UK New CMR Classifications Impacting Cosmetics

Ingredients: 30 Hazardous Chemical Substances including CMRs

Date of publication: 07 April 2025
The UK Health and Safety Executive (HSE) notified WTO of amendments to the GB Classification, Labelling and Packaging (CLP) Regulation, introducing mandatory classifications for 30 substances including several new CMR classifications that will impact cosmetic ingredient use under Article 15 of the UK Cosmetics Regulation.

What’s new?

On 7 April 2025, the UK Health and Safety Executive (HSE) notified the World Trade Organisation of amendments to the Great Britain Classification, Labelling and Packaging (GB CLP) Regulation. The notification introduces new and revised mandatory classification entries for 30 hazardous chemical substances under the GB Mandatory Classification List (GB MCL).

Several substances received new CMR (Carcinogenic, Mutagenic, Reprotoxic) classifications, triggering potential restrictions or bans under Article 15 of the UK Cosmetics Regulation.

New CMR Classifications

Biphenyl-2-ol; 2-Phenylphenol; 2-Hydroxybiphenyl (CAS No. 90-43-7)
Ozone (CAS No. 10028-15-6)
N,N’-methylenediacrylamide (CAS No. 110-26-9)
α,α’-propylenedinitrilodi-o-cresol (CAS No. 94-91-7)
2-ethylhexanoic acid, monoester with propane-1,2-diol (CAS No. 85114-00-7)
Silver in massive, powder, and nano form (CAS No. 7440-22-4)
Dinitrogen oxide (CAS No. various)

What now?

Immediate (by June 2025): WTO comment period closes
Q4 2026: Expected implementation of mandatory classifications
18 months from GB MCL publication: Exemption application deadline (likely early 2027)
12 months after exemption submission: SAG-CS evaluation completion
8 months after SAG-CS opinion: Regulatory amendments via Statutory Instrument

References

WTO Notification G/TBT/N/GBR/XX: GB CLP Regulation Amendment, 7 April 2025

other REGULATORY UPDATES

Update on the classification and labelling of Titanium Dioxide in powder form

Ingredients: TITANIUM DIOXIDE

Date of publication: 23/11/2022

The EU General Court annuls the Commission Delegated Regulation of 2019 in so far as it concerns the harmonised classification and labelling of Titanium Dioxide as a carcinogenic substance by inhalation in certain powder forms.

Butylphenyl Methylpropional (Lilial) ban in cosmetics comes into force in Great Britain

Ingredients: BUTYLPHENYL METHYLPROPIONAL

Date of application: 15/12/2022

Due to its classification as toxic to reproduction, Butylphenyl Methylpropional is prohibited in cosmetic products placed in the Great Britain market as of December 15, 2022.

Regulation (EU) 2022/692 – OMNIBUS ACT VI – New and Updated Classification of Cosmetic Ingredients

Ingredients: BENZOPHENONE, TEOPHYLLINE, MELAMINE, AZADIRACHTA EXTRACTS, TRIMETHYLOLPROPANE TRIACRYLATE, PENTETIC ACID, PENTASODIUM PENTETATE

Date of publication: 03/05/2022

Date of application: 01/12/2023

The Commission Delegated Regulation (EU) 2022/692 includes new or updated classification for 12 chemicals that may be used as cosmetic ingredients. Seven out of these 12 are now classified as carcinogenic, mutagenic or toxic to reproduction (CMR) and are banned from cosmetic products marketed in the EU.

French labelling requirement for leave-on products containing Phenoxyethanol repealed

Ingredients: PHENOXYETHANOL

The EU Court of Justice repealed the French requirement for the labelling of the precautionary measurement “Not to be used on the nappy-skin area of children under 3 years of age” on leave-on cosmetic products containing Phenoxyethanol. Therefore, the labelling restriction related to Phenoxyethanol is officially not mandatory for products imported into France.

Italy and France – Environmental Labelling of Cosmetic Products

PACKAGING WASTE MANAGEMENT

Date of application:01/01/2023

Although the European Cosmetics Regulation is applicable to every cosmetic product made available in the European Union market, some national legislations may also apply. Environmental regulations in Italy and France specify mandatory labelling requirements applicable to packaged products marketed in these countries.

SCCS Final Opinion on the Safety of Triclocarban and Triclosan

Ingredients: TRICLOCARBAN and TRICLOSAN

Date of publication: 25/10/2022

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.