What’s new?
On the 31st of October 2025, the United Kingdom (UK) notified the World Trade Organization (WTO) of a draft regulation amending the UK Cosmetics Regulation. This draft is titled “The Cosmetic Products (Restriction of Chemical Substances) Regulations 2026”. The regulation will apply to England, Wales, and Scotland.
The proposed amendments follow scientific opinions issued by the Scientific Advisory Group on Chemical Safety of Non-food and Non-medicinal Consumer Products(SAG-CS), that raised concerns about the safety of 4-Methylbenzylidene Camphor(4-MBC) and recommended lowering the labelling requirements for Formaldehyde-releasing preservatives.
Additionally, the proposed amendments include the addition of 16 prohibited ingredients, following its classification as CMR (Carcinogenic, Mutagenic or Toxic for Reproduction) under the GB CLP (Great Britain, Classification, Labelling and Packaging) Regulation.
Impact in Cosmetics Regulation:
The following substances have received a CMR classification, and will be inserted into Annex 2, becoming prohibited in cosmetic products:
- Trimethylbenzoyl diphenylphosphine oxide (CAS No. 75980-60-8)
- Clothianidin (CAS No. 210880-92-5)
- Dimethyl propylphosphonate (CAS No. 18755-43-6)
- Dibutyltin maleate (CAS No. 78-04-6)
- Dibutyltin oxide (CAS No. 818-08-6)
- Tetrabromobisphenol-A (CAS No. 79-94-7)
- 1,4-Benzenediamine, N,N’-mixed Ph and tolyl derivatives (CAS No. 68953-84-4)
- 4-Methylimidazole (CAS No. 822-36-6)
- Acetone Oxime (CAS No. 127-06-0)
- Benthiavalicarb isopropyl (CAS No. 177406-68-7)
- 2,3-epoxypropyl neodecanoate (CAS No. 26761-45-5)
- Multi-walled carbon tubes (synthetic graphite in tubular shape) with a geometric tube diameter range ≥ 30 nm to < 3 μm and a length ≥ 5 μm and aspect ratio > 3:1, including MultiWalled Carbon Nanotubes, MWC(N)T
- 7-oxabicyclo[4.1.0]hept-3-ylmethyl 7-oxabicyclo[4.1.0]heptane-3-carboxylate (CAS No. 2386-87-0)
- 2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4yl)phenyl]butan-1-one (CAS No. 119344-86-4)
- S-Metolachlor (CAS No. 87392-12-9)
- Trimethyl borate (CAS No. 121-43-7)
The ingredient 4-MBC, currently permitted in Cosmetics Regulation, will be removed from Annex 6 and inserted into Annex 2, as 3-(4-Methylbenzylidene)-d1camphor/Enzacamene (CAS No. 38102-62-4/36861-47-9), becoming prohibited in cosmetics.
The labelling threshold requirements for Formaldehyde releasing preservatives (such as DMDM Hydantoin or Diazolidinyl Urea) will be lowered to 0.001% (equivalent to 10 ppm), with the amendment to Annex 5 as follows:
“All finished products containing substances in this Annex and which release formaldehyde must be labelled with the warning ‘releases formaldehyde’ where the concentration of formaldehyde in the finished product exceeds 0.001%.”.
What now?
The draft is open for comments until the 30th of December 2025.
The amendment will come into force on the 15th of July 2026, other than the addition of the CMR substances to Annex 2, which will come into force on the 15th of August 2026.
The amendment is subject to transitional arrangements:
- For cosmetic products containing 4-MBC and Formaldehyde releasing substances, when a cosmetic product is placed on the market prior to 15th of July 2026 and complies with the past requirements of the Cosmetic Regulation, it may continue to be made available on the market until the end of the 15th of January 2027.
- For a cosmetic product containing any of the CMR substances, when a cosmetic product is placed on the market before the 15th of August 2026, it may continue to be made available on the market until the end of the 15th of February 2027.
References:
World Trade Organization (WTO) – Committee on Technical Barriers to Trade, G/TBT/N/GBR/107
