Monitoring report · published · reflects the rules at that date

SCCS issues Scientific Opinion on Hydroxyapatite (nano) – Submission IV

Our monitoring reports record the changes to cosmetics rules in a given period, and we publish one each month. Each one is a dated publication: it reflects the rules on the date it was published and is not updated afterwards. For what applies today, read the latest briefings or ask us.

See what happens after launch

What’s new?

The Scientific Committee on Consumer Safety (SCCS) has published its final opinion (SCCS/1677/25) on Hydroxyapatite (nano) following Submission IV, representing the fourth assessment of this nanomaterial for oral cosmetic applications.

This opinion follows a regulatory proposal by the European Commission to restrict hydroxyapatite (nano) use in cosmetics via Regulation 2024/858, which prompted industry to submit additional safety evidence to support higher concentrations in oral products.

The assessment was conducted following a public consultation period from April 3 to May 30, 2025, where the preliminary opinion was open for stakeholder comments.

The SCCS evaluated new scientific data to determine whether Hydroxyapatite (nano) can be safely used at concentrations significantly higher than previously approved levels for toothpaste and mouthwash applications.

Main conclusions

The SCCS concluded that hydroxyapatite (nano) is safe when used at the following concentrations in oral cosmetic products:

  • Toothpaste: Up to 29.5%
  • Mouthwash: Up to 10%

Scientific rationale supporting safety conclusion:

  • No mutagenic hazard demonstrated even at high concentrations
  • No cytotoxicity or inflammatory effects observed in buccal mucosa cell model testing
  • Negligible uptake by buccal mucosa with epithelial cells containing internalized particles being shed over time
  • Rapid dissolution of any unintentionally ingested nanoparticles in gastric fluid eliminates nano-specific safety concerns

Specific technical specifications required:

  • Rod-shaped particles with at least 87% (by particle number) having aspect ratios ≤3, and remaining 13% not exceeding aspect ratios of 9 (opinion does not apply to needle-shaped hydroxyapatite (nano) particles)
  • Hydroxyapatie (nano) particles must not be coated or surface modified
  • Maximum length of particles of 122 ± 43 nm

What now?

The SCCS opinion is effective immediately as scientific guidance. Future regulatory updates to EU Cosmetics Regulation may incorporate these conclusions into amended restrictions.

  • Opinion applies only to oral cosmetic products
  • Not applicable to sprayable products due to potential inhalation exposure
  • Needle-shaped particles remain prohibited under any circumstances

References

SCCS – Scientific Opinion on Hydroxyapatite (nano) – Submission IV (SCCS/1677/25), 26 June 2025

Need to know what this means for a product you have on the market now?

Ask the team for this area

One question works best. Leave out confidential product details; we can take those up by email.

Our team replies to every question. The reply goes to the email you gave.

We use your email to answer this question and for nothing else. Privacy and cookies

Follow an area

One email when an area publishes, in the language you choose. Nothing else.

Talk to us

Tell us the product, the market and the date you are working to. If the date is not realistic, we will say so.

Need a standing regulatory partner? See ongoing support →