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

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.

SCCS Revision of the Scientific Opinion on Vitamin A

Ingredients: RETINOL, RETINYL PALMITATE, RETINYL ACETATE, RETINYL LINOLEATE, RETINAL

Date of publication: 25/10/2022

The Scientific Committee on Consumer Safety has issued a final version of the Scientific Opinion on Vitamin A, concluding that exposure to Vitamin A derived from cosmetics can be a concern for higher exposure consumers, and since cosmetics alone do not exceed the upper limit the SCCS cannot suggest maximum concentration limits that take into account contributions from other sources.

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.

UK Responsible Person Labelling Deadline Extension

RESPONSIBLE PERSON

Date of application: 31/12/2025

The UK Office for Product Safety and Standards (OPSS) have reviewed the requirement to label the product with the UK Responsible Person and have decided to extend this transitional provision for a total period of five years, until 31 December 2025.

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.

Regulation (EU) 2022/1531 – OMNIBUS ACT V – applicable as of 17 December 2022

Ingredients: METHYL SALICYLATE, SODIUM HYDROXYMETHYLGLYCINATE, DBMC, MIBK

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.