EU
Omnibus Act VIII: new CMR bans and restrictions published
The European Union has formally published Regulation (EU) 2026/78, the eighth annual “CMR Omnibus” regulation amending the EU Cosmetics Regulation. The text transposes the 22nd ATP of the CLP Regulation into cosmetic law and introduces extensive changes to Annexes II, III, IV and V.
Key regulatory changes include:
- Expansion of Annex II (banned substances), including several perborates, acetone oxime, reaction masses and specific industrial chemicals
- Revised regulatory status of silver, with differentiated restrictions depending on particle size
- New and significantly revised limits for hexyl salicylate across fragrances, leave-on, rinse-off and oral care products
- Updated conditions of use for preservatives such as o-Phenylphenol and o-Phenylphenate, including concentration limits, inhalation exclusions and labelling requirements.
Timeline and impact
- Application date: 1 May 2026
- No distinction between placing on the market and making available
- Non-compliant products must be withdrawn before the application date
Early portfolio screening and reformulation planning are therefore critical.
Aggregate exposure to salicylic acid under SCCS review
The European Commission has requested a scientific opinion from the Scientific Committee on Consumer Safety (SCCS) on the safety of aggregate exposure to salicylic acid and its esters in cosmetic products.
The assessment will consider:
- Cumulative exposure from multiple cosmetic products
- Different usage patterns and frequencies
- Potential impact on vulnerable consumer groups
The SCCS has 12 months to deliver its opinion. Depending on the outcome, this could lead to revised concentration limits or new conditions of use. Brands using salicylates are advised to review exposure scenarios across their entire product portfolio.
SCCS opinions on CBD and BHA bring long-awaited clarity
In January, the SCCS published two important scientific opinions addressing ingredients of high industry interest.
For Cannabidiol (CBD), the Committee concluded that:
- CBD is safe up to 0.19% in dermal and oral cosmetic products
- THC impurities must not exceed 0.00025%
- The opinion does not apply to products with potential inhalation exposure
For Butylated Hydroxyanisole (BHA), the SCCS concluded that:
- Use up to 0.07% is safe in leave-on and rinse-off products
- The assessment is limited to dermal exposure
- Oral care products and inhalation exposure are excluded
These conclusions reinforce the importance of impurity control, exposure-based safety assessment and careful product classification.
Titanium dioxide: inhalation carcinogenic classification removed
The EU has officially removed the harmonised Carcinogen Category 2 (inhalation) classification for titanium dioxide under the CLP Regulation, following a final ruling by the Court of Justice of the European Union.
What this means in practice:
- Titanium dioxide powders are no longer classified as carcinogenic by inhalation under harmonised CLP rules
- Regulatory burden related to hazard classification is reduced
- Occupational safety obligations remain unchanged, including risk assessment and worker protection
Companies should update safety data sheets where relevant and review internal risk assessments accordingly.
France bans PFAS in cosmetic products
France has adopted Decree No. 2025-1376, banning the intentional use of per- and polyfluoroalkyl substances (PFAS)in cosmetic products.
Key points:
- Entry into force: 1 January 2026
- Transitional period: 12 months for products manufactured before that date
- After the transition, any placing on the market or export is prohibited
Formulation reviews, supplier confirmations and documentation updates should be prioritised.
UK
Great Britain bans UV filter 4-MBC and new CMR substances
Great Britain has adopted Statutory Instrument 2026 No. 23, introducing a ban on the UV filter 4-Methylbenzylidene Camphor (4-MBC) and 16 additional substances classified as CMR.
The regulation also modifies the labelling threshold for formaldehyde releasers. Importantly:
- The UK threshold is aligned with the EU, not divergent
- The EU adopted the same precautionary limits in 2022
- Existing preservative systems and formulations may remain unchanged
That said, the update raises practical questions around testing strategies, interpretation of formaldehyde release and documentation consistency.
HEMA and HMPA: UK HSE opinion on nail products
The UK Health and Safety Executive (HSE) has issued a scientific opinion on HEMA and HMPA, two acrylic monomers commonly used in artificial nail systems.
The opinion highlights:
- Strong skin sensitisation potential, even at low concentrations
- Increased risk linked to incomplete polymerisation
- Higher exposure for professional nail technicians
- Additional risks associated with untrained consumer use
The HSE recommends restricting use to trained professionals, alongside enhanced labelling, training and risk management measures. This reinforces the growing regulatory focus on nail product safety across Europe.
USA/Canada
California targets 1,4-dioxane in shampoos
California has proposed adding shampoos containing more than 1 ppm of 1,4-dioxane to its list of Priority Products, alongside manual dish detergents.
If adopted, this would:
- Trigger additional compliance obligations
- Require alternatives analysis
- Potentially lead to reformulation or supplier changes
The proposal reflects continued regulatory scrutiny of manufacturing impurities linked to ethoxylated ingredients.
MoCRA: implementation continues to evolve
While the Modernization of Cosmetics Regulation Act (MoCRA) is now two years old, its implementation is still ongoing.
Current status highlights:
- Facility registration and product listing requirements are in force
- Several implementing rules remain pending
- Regulatory expectations are becoming clearer through early enforcement practice
Companies active in the US market should continue monitoring developments and aligning internal compliance systems accordingly.
Switzerland
1 ppm limit for furocoumarins in leave-on cosmetics
From 1 January 2026, Switzerland will apply a group limit of 1 ppm to eight selected furocoumarins in leave-on cosmetic products exposed to sunlight.
The limit:
- Applies to most leave-on products used on sun-exposed skin
- Excludes perfumes, rinse-off products, hair care, oral care and night products
- Represents a Swiss derogation from the EU Cosmetics Regulation
Products containing citrus essential oils or botanical extracts should be reviewed carefully, with combined concentration calculations and updated technical documentation.
