rose water, are "active ingredients" as defined in the EU Medical Devices Directive. Cosmetics, as defined in the EU Cosmetics Products Directive, do not contain active ingredients.
Reference: Cosmetics Unmasked: Dr Stephen & Gina Antczak
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