A retinol serum for four euros. A tube of Korean sunscreen for six. A moisturiser at a fifth of the pharmacy price. Sometimes the cheap marketplace listing really is the same product moving on a thinner margin. Often it is not, and what differs is not the formula printed on the label. It is whether anyone is legally answerable for what is actually in the bottle.
What regulators found when they looked
In July 2025 the European Commission published preliminary findings against Temu under the Digital Services Act. A test-purchase exercise concluded that consumers in the EU were very likely to encounter illegal products on the platform. Two of the categories named were cosmetics: products sold with missing or incorrect ingredient lists, and products containing CMR substances – carcinogenic, mutagenic or reprotoxic – that the EU Cosmetics Regulation bans outright.
On 28 May 2026 the Commission fined Temu €200 million. It is worth being precise about what the fine was for, because it was narrower than the shopping results. The breach was of Article 34: Temu's own risk assessment from October 2024 had seriously underestimated how often EU consumers would run into illegal listings, and leaned on general industry data instead of on evidence from its own marketplace. Temu has until 28 August 2026 to submit an action plan.
What the low price is actually discounting
Selling a cosmetic legally in the EU means carrying a chain of obligations under Regulation (EC) No 1223/2009. A responsible person established in the EU has to be named on the pack, with an address. That person holds the safety assessment, keeps the product information file and is who an authority calls when something goes wrong. The product has to be notified through the Cosmetic Products Notification Portal before it goes on sale. The label has to carry the full ingredient list in INCI names in descending order of weight, a batch number, and either a durability date or the period-after-opening symbol.
Per unit, none of that costs much. As a fixed cost it is real, and it is the part a parcel shipped straight from a warehouse outside the EU most often skips. A listing with no readable ingredient list is not proof of a counterfeit. But it does mean the one document that would let you check anything at all is missing, and that is precisely what the Commission's investigators kept finding.
What actually turns up in the alerts
Safety Gate, the EU's rapid alert system for dangerous products, logged 4,671 alerts in 2025 – the highest annual total since the system started in 2003. Cosmetics were the single most reported category at 36% of all alerts, and chemical risk accounted for 53% of notifications across every category.
The proportions matter more than the headline. Roughly eight in ten cosmetics alerts concerned one substance: butylphenyl methylpropional, better known as Lilial or BMHCA, a synthetic fragrance ingredient banned in EU cosmetics since March 2022. It is a skin sensitiser and a reproductive-toxicity concern, not an acute poison, and most of those alerts are stock that should have been reformulated and wasn't. Authorities also notified nail polish containing TPO for the first time in 2025, a photoinitiator banned that September.
The serious end is rarer and much uglier. Trading Standards officers in Luton had creams seized in January 2026 tested in a laboratory. One, sold as Faiza facial cream, contained 19,170 mg/kg of mercury – close to 2% by weight. Another, Tibet facial cream, contained 85.92 mg/kg. Mercury is prohibited in cosmetics in the EU and the UK with only narrow exceptions. In a related raid in Romford, 1,400 skin-lightening products were seized, some of them containing mercury, hydroquinone or corticosteroids. Products like these are not a marketplace invention, but they are exactly the category that travels well through channels nobody is supervising.
Counterfeits concentrate online, and cosmetics are the most exposed
In the joint EUIPO and OECD study of e-commerce and counterfeit trade, perfumery and cosmetics had the highest share of any product category of EU customs detentions linked to an online purchase: 75.3%, ahead of pharmaceuticals at 71.9% and sunglasses at 71.3%. More than 90% of counterfeits sold online arrive in the EU by post or courier. In 2024, EU customs detained around 112 million counterfeit articles worth €3.8 billion, an all-time high, of which about 3% were perfumes and cosmetics.
Sunscreen is where a fake does the most damage, because the failure stays invisible until the burn. Counterfeit Beauty of Joseon sun products circulating on Amazon listings in 2024 were sent for laboratory testing; as reported by the beauty publication Beautygeeks, the fake protected for roughly a third as long as the genuine product and against UVB only, with the UV filters named on the label absent from the formula. The packaging gave it away without a lab: the genuine tube is glossy aluminium, the fake was matte plastic.
What to check before you pay
- Find the full ingredient list. If the listing shows only front-of-pack marketing images, you cannot check anything. Ask the seller for a photo of the back label. A legitimate seller has one.
- Compare it with the brand's own list. Open the product page on the brand's official site and read the two lists side by side. INCI order is fixed by weight, so a reordered list, a misspelling, or a common name where the INCI name belongs – "Gotu Kola Extract" instead of "Centella Asiatica Extract" – is worth stopping on.
- Look for an EU responsible person. Article 19 requires a name and an EU address on the pack. If the back label never appears in the photos, or carries no EU address at all, the product probably did not reach the EU market through the normal route.
- Check the batch code and the date. A batch or lot number plus either a best-before date or the open-jar PAO symbol are both mandatory. Printed on a removable sticker rather than stamped into the pack is a bad sign.
- Search the Safety Gate database. It is public and free, and brands or products already notified by a national authority are listed there with photographs.
- Read who is selling, not just who made it. On the big marketplaces, "sold by" and "shipped by" are separate fields, and a brand's own storefront is a different risk from a third-party seller with the same product photo.
- Buy sunscreen somewhere else. It is the one product where the price gap is never worth it.
What this check cannot tell you
Reading an ingredient list tells you what the label claims. It does not tell you what is in the jar. A competent counterfeiter copies the genuine INCI list exactly, and the fake Beauty of Joseon tubes are the proof: the words were right and the UV filters were not there. No label check survives that, and anyone who tells you otherwise is overselling.
Two more caveats worth stating plainly. Most cosmetics alerts in the Safety Gate concern a banned fragrance allergen rather than a heavy metal, so the typical problem is a compliance failure, not a poisoning. And marketplaces sell a great deal that is entirely genuine. The Commission's case against Temu was about the platform failing to assess a risk, not a finding that everything listed on it is illegal.
Where the app fits
Skinimalist reads the ingredient list – from a photo of the pack, a barcode or a shared product link – and scores it 1 to 5 against official EU classifications. For a marketplace purchase the useful moment is before you pay: screenshot the ingredient list in the listing and scan that. If the app has no list to read, neither do you, and that is itself the answer.
The database covers 36,700+ ingredients and 91,200+ names and synonyms, so alternative, outdated and misspelled names still resolve to the right substance. The analysis runs on your iPhone, with no login and no upload.
Check the listing before you check out. Snap the ingredient list or share the product link, and see the 1–5 score, the flagged substances and how well it fits your skin.
Sources: European Commission, preliminary findings against Temu under the Digital Services Act (July 2025) and the €200 million fine of 28 May 2026; European Commission Safety Gate annual report for 2025 (published March 2026); European Commission figures on low-value e-commerce parcels and the Council decision on the €3 flat customs duty from 1 July 2026; EUIPO and OECD, Misuse of E-Commerce for Trade in Counterfeits (2021); EUIPO and European Commission customs enforcement figures for 2024; Regulation (EC) No 1223/2009 on cosmetic products, Articles 4, 13 and 19 and Annex II; Luton Borough Council Trading Standards, laboratory results published 2026; Beautygeeks reporting on counterfeit Beauty of Joseon sun products (2024). This guide is decision support, not medical advice.