EU impacts of cosmetics regulations: Key mid-year regulatory updates

As part of our mid-year Global Outlook webinar series, Enhesa Product Intelligence experts discuss the latest regulatory updates in 2024 so far. In our regional deep dive into chemicals and chemical products in Europe, the Middle East and Africa, Regulatory and Compliance Managing Analyst for EMEA, Kimberley de Miguel, detailed the numerous restrictions and upcoming bills regulating cosmetic products in the European Union.  

Read on for key cosmetics updates.  

Delayed revision for EU Cosmetics Regulation

The European Green Deal and EU chemicals strategy for sustainability (CSS) have triggered a targeted revision of the EU Cosmetics Regulation, noted as Regulation (EC) 1223/2009, with the aim of better managing the presence of toxic chemicals in cosmetic products.  

The proposal was initially expected in the final quarter of 2022. However, the European Commission has delayed its publication due to ongoing political discussions. As it stands now (September 2024), there is no indication of when to expect the proposal, although we do know that some of the topics to be addressed in the revised document are as follows: 

• Digital labeling 

• General ban on endocrine disruptors category 1 

• Introduction of specific provisions on respiratory sensitizers of category 1 and specific target organ toxicity (STOT) 

• Reallocation of the Scientific Committee on Consumer Safety (SCCS) within ECHA 

• Introduction of horizontal definition of nanomaterials 

• Strengthened customs enforcement — Cosmetic Products Notification Portal (CPNP) linked to customs IT systems  

When the proposal is published, it’s clear it will generate impactful changes across the EU.  

Upcoming bans and restrictions for cosmetics

In March and April, respectively, the European Commission published two new laws establishing stricter bans and restrictions for certain substances in cosmetics:  

Commission Regulation (EU) 2024/858 bans the use of certain nanomaterials and restricts hydroxyapatite (nano). 

Commission Regulation (EU) 2024/996 bans 4-methylbenzylidene camphor and further regulates the use of: 

• genistein, daidzein, kojic acid, alpha-arbutin and arbutin (effective from 1 February 2025); 

• retinol, retinyl acetate and retinyl palmitate (effective from 1 November 2025); and 

• preservatives triclocarban and triclosan (effective from 31 October 2025). 

The laws also set concentration limits for retinol, retinyl acetate and retinyl palmitate, regulating a maximum of 0.05% retinol equivalent in body lotion and up to 0.3% in other cosmetic products.   

Further bans were established in June with the draft of Omnibus Act VII, which bans cosmetic substances newly classified as carcinogenic, mutagenic or reprotoxic (CMR) in the 21st ATP to the CLP Regulation.  

By 1 September 2025, any non-compliant cosmetics must be sold or recalled. The process for manufacturers has been defined as follows: 

1. Identify products containing the soon-to-be-banned substances 
2. Inform the supply chain 
3. Source alternatives and reformulate products accordingly 
4. Update product information file (PIF) and safety assessment 
5. Relabel revised products 
6. Update CPNP notification and ensure old products are either sold or recalled by the deadline  

Cosmetic regulation amending REACH

In May, the European Commission published Commission Regulation (EU) 2024/1328, amending REACH with restrictions on D4, D5and D6 substances. The new law regulates that these substances can’t be placed on the market in a concentration > 0.1% by weight of the respective substance after 6 June 2026.

Outside of cosmetic products, the regulation also extended the transitional period for medical devices and in vitro diagnostic medical devices, medicinal products and veterinary medicinal products, and solvents in the dry cleaning of textiles, leather and fur.

Catch up on the full webinar

The above updates on cosmetics are just a portion of the many highlights from our 2024 Global Outlook for chemicals & chemical products: Mid-year review for Europe, Middle East and Africa webinar.  

Other key topics covered by our experts include: 

• The REACH restriction roadmap 

• Restrictions on mercury and POPs in the EU 

• EPR for packaging and packaging waste in the UK 

• CLP’s upcoming 22nd ATP changes 

• Labeling and packaging rules in Ukraine 

• Chemical substances in Russia 

• Product safety developments in Saudi Arabia 

• Environmental protection developments in Israel 

• EPR implementation in Jordan

Watch the webcast now