What If A Trusted Cosmetic Ingredient Becomes A Compliance Risk?

As the regulations governing cosmetic products continue to evolve, ingredients that businesses have long relied upon may become prohibited or subject to new restrictions. A trusted ingredient may quickly become a compliance risk in the light of regulatory changes. Such changes can create new compliance requirements relating to product formulations, safety assessments, documentation and labelling and impact a business’s ability to continue placing products in the market.

Recently, the United Kingdom has introduced the Cosmetic Products Regulation (EC) No. 1223/2009 (Restriction of Chemical Substances) (Amendment and Transitional Provisions) (No. 2) Regulations 2026¹ (the “Regulations”). The Regulations amend the UK’s retained Cosmetic Regulation² by prohibiting the use of certain chemical substances that have been classified as carcinogenic, mutagenic or toxic for reproduction (“CMR”) and by introducing revised restrictions on the use of Hexyl Salicylate based on the latest scientific assessments.

Considering these amendments, manufacturers, importers and distributors should review their products to assess whether they contain newly prohibited or restricted substances and take timely action to ensure compliance before the applicable implementation dates.

What are the key changes under UK’s Cosmetic Products Regulations 2026?

The UK’s (EC) No. 1223/2009 (Restriction of Chemical Substances) (Amendment and Transitional Provisions) (No. 2) Regulations 2026 (the “Regulations”) introduce several important changes to the UK’s retained Cosmetic Regulation concerning the use of certain substances in cosmetic products.

Some of the key changes include:

• Prohibition on the use of newly classified CMR substances – Several substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) have been added to the list of prohibited ingredients and can no longer be used in cosmetic products. The substances set out in Schedule 1 of the Regulations have been classified as Category 1B or Category 2 CMR substances under Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures³ (the “CLP Regulation”) and are added to Annex 2 of the Cosmetic Regulation.

The prohibition applies from 23 March 2027:

• Revised restrictions for Hexyl Salicylate – Hexyl Salicylate, a commonly used fragrance ingredient, has been classified as a Category 2 CMR substance. However, following an assessment by the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS), its use in cosmetic products is permitted subject to specified concentration limits and conditions. These limits vary depending on the product type and intended users, including lower limits for products intended for children. The entries set out in Schedule 2 of the Regulations are added to Annex 3 of the Cosmetic Regulation.

The new restrictions apply from 15 August 2026.

Transitional provisions

To facilitate implementation, the Regulations provide transitional periods allowing businesses to reformulate products, update product documentation, revise labels and manage existing stock before the relevant requirements fully apply.

For products containing the newly prohibited CMR substances added to Annex 2 of the Cosmetic Regulation under Schedule 1 of the Regulations:

• the prohibition applies from 23 March 2027; and
• products placed on the market before that date may continue to be made available until 22 September 2027.

For products containing Hexyl Salicylate added to Annex 3 of the Cosmetic Regulation under Schedule 2 of the Regulations:

• the new restrictions apply from 15 August 2026; and
• products placed on the market before that date may continue to be made available until 14 February 2027.

What does this mean for cosmetic manufacturers?

For cosmetic manufacturers, the amendments are more than just a legal update. They require active compliance management. Manufacturers should assess their product portfolio for the presence of newly regulated and prohibited substances. Depending on the affected ingredients, businesses may need to reformulate products, update Cosmetic Product Safety Reports (CPSRs), Product Information Files (PIFs) and product labelling.

Manufacturers should also engage with suppliers to obtain updated ingredient specifications, declarations and supporting documentation.

What about importers and distributors?

Compliance is not limited to manufacturers alone. Importers should ensure that cosmetic products placed on the Great Britain market comply with the amended requirements. Distributors should exercise due diligence before making products available, including verifying compliance with applicable documentation and labelling requirements.

Key compliance takeaways

Cosmetic businesses should consider taking the following steps:

• Review product formulations to identify newly prohibited or restricted substances.
• Assess whether reformulation is required before the applicable compliance dates.
• Update Cosmetic Product Safety Reports (CPSRs) and Product Information Files (PIFs) based on the amendments, where required
• Obtain updated ingredient specifications and declarations from suppliers.
• Review product labels and supporting documentation to ensure compliance.
• Plan inventory management in line with the transitional arrangements.
• Monitor future amendments to the Cosmetic Regulation, as ingredient restrictions continue to evolve with scientific developments.

Conclusion

The 2026 amendments highlight how scientific developments can quickly translate into new compliance obligations for cosmetic businesses. Staying compliant is no longer just about meeting today’s requirements; it also requires businesses to monitor regulatory developments and act before applicable transition periods expire.

Businesses should use the transitional period to identify affected products, review product formulations, complete any necessary technical documentation updates, including CPSRs and PIFs where required, and strengthen their compliance processes. By taking proactive action, businesses can minimise regulatory risk, avoid disruption and continue placing compliant products on the Great Britain market.

How Komrisk can help with compliance?

Komrisk is a SaaS-based, automated compliance management software/tool with a centralized repository of actionable compliance obligations. It also features automated alerts, dashboards, and reports that give a clear, real-time view of compliance, helping organisations demonstrate compliance confidently to boards, auditors, and regulators across different units and jurisdictions, thereby supporting strong governance.

In light of the amendments to the Cosmetic Regulation in the UK made in 2026, companies can use Komrisk to monitor compliance deadlines, allocate and track compliance tasks such as assessing the need for product reformulation and updating Cosmetic Product Safety Reports (CPSRs), Product Information Files (PIFs) and labelling of products within the applicable timelines. The platform also enables companies to stay up to date with regulatory changes, automate reminders for key implementation and transition dates and maintain a central repository of compliance evidence.

Source: https://www.legislation.gov.uk/uksi/2026/109/made

Footnotes

1 https://www.legislation.gov.uk/uksi/2026/109/made

2 https://www.legislation.gov.uk/eur/2009/1223/contents

3 https://eur-lex.europa.eu/eli/reg/2008/1272/oj/eng

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.