EU
Commission Opens Three Consultations on PPWR Requirements
The European Commission has opened three consultations on two implementing acts and one delegated act under Article 7 of the Packaging and Packaging Waste Regulation (EU) 2025/40.
Article 7 establishes requirements concerning minimum recycled content in plastic packaging. The forthcoming measures are expected to provide the technical rules needed to calculate, verify and document compliance, including the methodology and reporting framework to be used by economic operators.
The measures are relevant to cosmetic brands using plastic primary, secondary or transport packaging placed on the EU market. They may influence packaging specifications, supplier declarations, recycled-content data and supporting compliance records.
The PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026.
What this means: Companies should review their plastic-packaging portfolio, confirm the availability of recycled-content information from suppliers and consider commenting on the draft measures before 16 September 2026.
Climbazole Enters the EU Harmonised Classification Process
ECHA has moved forward with Belgium’s proposal to create a unified classification and labeling for climbazole, which is commonly used in cosmetics.
The proposal will now go through public consultation and review by ECHA’s Risk Assessment Committee, which usually takes 12 to 24 months. There is no immediate change to how climbazole can be used, but a unified classification could prompt a future review under the Cosmetics Regulation.
What this means: Brands using climbazole should keep track of the classification process and check which of their products might be affected.
EU Proposes More Flexible Limits for Silver in Cosmetics
The European Commission has notified the WTO of a draft amendment to the silver restrictions introduced by Omnibus VIII and applicable since 1 May 2026.
The proposal follows updated SCCS advice indicating that micron-sized particulate silver—between 100 nm and 1 mm—does not penetrate, or only negligibly penetrates, beyond the stratum corneum in products without relevant inhalation exposure.
The draft would permit porous and sintered silver powder at the following maximum concentrations:
- Rinse-off products: 0.2%
- Oral products other than children’s mouthwash: 0.2%
- Children’s mouthwash: 0.05%
- Leave-on products: 0.3%
- Nail products: 0.3%
- CI 77820 in leave-on and nail products: 0.3%
Aerosol and propellant-based products presenting an inhalation risk would remain excluded. The amendment concerns micron-sized silver and should not be interpreted as authorising nanosilver under the same conditions.
If adopted as proposed, the revised limits could apply retroactively from 1 May 2026. Until adoption, however, companies must continue to comply with the existing Omnibus VIII restrictions.
What this means: Brands should determine the particle form and specifications of the silver used in their products, confirm whether the proposed limits would apply and retain supplier documentation demonstrating that the material is not nano.
SCCS to Assess Cuminaldehyde and p-Cymene
The European Commission has asked the Scientific Committee on Consumer Safety (SCCS) to assess cuminaldehyde (CAS 122-03-2) and p-cymene (CAS 99-87-6). Both substances occur naturally in essential oils—including thyme, oregano and cumin oils—and may be present in fragrance mixtures as constituents of natural complex substances.
The mandates follow a recommendation from ECHA’s Risk Assessment Committee to classify both ingredients as Reproductive Toxicants Category 1B, with hazard statement H360Fd.
Under Article 15 of the EU Cosmetics Regulation, substances classified as CMR Category 1A or 1B are generally prohibited in cosmetic products unless all conditions for a specific exemption are met. The SCCS assessments will therefore consider whether the substances can be used safely and, if so, at what maximum concentrations. The Commission published the two requests on 30 July 2026.
The SCCS has nine months to deliver its opinions. No prohibition or new concentration limit applies at this stage.
What this means: Brands should request compositional data from fragrance and essential-oil suppliers, identify formulations containing either constituent and assess their dependence on the affected materials.
Galaxolide Classification Raises Prospect of Future EU Ban
ECHA’s Risk Assessment Committee has concluded that Galaxolide—also known as HHCB (CAS 1222-05-5)—should be classified as a Reproductive Toxicant Category 1B with hazard statement H360D, “May damage the unborn child.”
Galaxolide is a synthetic musk widely used to provide a clean, persistent fragrance in perfumes, personal care products, detergents and other fragranced consumer goods.
The RAC opinion does not itself prohibit Galaxolide. The classification must first be formally incorporated into the CLP Regulation. Once applicable, its CMR 1B status could trigger the prohibition mechanism under Article 15 of the EU Cosmetics Regulation unless the conditions for an exemption are satisfied.
No cosmetics ban or transition deadline has been adopted yet. References to a possible restriction from 2028 are therefore indicative estimates, not a confirmed legal deadline.
What this means: Brands should identify fragrances containing Galaxolide, discuss alternatives with fragrance suppliers and allow sufficient time for reformulation, safety assessment, stability testing and consumer validation.
Formaldehyde-Releaser Labelling: Final EU Deadline Reached
The final transition period established by Commission Regulation (EU) 2022/1181 ended on 31 July 2026. From that date, cosmetic products containing formaldehyde-releasing preservatives may only continue to be made available on the EU market if they comply with the revised labelling requirement.
