Our team would like to remind you about the most significant changes that have taken place in the cosmetic industry in the last few months.

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Alert – Lilial recall in the EU market.

On 3rd November 2021, the European Commission published the Omnibus IV. This amendment, the Regulation (EU) 2021/1902 included in Annex II to the EU Cosmetics Regulation those substances that have been classified as CMR in the latest amendment of the CLP Regulation, dated 19th May 2020.

The ban applies from the 1st of March 2022 and, as you probably know, cosmetics containing Butylphenyl Methylpropional (Lilial) must not be present in cosmetic products.

Please, note that as of 15th March 2022, only products compliant with the ban can be placed and made available on the EU market.

Rapex has notified since the ban a huge number of products with Butylphenyl Methylpropional (Lilial) since today. We strongly suggest checking the formulas of all your products.

Warning for products containing Formaldehyde releasers modified.

On the 8th of July 2022, the European Commission published the Commission Regulation (EU) 2022/1181. This publication amends the preamble of Annex V to Regulation (EC) No 1223/2009. The modification lowers the current threshold for labelling formaldehyde from 500 to 10 ppm.

Therefore, all finished products containing substances that release formaldehyde shall be labelled with the warning “releases formaldehyde” where the total concentration of formaldehyde released in the finished product exceeds 0,001 % (10 ppm).

New limits for the UV filters Benzophenone-3 and Octocrylene.

The EU Cosmetics Regulation was amended on the 7th of July 2022, amending Annex VI, the list of UV filters allowed in cosmetics. Octocrylene and Benzophenone-3 use limits have been modified.

The new regulation entered into force on 28th July 2022. Cosmetic products containing Benzophenone-3 and Octocrylene in concentrations that comply with the old restrictions can still be placed on the EU market until 23rd January 2023. The products have six months to reach the EU market, until 28th July 2023.

From 28th July 2023, non-compliant products must be withdrawn from the market.

Definition of nanomaterial

On June 10, 2022, The European Commission adopted a new recommendation for the definition of nanomaterial.

Nanomaterial‘ means a natural, incidental, or manufactured material consisting of solid particles that are present, either on their own or as identifiable constituent particles in aggregates or agglomerates, and where 50 % or more of these particles in the number-based size distribution fulfill at least one of the conditions that we further explain in the following link.

Triman + info Tri logo 

Since January 1, 2022, it has been mandatory to display the Triman logo on all recyclable products and packaging. In addition, it must be accompanied by the Info-Tri logo, which contains sorting information for the consumer.

A transition period until March 9, 2023, has been granted for products produced before September 9, 2022. Therefore, manufacturers, importers, or distributors can sell the stock of old packaging but products manufactured after September 9, 2022, must have the Triman + info-Tri Logo included on the packaging.


If you have any questions, please do not hesitate to contact us and our team will be happy to help you.

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