EU Cosmetics Requirements: Upcoming Changes & Deadlines

This blog was originally posted on 6th July, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY FREIDA WÜSCHNER GUBBINS, SENIOR REGULATORY COMPLIANCE SPECIALIST, ADHERENT

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Key Insight

The EU cosmetics sector faces a series of strict new regulatory deadlines between 2026 and 2028, encompassing ingredient bans, expanded allergen labelling, and environmental restrictions. Cosmetic brands and manufacturers must proactively audit formulations, update product labels, and manage inventory timelines to comply with these sweeping changes and avoid costly product withdrawals.

Table of Contents

• Introduction
• Key Regulatory Deadlines
• What Businesses Need to Consider
• Conclusion
• Frequently Asked Questions

Introduction

The first half of 2026 has already proven demanding for the EU cosmetics sector, marked by the introduction of stringent new CMR reclassifications under Regulation (EU) 2024/2564. However, the pace of regulatory change is not slowing down. For businesses placing cosmetic products on the EU market, staying ahead of compliance obligations remains a critical task. Over the coming months and years, a wave of major transitions spanning ingredient bans, expanded allergen labelling, and new environmental restrictions will take effect, requiring proactive preparation.

Want to stay ahead of regulatory trends in Cosmetics? Check out our 12-18 month outlook.

Key Regulatory Deadlines

July 15, 2026: End of Phase Out Period for ‘Unlabelled’ Existing Stock and Deadline for Formaldehyde-Releaser Labelling

• The Change: The threshold that triggers a mandatory “releases formaldehyde” consumer warning drops significantly to 0.001% (10 ppm). Essentially, from this date the transitional “sell-through” period for products meeting older labelling rules ends, and any cosmetic product that does not comply with the new formaldehyde labelling rules must be completely withdrawn from retail shelves and can no longer be made available (sold or distributed) on the EU market.
• Impacted Preservatives: DMDM Hydantoin, Imidazolidinyl Urea, Diazolidinyl Urea, and Quaternium-15.
• Regulation: EU 2022/1181

July 31, 2026: Expanded Fragrance Allergen Labelling

• The Change: The list of mandatory fragrance allergens requiring individual disclosure under Annex III expands dramatically from 26 to 81 substances.
• Impact: Brands must update labels for any products containing the newly listed fragrance allergens above 0.001% for leave-on and 0.01% for rinse-off products.
• Regulation: EU 2023/1545

January 1, 2027: New Ingredient Restrictions

• The Change: Under the newly adopted Regulation (EU) 2026/909, a broad group of ingredients faces strict new maximum concentration limits or outright bans. Non-compliant products cannot be placed on the EU market from this date.
• Key Substances Impacted:
  • Triphenyl Phosphate: Fully prohibited (added to Annex II).
  • Aluminium & Aluminium-containing ingredients: Subject to new specific category limits (e.g., antiperspirants, toothpaste, lip products).
  • Water-soluble zinc salts: Strict new age- and product-specific concentration limits.
  • Citral, Geranial, Neral, Benzyl Salicylate, and Acetylated Vetiver Oil: Subject to revised restriction and stability requirements.
• Regulation: EU 2026/909

May 1, 2027: Market Restrictions for Vitamin A (Retinol)

• The Change: Cosmetic products containing Retinol, Retinyl Acetate, or Retinyl Palmitate that do not comply with the newly established maximum concentration limits (e.g., 0.3% for leave-on face products) can no longer be placed on the Union market.
• Regulation: EC 1223/2009

June 6, 2027: Siloxanes Ban (D4, D5, and D6)

• The Change: Cyclosiloxanes D4, D5, and D6 in concentrations equal to or greater than 0.1% by weight can no longer be placed on the market or used.
• Impact: This restriction explicitly covers leave-on cosmetics (for D4, D5, and D6) and rinse-off cosmetics (for D6, aligning it with existing D4/D5 rinse-off bans).
• Regulation: EU 2024/1328

October 17, 2027: Phase Out of Intentionally Added Microplastics

• The Change: The transitional period for rinse-off cosmetic products ends. From this date, rinse-off cosmetics containing intentionally added synthetic polymer microparticles (microplastics) can no longer be placed on the market.
• Regulation: EU 2023/2055

