On 16 January 2025, the UK notified the WTO of an amendment to Annex III of its cosmetics regulation, introducing new restrictions on the use of Methyl Salicylate.
Differences from EU restrictions
The UK's restrictions on methyl salicylate differ from those set by the EU Cosmetics Regulation, representing the second case of active regulatory divergence by the UK, following its earlier limitations on butylated hydroxytoluene (BHT).
The main distinctions between the current UK and EU Annex III entries for methyl salicylate are:
- Specific age-based restrictions: in certain categories, the UK imposes distinct restrictions for products intended for children aged 6 months to 1 year, whereas the EU does not include such specific age-related provisions currently.
- Distinction between limits for leave on and rinse-off hair products: the UK does not differentiate between rinse-off and leave on hair products setting the limits either for spray/aerosol hair products (0.009%) or non-spray/non-aerosol hair products (0.06%), whereas the EU does include this differentiation. Consequently, it can be interpreted that leave-on and rinse off hair products in spray/aerosol form may have different limits: 0.009% and 0.06% respectively.
- Variation in toothpaste limits: in the EU, toothpaste containing methyl salicylate may have a maximum concentration of 2.52%, whereas the UK limits this to 2.5%.
Deadlines for compliance
Cosmetic products containing methyl salicylate placed on the market on or before 30 September 2025 may be made available until 31 March 2026.
New SCCS opinion on methyl salicylate and children
On 17 January 2025, the Scientific Committee on Consumer Safety (SCCS) released a revised opinion on children’s exposure to methyl salicylate. While this opinion does not hold legal validity, this development could prompt an amendment to the EU restrictions on methyl salicylate and a closer alignment between EU and UK.
According to the SCCS, the concentration of methyl salicylate should not exceed:
- 0.45% in toothpaste for children aged 0-3
- 0.02% in other products for children aged 0-3 years.
If adopted into EU regulations, the new restrictions would slightly differ from the UK’s approach.