Regulation (EU) 2022/1181 amended the preamble to Annex V of the EU Cosmetics Regulation by lowering the threshold that triggers the warning from 0.05% (500 ppm) to 0.001% (10 ppm) of total formaldehyde released in the finished cosmetic product.
Where the total concentration of released formaldehyde exceeds 0.001%, the product must carry the warning:
“Releases formaldehyde”
The requirement applies irrespective of whether the formaldehyde originates from one or several formaldehyde-releasing substances in the formulation. It is the total concentration released by the finished product—not simply the concentration of an individual preservative—that determines whether the warning is required.
Formaldehyde itself is prohibited in cosmetic products under Annex II of Regulation (EC) No 1223/2009. However, certain preservatives listed in Annex V may release small quantities of formaldehyde as part of their preservative action. Ingredients commonly associated with formaldehyde release include:
- DMDM Hydantoin
- Imidazolidinyl Urea
- Diazolidinyl Urea
- Sodium Hydroxymethylglycinate
- Bronopol (2-Bromo-2-Nitropropane-1,3-Diol)
- Methenamine
The transition was implemented in two stages:
- 31 July 2024: Products that did not meet the new requirement could no longer be placed on the EU market.
- 31 July 2026: Existing non-compliant stock could no longer be made available, including products already within the distribution chain or offered for sale to consumers.
What this means: Responsible Persons and brands should confirm that the released-formaldehyde concentration has been assessed in the finished product under suitable and representative conditions. Where the 10 ppm threshold is exceeded, the warning must appear on the label. Product Information Files, Cosmetic Product Safety Reports, specifications and packaging artwork should also reflect the assessment and any resulting labelling decision.
Companies should pay particular attention to older products and remaining stock manufactured or placed on the market before July 2024, as the sell-through period has now ended.
UK
SAG-CS Publishes Seven Cosmetic Ingredient Safety Opinions
The UK Scientific Advisory Group on Chemical Safety (SAG-CS) has published seven final opinions, concluded between December 2025 and June 2026, covering the following cosmetic ingredients:
- Triclocarban: Considered safe for adults at 1.5% in rinse-off products for non-preservative purposes and at 0.2% as a preservative. Mouthwash for all age groups and toothpaste for children under six are excluded at 0.2% because aggregate exposure could exceed the acceptable safety margin.
- Sodium o-phenylphenate: Considered acceptable at 0.2% in rinse-off and 0.15% in leave-on products. Oral-care products and sprays are excluded.
- Triclosan: Considered safe as a preservative at 0.2% in mouthwash and 0.3% in toothpaste, soaps, shower gels, non-spray deodorants, face powders, blemish concealers and specified nail-cleansing products.
- Daidzein: Considered safe in cosmetic products at up to 0.02%, in line with the EU SCCS conclusion.
- O-phenylphenol: Considered acceptable at 0.2% in rinse-off and 0.15% in leave-on products. Oral-care products and sprays are excluded. When used together with sodium o-phenylphenate, the combined concentration must remain within these limits.
- Resorcinol: Considered acceptable at a maximum on-head concentration of 1.25% in oxidative hair and eyelash dyes, and at 0.5% in hair lotions and shampoos. Existing conditions of use and label warnings continue to apply.
- Micron-sized particulate silver: For particles larger than 100 nm and smaller than 1 mm, SAG-CS supports maximum concentrations of 0.3% in leave-on products, 0.2% in lip products, 0.3% in rinse-off products and 0.05% in mouthwash and toothpaste. Nanosilver and propellant-based sprays are outside the scope of the opinion.
For several of the ingredients, SAG-CS recommended further assessment for children and adolescents once sufficient data and an appropriate methodology are available.
Importantly, these opinions provide scientific advice to the Office for Product Safety and Standards (OPSS) but do not immediately amend UK cosmetics legislation. Any new legal limits or conditions would require a separate regulatory decision.
What this means: Brands selling in Great Britain should identify affected products, compare their concentrations and uses with the SAG-CS conclusions, and monitor future OPSS measures. Companies operating in both the UK and EU should also watch for regulatory divergence that could require market-specific formulations or compliance strategies.
USA
FDA Sets November 2026 Timeline for Formaldehyde Ban and Fragrance Allergen Rule
The FDA’s July 2026 Unified Agenda confirms two cosmetic rulemakings targeted for November 2026: a proposed ban on formaldehyde and formaldehyde-releasing chemicals in heat-activated hair smoothing and straightening products, and a proposed rule on fragrance allergen disclosure under MoCRA, which would specify which fragrance allergens must appear on cosmetic labels.
The asbestos testing methodology for talc has been dropped from the agenda following FDA’s withdrawal of that rulemaking in late 2025. The MoCRA-mandated GMP rule is also absent, leaving its timeline undetermined.
What this means: Brands selling hair smoothing/straightening products in the US should watch for the NPRM and review formulations containing formaldehyde-releasing ingredients. Companies should also prepare for eventual fragrance allergen disclosure requirements once the proposed allergen list is published.
