Putty (2019 formulation)

These describe what an ingredient is, not whether it is a problem. The stance marks above are the ratings; these are not.

• fragrance materialLavandula Angustifolia Oil, Limonene, Linalool, Citral

  • Lavandula Angustifolia Oil: An essential oil the EU names on its own account as a fragrance substance to be declared on the label, under a shared name covering several lavender species. EU Regulation (EC) 1223/2009, Annex III entry 360, inserted by Commission Regulation (EU) 2023/1545: a fragrance substance whose presence must be indicated in the list of ingredients above 0,001% in leave-on and 0,01% in rinse-off products. It is declarable in its OWN right, not by way of any component it carries. The entry is a GROUPED one covering the oils and extracts of Lavandula angustifolia, Lavandula intermedia and Lavandula hybrida, about eight glossary names in all, all declared under the single common name "Lavandula Oil/ Extract", so that name on a label does not identify which of them is present. The duty applies now. Transition footnote (40) lets stock that does not comply, lawfully placed on the Union market before the 31 July 2026 cut-off, be made available until 31 July 2028.
  • Limonene: A citrus-smelling fragrance component named separately on the label; the one name covers three related isomers. EU Regulation (EC) 1223/2009, Annex III entry 88: a fragrance substance whose presence must be indicated in the list of ingredients above 0,001% in leave-on and 0,01% in rinse-off products, because of established contact-allergy risk. That entry carries transition footnote (37): stock that does not comply, lawfully placed on the Union market before the 31 July 2026 cut-off, may still be made available until 31 July 2028. It is marked on the racemic dl-limonene/Dipentene line and the (S)-(l-limonene) line, but NOT the (R)-p-mentha-1,8-diene (d-limonene) line, CAS 5989-27-5, whose duty was already running as entry 88 before Commission Regulation (EU) 2023/1545 and so needed no transition. All three isomers are declared under the single glossary name "Limonene", so that name on a label does not identify which of them is present.
  • Linalool: A floral fragrance component named separately on the label. EU Regulation (EC) 1223/2009, Annex III entry 84: a fragrance substance whose presence must be indicated in the list of ingredients above 0,001% in leave-on and 0,01% in rinse-off products, because of established contact-allergy risk.
  • Citral: A lemon-scented fragrance component named separately on the label; the one name covers three related substances. EU Regulation (EC) 1223/2009, Annex III entry 70: a fragrance substance whose presence must be indicated in the list of ingredients above 0,001% in leave-on and 0,01% in rinse-off products, because of established contact-allergy risk. As replaced by Commission Regulation (EU) 2026/909 of 27 April 2026, the entry is a GROUPED one covering citral, geranial and neral, declared collectively as "Citral", with per-product-type caps from 0,032% in deodorant to 1,2% in rinse-off and leave-on hair products. Its three substances carry two different sell-through dates: products not complying may not be placed on the Union market from 1 January 2027 in every case, and may not be made available from 1 July 2028 for citral, footnote (**), or from 1 August 2028 for geranial and neral, footnote (***). In the consolidated text those two footnotes are renumbered (46) and (47); both are worded "these substances", where the footnotes that attach to a single named substance say "that substance".

• rich occlusiveTheobroma Cacao Seed Butter

  • Theobroma Cacao Seed Butter: A rich butter the FDA recognises by name as a skin protectant. FDA OTC skin protectant monograph, 21 CFR 347.10(d): "Cocoa butter, 50 to 100 percent."

• humectantGlycerin

  • Glycerin: A humectant, and one of the two ingredients a comparison of moisturiser components found made a significant difference to skin hydration. FDA OTC skin protectant monograph, 21 CFR 347.10(h), lists glycerin as a skin protectant at 20 to 45%. On the humectant half: Jeong CB, Han JY, Cho JC, Suh KD, Nam GW, "Analysis of electrical property changes of skin by oil-in-water emulsion components", Int J Cosmet Sci 2013;35(4):402-410, DOI 10.1111/ics.12059, PMID 23621673, found that "glycerine and urea showed significant skin hydration effects compared with other humectants".

• soothingColloidal Oatmeal, Zinc Oxide

  • Colloidal Oatmeal: One of the ingredients the FDA recognises by name as an over-the-counter skin protectant for irritation and itching. FDA OTC skin protectant monograph, 21 CFR 347.10(f): "Colloidal oatmeal, 0.007 percent minimum; 0.003 percent minimum in combination with mineral oil in accordance with 347.20(a)(4)."; section 347.50(b)(4) gives it the indication "temporarily protects and helps relieve minor skin irritation and itching due to:" followed by at least one of rashes, eczema, poison ivy/oak/sumac, or insect bites. The indication is conditional on naming a cause; the same opening phrase also serves sodium bicarbonate at (b)(5), so the phrase alone does not identify oatmeal.
  • Zinc Oxide: A mineral UV filter that the FDA also recognises as a skin protectant. FDA OTC skin protectant monograph, 21 CFR 347.10(u), lists zinc oxide as a skin-protectant active at 1 to 25%. Its labelled indication is 21 CFR 347.50(b)(3), "dries the oozing and weeping of poison: ivy, oak, sumac". The monograph does not give it the "minor skin irritation and itching" wording.