Major Revision to EU REACH Regulation Impacts the Cosmetics Industry

Date of publication: 03 April 2025
The European Commission presented its final REACH reform proposal at CARACAL-54, introducing 10-year registration validity, Digital Product Passports, and enhanced enforcement measures that will significantly increase compliance requirements and administrative burden for cosmetics companies operating in the EU market.

What’s new?

On 3 April 2025, the European Commission presented its final REACH reform proposal at the CARACAL-54 meeting, marking the most significant overhaul of EU chemical regulation in nearly two decades.

The comprehensive revision introduces 10-year registration validity limits, mandatory Digital Product Passports (DPP), enhanced ECHA enforcement powers, and new assessment methodologies. Industry stakeholders, led by Cefic, warn of 40% cost increases for SMEs and significant administrative burden increases, particularly affecting cosmetics supply chains where each ingredient >1 tonne annually requires REACH registration.

Key provisions

Registration System Changes

10-year validity: All REACH registrations limited to 10-year validity periods
Mandatory updates: Dossiers must be updated when substances become SVHC or receive harmonized classifications
ECHA revocation authority: Enhanced powers to revoke non-compliant registration numbers
Simplified registrations abolished: 1-10 tonne registrations must now include full data requirements

Digital Product Passport Implementation

Mandatory DPP: Digital Product Passports required for supply chain communication
Digital SDS: Safety Data Sheets must align with DPP requirements
Substance of concern tracking: Enhanced communication for hazardous substances
Raw materials coverage: Cosmetic ingredients exported to EU require SDS and DPP establishment

Enhanced Risk Assessment

New assessment metrics: PMT (Persistent, Mobile, Toxic) and vPvM (very Persistent, very Mobile) substances
Mixture Assessment Factor (MAF): New methodology for substances >1000 tonnes annually
Enhanced testing requirements: All in vivo tests require testing proposals regardless of tonnage

Enforcement Strengthening

Systematic audits: Both systematic and ad-hoc audits across Member States
Enhanced penalties: Strengthened enforcement mechanisms

What now?

Q4 2025: Final legislative package adoption expected
2026-2027: Implementation phase begins with registration system changes

References

European Commission CARACAL-54 Meeting: REACH Revision Proposal, 3 April 2025

other REGULATORY UPDATES

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Date of publication: 15/09/2022

Date of application: 17/12/2022

The European Commission has published the Commission Regulation (EU) 2022/1531, which amends the Regulation (EC) No 1223/2009 as regards the use in cosmetic products of certain substances classified as CMR, by adding new entries to Annex II and Annex III and revising an entry in Annex V.

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During the plenary meeting on 24-25 October 2022, the Scientific Committee on Consumer Safety (SCCS) presented its final opinion on the safety of Triclocarban and Triclosan as substances with potential endocrine disrupting properties in cosmetic products.