Cosmetic regulation in the EU and UK does not stand still. The EU's rolling Omnibus amendment programme adds banned substances to Annex II every year, and the UK is building an independent GB-specific substances list following its departure from EU law. The result for cosmetic brands is a compliance calendar that requires active monitoring — not a one-time review. The deadlines below are the ones that should be driving reformulation and documentation decisions right now.
For context: in 2024, EU Safety Gate recorded 4,137 alerts — the highest since the system launched in 2003 — with cosmetics accounting for 36% of all alerts, the most flagged category for the second consecutive year. US facility registrations under MoCRA reached 9,528 active registrations as of January 2025, nearly double the total ever registered voluntarily under the prior VCRP programme. Enforcement pressure is rising in every major market.
European Union
1 September 2025 — EU Omnibus VII in Force (Regulation EU 2025/877)
Commission Regulation (EU) 2025/877 added 22 CMR (carcinogenic, mutagenic, or reprotoxic) substances to Annex II of the EU Cosmetics Regulation — the banned substances list. Among these, TPO (diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide), widely used as a photoinitiator in gel nail products, was banned with no transition period. Products containing any of the 22 newly banned substances could not be placed on the EU market from 1 September 2025. Products already on the market were subject to a sell-through period. Source: Regulation (EU) 2025/877.
1 May 2026 — EU Omnibus VIII Applies (Regulation EU 2026/78)
Regulation (EU) 2026/78, published in the Official Journal on 13 January 2026, brings further restrictions to Annexes II, III, IV, and V of the EU Cosmetics Regulation. Perborate derivatives and additional CMR substances are prohibited. Brands with affected ingredients in formulations have until 1 May 2026 to withdraw products from the EU market. The regulation also includes modifications to conditionally permitted substances in Annex III, requiring label updates for affected products. Source: Regulation (EU) 2026/78.
31 July 2026 — EU Nano Ingredient Prohibitions Apply (Regulation EU 2024/858)
Commission Regulation (EU) 2024/858 introduces new prohibitions on specific nano-form ingredients in cosmetics. Products placed on the EU market from 31 July 2026 must not contain the nano-form substances specified in the regulation. Products placed on the market before this date may continue to be sold through their natural shelf life. Cosmetic brands using nano-form sunscreen filters, nano silver, or other nano-form actives should audit their formulations against the prohibited list. Source: Commission Regulation (EU) 2024/858.
1 January 2027 — EU Proposed: 15 Further CMR Substances Banned
A further set of 15 CMR substances — including Triphenyl Phosphate — was notified to the WTO in May 2025 under notification G/TBT/N/EU/1140 and is subject to final adoption as a Commission Regulation in 2026. If adopted on the proposed timeline, market placement would be prohibited from 1 January 2027, with a sell-through period ending 1 July 2028. This is a proposed measure and subject to change pending final adoption. Brands should monitor the Official Journal and update reformulation planning accordingly. Source: WTO notification G/TBT/N/EU/1140.
United Kingdom
15 July 2026 — UK 4-MBC UV Filter Banned; Formaldehyde Labelling Threshold Tightened
UK Statutory Instrument 2026 No. 23 introduces two significant changes for GB-market cosmetics. First, 4-methylbenzylidene camphor (4-MBC), a UV filter used in sun care products, is banned from being placed on the GB market from 15 July 2026. Second, the threshold at which a formaldehyde-releaser warning must appear on-label drops from 0.05% to 0.001% — a 50-fold tightening that will require label updates for a significant range of preservative-containing formulations. Products already on the market before the enforcement date may continue to be sold through their natural shelf life. Source: UK SI 2026 No. 23.
15 August 2026 — UK 16 CMR Substances Banned from Market Placement
Also under UK SI 2026 No. 23, 16 CMR substances are banned from being placed on the GB market from 15 August 2026. The list includes TPO (already banned in the EU under Omnibus VII), clothianidin, dimethyl propylphosphonate, and dibutyltin maleate. Products containing these substances that are already in the distribution chain may be sold through until 15 February 2027 — after which point all stock must be withdrawn regardless of manufacture date. Brands selling in both the EU and GB will need to confirm that formulations comply with both the EU Omnibus VII/VIII substance lists and the GB-specific SI 2026 No. 23 list, which are similar but not identical. Source: UK SI 2026 No. 23.
Planning for These Deadlines
The EU and UK enforcement calendars are diverging. The EU Omnibus programme continues to add banned substances annually through the Commission Regulation process, while the UK is now building an independent regulatory position under its post-Brexit framework. Brands selling in both markets need separate compliance tracking for each jurisdiction — an ingredient banned in the EU is not automatically banned in the UK, and vice versa.
For any product approaching a deadline, the critical path is: formulation review against the updated Annex, reformulation or withdrawal decision, label copy update, print and packaging lead time, and distributor notification. For large-format products with long print runs, this process typically requires at least six months of lead time from the date of confirmed regulatory change.
Deadline coming up?
We can review your product against the upcoming EU and UK changes and tell you exactly what needs to change — and by when.
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