EU
Reminder: Full Implementation of Regulation (EU) 2024/858 (Nanomaterials) — 1 Nov 2025
What changes
- 12 nanomaterials prohibited in cosmetics (e.g., Colloidal Silver/Gold/Platinum and peptide-functionalized variants; Styrene/Acrylates Copolymer (nano); Sodium Styrene/Acrylates Copolymer (nano), etc.).
- Hydroxyapatite (nano) now restricted:
- Only in toothpastes (≤10%) and mouthwashes (≤0.465%).
- Only rod-shaped particles meeting strict aspect-ratio specs; no coating/surface modification.
- Prohibited in any use leading to inhalation exposure.
Timing & scope
- Applies to products placed on the market since 1 Feb 2025.
- Becomes fully enforceable for products made available on the market on 1 Nov 2025 (non-compliant stock must be withdrawn).
What to do now
- Audit raw material specs for nano status and morphology claims; request particle size distribution and shape data.
- Replace/phase out listed nanos; verify HAp (nano) meets limit, morphology, and non-inhalation use.
- Prepare withdrawal plans for legacy SKUs before 1 Nov 2025.
Reminder: Multiple Provisions of Regulation (EU) 2024/996
Effective 31 Oct 2025 (made available on the market)
- Triclocarban ≤0.2% in all cosmetics; forbidden in toothpastes intended for children under 6.
- Triclosan ≤0.3% in toothpastes, hand soaps, body washes/shower gels, non-spray deodorants, face powders/blemish concealers, and nail cleansers before artificial systems; forbidden in toothpastes for children under 3.
- (These limits have applied to placed on the market since 31 Dec 2024.)
Effective 1 Nov 2025 (made available on the market)
- Genistein ≤0.007%
- Daidzein ≤0.02%
- Kojic Acid ≤1% in face and hand products
- Alpha-Arbutin ≤2% (face creams) and ≤0.5% (body lotions)
- Arbutin ≤7% (face creams)
- (These limits have applied to placed on the market since 1 Feb 2025.)
Heads-up (future) — Retinoids
- Retinol, Retinyl Acetate, Retinyl Palmitate at 0.05% RE in body lotions and 0.3% in other products apply to products placed on the market and become enforceable for products placed from 1 May 2027.
What to do now
- Lock formula specs and labels for all affected actives.
- Recalculate retinoid RE where used; adjust pack claims and warnings.
- Segregate non-compliant inventory and plan a sell-through/withdrawal strategy.
Microplastics Regulation: First Provisions
What changes
- If your product benefits from the “permanently modified” derogation (the polymer no longer falls under entry 78 after intended end use), consumer-facing instructions for use and disposal are now mandatory to prevent releases (e.g., “Do not rinse container before disposal”).
- For B2B products within the entry 78 scope, suppliers must provide industrial-user information: usage/disposal instructions to prevent releases, a specific statement noting subjection to REACH entry 78, quantity/concentration of SPMs, and generic polymer identity data.
What to do now
- Update packaging artwork and SDS annexes to include the required statements.
- Ensure instructions are clear, visible, and durable on pack or via acceptable media linked on pack.
- Train customer service and sales teams on the new phrases and scope.
Corrigendum to Cosmetics Regulation 1223/2009 (Labelling “ingredients”) — 9 Oct 2025
- In FR, EL, HR, PT, RO, the heading preceding the INCI list changes to the English word “ingredients” (replacing the local term).
- Authorities indicate it can be implemented in the next print run, provided you document consideration from 9 Oct 2025.
What to do now
- Update your artwork master templates for the five languages.
- File evidence (change control forms, emails to printers) to show timely adoption.
CLP Revision Timeline Postponed — Target Date: 1 Jan 2028
- As part of Omnibus VI, Parliament supports delaying the application of several new CLP provisions (label structure/typography, 6-month re-labeling window post-classification changes, extended advertising content, online/distance-selling rules).
- The Council already endorsed the text (24 Sep 2025); formal adoption to follow.
What to do now
- Use the extra runway to design new label templates, test UX for online display requirements, and plan relabeling cycles that align with supply chain realities.
Reminder: Additional SI 2024 No.1334 Prohibitions
- Now prohibited for making available on the market: Methylene Di-T-Butylcresol, MIBK, Benzophenone, Theophylline, Trimethylolpropane Triacrylate, Azadirachta Indica Seed Extract, and Melamine.
- Ban already applied to be placed on the market from 20 Apr 2025.
What to do now
- Scrub supplier specs, trade names, and blends for these substances.
- Use positive release checks to prevent accidental shipments post-deadline.
Reminder: IFRA 51 — Final Compliance for Existing Creations
- The 51st Amendment (59 changes: 1 Specification Standard, 46 Restriction Standards, etc.) is now fully applicable.
- The 28-month conversion window for existing creations expired on 30 Oct 2025.
What to do now
- Confirm IFRA certificates and allergen calculations for each defined product use.
- Document that the specific compound complies in each consumer product category you sell.
United Kingdom
Reminder: Kojic Acid Restrictions Fully in Force — 1 Nov 2025
- Under Statutory Instrument 2024 No.1334
- Kojic Acid limited to ≤1% and only in face and hand products.
- Applies to products made available on the market from 1 Nov 2025 (already applicable to placed on the market since 20 Jun 2025).
- Non-compliant SKUs must be withdrawn from the market.
What to do now
- Verify traded goods (imported) meet GB rules (they differ slightly from EU).
- Update claims/usage panels to avoid off-scope applications (e.g., body uses).
United States
California AB-823 — Plastic Microbeads & Plastic Glitter (Personal Care)
Key provisions
- From 1 Jan 2029:
- Prohibits plastic glitter in personal care products.
- Prohibits plastic microbeads used as abrasives in leave-on personal care and cleaning products.
- Sell-through of existing stock containing plastic glitter allowed until 1 Jan 2030.
- Enforced under the Plastic Microbeads Nuisance Prevention Law (civil penalties).
What to do now
- Begin R&D on biodegradable glitter and non-abrasive sensory alternatives.
- Plan artwork and marketing updates now to avoid late-stage product/claim conflicts.
Canada
Cosmetic Notification Form (CNF) Updates
Usability & data integrity
- Section 4 (Contacts): “Select Contact” lets you pre-populate contact fields.
- Section 5 (Ingredients):
- “Other Chemical Name” becomes “If no INCI name is available, the Chemical Name.”
- New “Fragrance Allergen” checkbox to flag allergens above disclosure thresholds (align with labeling guide Appendix 1).
- Mandatory label upload trigger for certain hazardous ingredients (e.g., PPD/coal tar dyes) — form will show an error if missing.
What to do now
- Align your ingredient database with INCI-first logic and clear backups for chemical names.
- Tag fragrance allergens in your PIF and CNF; prepare label files in Section 6 before submission.
