6th CMR Omnibus Draft Notified to WTO

The EU Commission notified to the World Trade Organisation (WTO) the draft legislation for the 6th CMR omnibus. This is to implement the 18th Adaptation to Technical Progress (ATP) to the EU Classification Labelling and Packaging (CLP) Regulation.

The draft Regulation includes 30 new entries to Annex II. The most important and relevant entries are:

  • Benzophenone: carcinogenic 1B
  • Theophylline: reprotoxic 1B
  • Melamine: carcinogenic 2
  • Margosa (azadirachta indica) extract: Reprotoxic 2
  • Trimethylolpropane triacrylate: carcinogenic 2
  • Pentetic acid: reprotoxic 1B
  • Pentasodium pentetate: reprotoxic 1B
  • 2-ethylhexanoic acid and its salts:
    • 2-ethylhexanoic acid and 2-ethylhexanoic acid nickel salt are already found in Annex II of the EU Cosmetic Products Regulation and therefore already banned from use in cosmetics
    • 2-ethylhexanoic acid zinc salt (INCI name zinc ethylhexanoate) is currently not listed in Annexes of the EU Cosmetics Regulation and may therefore be used as a cosmetic ingredient. It is expected that this ingredient will be banned for use in cosmetics and added to Annex II of the EU Cosmetic Products Regulation.


The 6th CMR Omnibus will apply from 1 December 2023, which will be the making available on the market deadline (off-shelf) and it will apply only in the EU.