November 11, 2025
By Susana Planas MunGavin BSc., MSc, Senior Regulatory Specialist, Supply Chain Team, UL Solutions
On Oct. 31, 2025, the Draft Cosmetic Products (Restriction of Chemical Substances) Regulations 2026 proposed by the UK's Trade Office for Product Safety and Standards (OPSS) was notified by the UK Government to the World Trade Organization (WTO).
These Regulations would further amend the retained Regulation EC (No.) 1223/2009 of the European Parliament and of the Council on cosmetic products, referred to as "the Cosmetic Regulation."
They introduce amendments to Annex II of the UK Cosmetic Regulation adding further substances to the list of substances prohibited to be used in cosmetic products.
Starting July 15, 2026, these Regulations would ban the use of the substance listed under Schedule 1 to the draft Regulations, Enzacamene (CAS No. 38102-62-4 and No. 36861-47-9). This substance is currently permitted to be used as a component of UV filters in cosmetics.
A transitional compliance period would apply to products already available on the market before July 15, 2026 that comply with the requirements of the UK Cosmetic Regulation, buying time for the affected business to phase-out the use of Enzacamene in their products. In this case, products could remain on the market until Jan. 15, 2027 (off the shelf deadline).
Certain carcinogenic, mutagenic or reprotoxic (CMR) substances would also be banned from use in cosmetic products. These include 16 CMRs as listed under Schedule 2 of the draft Regulations. Currently, Trimethylbenzoyl diphenylphosphine oxide (TPO), (CAS No. 75980-60-8) is widely used in extremely low concentrations in cosmetics, such as nail products. This substance has been classified as a Reproductive 1B under the GB Classification, Labelling and Packaging Regulation (CLP Regulation).
Placing on the market of cosmetic products containing CMRs would no longer be allowed from August 15, 2026. A transitional compliance period would apply to products already available on the market before this date and comply with the requirements of the UK Cosmetic Regulation. These products could then remain until February 15, 2027 (off the shelf deadline).
Table 1 on Compliance Deadlines of Cosmetic Products
Banned Substances in Cosmetic Products | Deadline for placing on the market | Off the shelf deadline |
| Schedule 1: Enzacamene | July 15, 2026
| January 15, 2027 (if already available on the market before July 15, 2026) |
| Schedule 2: CMRs | August 15, 2026 | February 15, 2027 (if already available on the market before August 15, 2026) |
Also, labeling provisions would apply to cosmetic products releasing Formaldehyde. From July 15, 2026, cosmetics placed on the market would require to be labelled with the warning phrase "releases formaldehyde", if they contain Annex 5 listed preservatives where the concentration of formaldehyde in the finished product exceeds 0.001%."
Currently, the Cosmetic Regulation requires the warning phrase where the concentration of formaldehyde in the finished product exceeds 0.05%.
The draft legislation is open for comments until Dec. 30, 2025.
Any comments can be submitted by email to tbtenquiriesuk@businessandtrade.gov.uk.
Recommended action items
- Manufacturers and/or importers should phase-out the use of Enzacamene as a UV filter component of cosmetic products, as they should no longer be placed on the market after July 15, 2026.
- Products containing Enzacamene as a UV filter component that were made available on the market before July 15, 2026 would need to be withdrawn and no longer made available on the market after Jan. 15, 2027 (off the shelf deadline).
- Manufacturers and/or importers should phase-out the use of any of the proposed banned CMR substances in cosmetic products, as they should no longer be placed on the market after Aug. 15, 2026.
- Products containing any of the 16 CMR substances proposed to be banned that have already been made available on the market before Aug. 15, 2026 would need to be withdrawn and no longer made available on the market after Feb. 15, 2027 (off the shelf deadline).
- Labels of Cosmetic products placed on the market from July 15, 2026 containing substances used as preservatives and listed in Annex 5 of the Cosmetic Regulation and which release Formaldehyde would need to indicate this warning phrase on the label where the concentration of Formaldehyde in the finished product exceeds 0.001%: "releases formaldehyde".
- Cosmetic products already placed on the market before July 15, 2026 may remain on the market until Jan. 15, 2027.
References
The Draft Cosmetic Products (Restriction of Chemical Substances) Regulations 2026
UK retained Regulation (EC) No 1223/2009 on cosmetic products
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