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

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