A sweeping update to EU cosmetics law restricts or bans eleven substances and newly permits three hair dye compounds, with compliance deadlines running from mid-2026 to mid-2028 for certain categories.
The European Commission updated the annexes to Regulation (EC) No 1223/2009 on cosmetic products on 27 April 2026, amending four of the regulation’s technical annexes in a single instrument addressing twelve substances across fragrance, preservation, hair dye, and UV filter categories. The changes follow opinions and scientific advice from the Scientific Committee on Consumer Safety (SCCS) adopted between 2019 and early 2025.
The most consequential single action is the outright prohibition of Triphenyl Phosphate (CAS No 115-86-6, INCI name ‘Triphenyl Phosphate’), used as a plasticiser in nail products and other formulations. The SCCS concluded in July 2024 that it could not confirm the substance’s safety because submitted industry data was insufficient to rule out potential genotoxicity. Under Article 15 of the Cosmetics Regulation, that finding triggers prohibition. The substance is added to Annex II of the regulation, the list of substances prohibited in cosmetic products, with immediate effect.
Running in the other direction, silver zinc zeolite (Ammonium Silver Zinc Aluminium Silicate) is removed from the prohibited list and transferred to Annex V as a permitted preservative, following a December 2023 SCCS opinion concluding it is safe at up to 1% in spray deodorant and powder foundation (provided silver content in the zeolite does not exceed 2.5%). This marks the first time a substance has been lifted from Annex II under this regulatory cycle and reflects an industry argument about the diminishing pool of available cosmetic preservatives.
Aluminium-containing ingredients, used across deodorants, antiperspirants, and other products — are subject to new maximum concentration limits in Annex III, based on an SCCS opinion from March 2024 addressing systemic exposure from multiple product categories. The limits apply separately to non-spray and sprayable product categories and are calibrated to avoid significant contribution to total aluminium intake.
Three hair dye substances receive first-time regulatory authorisation at defined concentration limits: HC Blue No 18 (max 0.35% on-head), HC Red No 18 (max 1.5% oxidative, 0.5% non-oxidative), and HC Yellow No 16 (max 1% oxidative, 1.5% non-oxidative). These had been used in products without formal listing; the authorisations in Annex III now set the legal ceiling.
Three fragrance substances, Benzyl Salicylate, Citral, and Acetylated Vetiver Oil, have their permitted concentration levels tightened or formally capped following SCCS sensitisation risk assessments. Water-soluble zinc salts used in oral products such as toothpaste and mouthwash receive age-differentiated concentration limits, with children under one year subject to a lower cap of 0.72% (as zinc) in toothpaste.
For DHHB (Diethylamino Hydroxybenzoyl Hexyl Benzoate), a UV filter already in Annex VI, the regulation adds a purity condition: the trace impurity di-n-hexyl phthalate (DnHexP) must not exceed 10 ppm in the final substance, with 1 ppm set as the industry target. A staggered compliance timetable applies: from 1 January 2027, non-compliant products may not be placed on the market; from 1 July 2028, they may not be made available on the market at all.
For manufacturers and importers, the regulation requires an immediate audit of formulations containing Triphenyl Phosphate and a review of aluminium-level compliance across applicable product lines. The authorisation of three new hair dyes simultaneously removes the legal ambiguity that had surrounded their use.
