Skip to main content
  • Regulatory Update

UK Proposal Amending the Cosmetics Regulation Notified to the WTO

The UK Cosmetics Regulation amendment proposal has been notified in October 2023 to the WTO relating to the restriction of Butylated hydroxytoluene (BHT), assigned CAS No. 128-37-0.

A hand touching a clear screen with several colorful icons around a checkmark

November 20, 2023

UK Proposal Amending the Cosmetics Regulation Notified to the WTO

By Susana Planas MunGavin, BSc, MSc - Senior Regulatory Specialist, UL’s Supply Chain Insights

The proposal to amend Annex III on restricted ingredients of the UK Cosmetics Regulation was notified to the WTO on Oct. 27, 2023.  Comments can be submitted until Dec. 26, 2023.  After the assessment period, the proposed UK Statutory Instrument would be adopted on Jan. 16, 2024.  It would become effective on Oct. 6, 2024. By Feb. 6, 2025, any existing products not complying to the new restriction would need to be removed from the market (off-the-shelf).

The use of ingredients in cosmetic products is controlled through the Annexes. These include positive lists addressed under Annexes IV on approved colorants, Annex V on approved preservatives and Annex VI on approved UV filters or as negative lists, addressed under Annex II on prohibited ingredients and Annex III on restricted ingredients.  The proposed amendment concerns Annex III and would implement the opinion issued by the Scientific Advisory Group on Chemical Safety (SAG-CS) on the restricted use of Butylated hydroxytoluene (BHT) (CAS No. 128-37-0) in certain products. The restriction of BHT is not currently regulated under the Cosmetic Products Regulation UK No 1223/2009 (as amended). The proposed maximum permitted concentration limits for each product are as follows:

  • toothpaste at 0.1%;
  • mouthwash at 0.001%;
  • leave-on oral care products at 0.001%;
  • other leave-on and rinse-off products at 0.8%

The BHT proposed restriction would be in line with that of the EU Cosmetic Products Regulation. However, the restriction for leave-on oral care products at 0.001% would apply only in the UK.

Recommended action items

  • Review the use of BHT in impacted products regulated under the proposed restriction of ingredients.
  • If using BHT, ensure their concentrations are not exceeding the maximum permitted concentration listed in Annex III to the Cosmetics Regulation.
  • Maintain an inventory of restricted ingredients in cosmetic products placed or made available on the market.


Final opinion of February 2023 of the Scientific Advisory Group on Chemical Safety (SAG-CS) on the restricted use of Butylated hydroxytoluene (BHT)

UK Cosmetics Regulation 2019 retaining Regulation (EC) No 1223/2009

Regulatory Roundup Newsletter

Never miss an update

UL Solutions, the global safety science leader, can keep you updated on the latest events with a variety of materials, ranging from the latest regulatory news, webinars, white papers, events, industry insights and more.

Subscribe to our monthly Regulatory Roundup Newsletter and stay up to date on current and upcoming regulations and all the latest chemical industry news.

Subscribe now

Safety Data Sheet (SDS) Authoring and Labeling Services

Create, maintain and distribute comprehensive SDSs and labels to meet your increasingly complex global compliance requirements.

Safety Data Sheet (SDS) Authoring and Labeling Services (172201)

Chemical Regulatory Compliance

Manage your chemical compliance needs with the help of global regulatory expertise and leading resources.

Learn more about chemical regulatory compliance

Chemical Compliance Training

We provide a series of chemical regulatory training programs designed to help understand the diverse set of requirements and how to confront them.

Learn more about chemical compliance training

Get connected with our sales team

Thanks for your interest in UL's products and services. Let's collect some information so we can connect you with the right person.

Please wait…