Differences in cosmetic ingredient bans and restrictions: EU vs UK

The table below provides an overview of the existing and upcoming distinctions in ingredient prohibitions and restrictions within the Cosmetic Regulations for the UK and EU markets.

Cosmetic IngredientEU Cosmetics RegulationUK Cosmetics Regulation
Titanium dioxide Annex III, IV, and VI – restrictions for Titanium dioxide in powder form containing 1 % or more particles with aerodynamic diameter ≤ 10 μm.

Applied from 1 October 2021.
Restrictions as per EU situation before 1 October 2021, which means fewer restrictions currently than in the EU.
Salicylic AcidAnnex III/98 – allowed up to
3% in rinse-off hair products; 2%
in other products (except for body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant); 0.5% in body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant; not to be used in specific product categories with a demand for related warning.

Applied from 17 June 2021.
Annex III/98 – allowed up to 3% in rinse-off hair products; 2% in other products (except for body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant); 0.5% in body lotion, eye shadow, mascara, eyeliner, lipstick, and roll-on deodorant; not to be used in specific types of products with a demand for related warning.

Entered into force on 15 December 2022. The transition period ended on 15 March 2023.
Tetrahydropyranyloxy phenol (i.e., Deoxyarbutin)Annex II/1657

Applied from 26 July 2021.
Annex II/1645

Entered into force on 15 December 2022. The transition period ended on 15 March 2023.
Dihydroxyacetone
Annex III/321- allowed up to 10% in self-tan and 6.25% in non-oxidative hair dye.

Applied from 22 April 2022.
There is no restriction yet.
Butylphenyl methylpropional Annex II/1666

Applied from 1 March 2022.
Annex II/1666

Entered into force on 15 October 2022. The transition period ended on 15 December 2022.
Methoxyethyl acrylate Annex II/1668

Applied from 1 March 2022.
Annex II/1668

Entered into force on 15 October 2022. The transition period ended on 15 December 2022.
Sodium HydroxymethylglycinateAnnex V/51 - restricted at 0.5%; not to be used if the maximum theoretical concentration of releasable formaldehyde, irrespective of the source, in the mixture as placed on the market is ≥ 0,1 % w/w.

Applied from 1 March 2022.
Included in Annex V/51 - restricted at 0.5%; not to be used if the maximum theoretical concentration of releasable formaldehyde, irrespective of the source, in the mixture as placed on the market is ≥ 0,1 % w/w.

Entered into force on 15 October 2022. The transition period ended on 15 December 2022.
Zinc PyrithioneAnnex II/1670

Applied from 1 March 2022.
Annex II/1669

Entered into force on 15 October 2022. The transition period ended on 15 December 2022.
Methyl-N-methylanthranilate
Annex III/323

Applied from 21 November 2022.
Restriction published.

Placing on the market 6 July 2024; making available 6 July 2026.
5th (V) CMR Omnibus ingredientsThe Omnibus V contains, among others, methylene di-t-butylcresol, methyl isobutyl ketone which are added to Annex II; Methyl Salicylate is added to Annex III.

Applied from 17 December 2022.
There is no restriction yet. GB
MCL amendments notified to WTO.
6th (VI) CMR Omnibus ingredientsThe Omnibus VI contains the cosmetic ingredients "Benzophenone, Theophylline, Melamine, Azadirachta Indica Seed Extract, Azadirachta Indica Bark/Seed Extract, Trimethylolpropane triacrylate, Pentetic acid, Pentasodium pentetate, Salts of 2-ethylhexanoic acid (Zinc Ethylhexanoate) unless authorized by Annex VI to Regulation (EC) No 1272/2008".

The harmonized CMR classification will apply from 1 December 2023.
No restriction published yet. GB MCL amendments notified to WTO (does not include Pentetic acid, Pentasodium pentetate).
Benzophenone-3 and
Octocrylene
Annex VI restrictions.

Applied from 28 July 2023.
Under assessment for suspected
endocrine disrupting properties.
Formaldehyde releasersNew labelling requirements where the total concentration of formaldehyde released in the finished product exceeds 0,001 % (10 ppm), irrespective of whether the finished product
contains one or more substances
releasing formaldehyde.

Placing on the market 31 July 2024; making available 31 July 2026.
No update to the existing labelling requirements for products containing formaldehyde releasers. SAG-CS opinion published.
Various ingredientsBHT, Acid yellow 3 – Annex III. Applied from 1 July 2023 for products placed in the market. Will apply from 1 January 2024 for products made available on the market.

Resorcinol (labelling correction)–Annex III. No deadline.

HAA299–Annex VI. No deadline.

Homosalate – Annex VI.
Homosalate will apply from
1 January 2025 for products placed on the market and 1 July 2025 for products available on the market.
No restriction or updates published, but may be expected in the future.

BHT expected restriction 2024-2025. SAG-CS opinion published.

HAA299 regulation published; applied from 28 July 2023.
Fragrance ingredientsLabelling of 56 additional fragrance allergens. Published, placing on the market 31 July 2026; making available on the market 31 July 2028.No updates.
Various ingredients4-Methylbenzylidene camphor (4-MBC)– Annex II

Genistein, Daidzein, Kojic acid, Vitamin A, Alpha-arbutin, Arbutin – Annex III

Triclosan, Triclocarban – updated Annex V

Draft Regulation notified to WTO. Publication expected Q1 2024
Kojic acid expected restriction 2024- SAG-CS opinion published.

4-MBC, Triclosan, Triclocarban call for data for suspected endocrine-disrupting properties issued.

No updates on the other ingredients.
Nano ingredientsStyrene/acrylates copolymer (nano) and sodium styrene/acrylates copolymer (nano), Copper (nano),
colloidal copper (nano), Colloidal silver (nano), Gold (nano), colloidal gold (nano), gold thioethylamino hyaluronic
acid (nano), acetyl heptapeptide-9, colloidal gold (nano), Platinum (nano), colloidal platinum (nano), acetyl
tetrapeptide-17 colloidal platinum (nano) – Annex II (draft regulation notified to WTO)

Hydroxyapatite – Annex III (draft regulation notified to WTO)
OPSS launched call for data for
platinum (nano), copper (nano),
silver (nano)/colloidal silver (nano), gold (nano)/colloidal gold (nano)/gold thioethylamino
hyaluronic acid (nano),
silica (nano)/hydrated silica
(nano)/silica silylate (nano)/silica
dimethyl silylate (nano),
lithium magnesium sodium silicate (nano), hydroxyapatite (nano)

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