July 1, 2028: Deadline for Selling Existing Stock Containing Restricted or Prohibited Substances

• The Change: Products containing the substances restricted under Regulation (EU) 2026/909 (such as Triphenyl Phosphate or non-compliant Aluminium/Zinc formulations) that were placed on the market before January 2027 must be completely withdrawn from store shelves. The full list of impacted substances includes:
  • Triphenyl Phosphate (typically used as a plasticizer in nail polish)
  • Water-soluble zinc salts with the exception of zinc 4- hydroxy-benzene sulphonate (typically used in oral products)
  • 3,7-Dimethyl-2,6-octadienal (Citral) (typically used in lip make-up, deodorants, antiperspirants, eye and fragrance products)
  • 2 hydroxybenzoic acid phenylmethyl ester (typically used in oral and fragrance products etc)
  • Aluminium containing ingredients (typically used in antiperspirants, lipsticks, toothpaste, and make-up)
  • Vetiveria zizanioides, ext., acetylated; Oils, vetiver, acetylated (typically used in fragrance products, deodorant, make-up, leave-on products and rinse-off products)
  • Benzoic acid, 2-[4-(diethylamino)-2-hydroxybenzoyl]-, hexyl ester (typically used as a UV filter)
• Regulation: EU 2026/909

What Businesses Need to Consider

To effectively navigate these upcoming deadlines, cosmetic brand owners, manufacturers, and Responsible Persons (RPs) should proactively take the following steps:

• Audit Product Formulations: Cross-reference your raw materials against the expanded fragrance allergen list, upcoming siloxane bans, and the new concentration limits for Aluminium, Zinc, and Vitamin A.
• Reformulate & Substitute: Initiate raw material substitutions immediately for banned items like Triphenyl Phosphate and intentionally added microplastics in rinse-off formats.
• Update Product Labelling: Verify allergens and overhaul ingredient lists (INCI) well ahead of the July 2026 allergen and formaldehyde-releaser deadlines.
• Revise Safety Documentation: Ensure your Cosmetic Product Safety Reports (CPSR) are updated by your safety assessor to reflect the new regulatory limits.
• Manage Inventory Phase-Out: Strategise your supply chain timelines to ensure non-compliant stock is sold before the respective “making available” deadlines to avoid costly product recalls.

Conclusion

The regulatory landscape in the EU demands constant vigilance. By mapping out critical deadlines early, cosmetic brands can better transition their products, reduce potential remedial costs, protect their supply chains, and maintain uninterrupted compliance in one of the world’s largest beauty markets.

Want an in-depth look at PFAS in Cosmetics in the US? Read our blog ‘PFAS in Cosmetics: US State Bans and Compliance Deadlines – 2026 Update‘.

Frequently Asked Questions

• What is the new consumer warning threshold for formaldehyde-releasers, and when does it take effect?
  The threshold that triggers a mandatory “releases formaldehyde” consumer warning drops to 0.001% (10 ppm). The transitional “sell-through” period ends on July 15, 2026, by which date non-compliant products must be completely withdrawn from retail shelves.
• How many fragrance allergens will require mandatory individual disclosure after July 31, 2026?
  The list of mandatory fragrance allergens requiring individual disclosure expands from 26 to 81 substances. Brands must disclose these on labels if they exceed 0.001% for leave-on products and 0.01% for rinse-off products.
• What are the restrictions and deadlines regarding Vitamin A (Retinol)?
  Starting May 1, 2027, cosmetic products containing Retinol, Retinyl Acetate, or Retinyl Palmitate that do not comply with newly established maximum concentration limits (such as 0.3% for leave-on face products) can no longer be placed on the Union market.
• Which ingredients face strict concentration limits or outright bans starting January 1, 2027, under Regulation (EU) 2026/909?
  Triphenyl Phosphate will be fully prohibited. In addition, Aluminium & Aluminium-containing ingredients, water-soluble zinc salts, Citral, Geranial, Neral, Benzyl Salicylate, and Acetylated Vetiver Oil face strict new concentration limits, category limits, or revised restrictions.
• When must existing stock containing substances restricted under Regulation (EU) 2026/909 be completely sold or withdrawn?
  Products placed on the market before January 2027 that contain these restricted substances must be completely withdrawn from store shelves by July 1, 2028.

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