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If you thought 2025 was a whirlwind for compliance, hold onto your lab coats. On the 27th of April 2026, the European Commission dropped a significant update that we’ve all been anticipating—Commission Regulation (EU) 2026/909.
The amendment to the EU Cosmetics Regulation (EC) No 1223/2009 modifies fragrance allergens, UV filters, hair dyes and heavy-hitting minerals like Aluminium. If your portfolio includes fragrances, sunscreens, or hair colourants, you’ll want to pay close attention.
Fragrance ingredients: Benzyl Salicylate, Citral, and Vetiver Oil
Fragrance allergens are always within scope, but the restrictions on Benzyl Salicylate and Citral (and its family, Geranial and Neral) in this regulation are particularly stringent. Now, these ingredients will have a limit on their use depending on the product category, as different concentrations of use were defined for different products.
- Benzyl Salicylate: Known for its floral notes, it’s a must in many “clean” scents. However, due to concerns regarding its potential as an endocrine disruptor, Regulation 2026/909 introduces tight concentration limits, modifying the entrance in Annex III.
- Citral, Geranial, and Neral: A citrus powerhouse. The new limits settled in Annex III are designed to mitigate the risk of skin sensitisation.
- Acetylated Vetiver Oil: Used as a fragrance, it is now subject to specific stability conditions and concentration limits. The new entrance in Annex III aims to ensure that the constituents of the oil do not pose a sensitisation risk to consumers.
NOTE: If you haven’t already audited your fragrance oils with your perfume houses, do it now! These changes often necessitate a “re-dosing” of the fragrance, which can subtly alter the olfactive profile of your best-sellers
The metallic trio: Aluminium-containing ingredients, Zinc salts, and Silver silicate
Aluminium and its Compounds
The conversation around Aluminium has been bubbling for years. We finally have a definitive stance in this 2026 update.
A new entry in Annex III now sets specific maximum concentrations for Aluminium- containing ingredients, limiting the concentration for deodorants and antiperspirants, among other products. This is largely based on the SCCS’s assessment of systemic exposure and the risk of accumulation. Aluminium- containing ingredients, except for those listed in the different entries of Annex III, IV, V, and VI, are now regulated.
Water-Soluble Zinc Salts
Whether it’s Zinc Sulphate, Zinc Glutamate or Zinc Chloride, these ingredients are common in oral care and skin-conditioning products. The new regulation harmonises the use of the water-soluble zinc salts, ensuring that the total zinc content across multiple products doesn’t lead to excessive daily intake. In Annex III, entries 24, 70 and 75 are replaced by the new entrance, setting the use of the different Zinc salts.
Ammonium Silver Zinc Aluminium Silicate
The ingredient is primarily used as a preservative or antimicrobial agent. The inclusion of Ammonium Silver Zinc Aluminium Silicate in Annex V (allowed preservatives) marks a move towards tighter control over silver-based technologies in cosmetics, focusing on dermal penetration and long-term safety. The ingredient can be used as a preservative in deodorant sprays and powder foundations up to 1%. The rest of the Silver Zinc Zeolites are included in Annex II, so their use is not allowed in cosmetic products.
Now prohibited: Triphenyl Phosphate (TPP)
Triphenyl Phosphate (TPP), which wasn’t regulated, was often used as a plasticiser in nail polishes to prevent chipping. The SCCS could not conclude on the safety of Triphenyl Phosphate, the ingredient has been under scrutiny for its potential impact on the endocrine system, so the EU is taking a precautionary approach. Regulation 2026/909 introduces a ban that will force many nail care brands to reformulate, as the ingredient is included in Annex II.
The colour palette: hair dyes
The hair care sector is perhaps the most impacted by this update. The EU continues its mission to ensure hair dyes are as safe as possible, leading to new entries and modifications in Annex III and Annex VI.
- HC Blue No 18, HC Red No 18, and HC Yellow No 16: These hair dyes have undergone rigorous safety assessments. The new entrances in Annex III define their maximum concentrations in oxidative and non-oxidative hair dye products, as well as the warnings that should be placed on the labelling of the products.
- Hydroxypropyl-p-phenylenediamine (and its dihydrochloride salt): This new entrance in Annex III is a significant update for professional hair colourants. The ingredient use must not exceed 2%, and labelling requirements have been clearly stated to ensure users are aware of the potential for allergic reactions and make good use of the ingredients.
Key deadlines you need to plan for (2027-2028)
Compliance isn’t a destination; it’s a constant state of motion. The regulation establishes a clear transition timeline:
- 1st January 2027, non-compliant cosmetic products cannot be placed on the EU market.
- 1st July 2028, non-compliant products cannot be made available on the EU market. For certain substances such as Citral, the deadline extends to 1 August 2028.
Typically, the brands have 12 to 18 months to reformulate and 24 months to keep the existing products on the market.
In practice, these transition periods leave brands with limited time to:
- reformulate affected products,
- update CPSRs and PIF documentation,
- revise labels and artworks,
- validate stability and compatibility,
- coordinate existing stock phase-out.
For many cosmetic brands, the biggest challenge will not necessarily be reformulation itself, but coordinating all related compliance updates simultaneously.
Regulation 2026/909 confirms a broader regulatory trend in the EU, stricter control of sensitising substances with an increased focus on vulnerable populations such as children. Also, a greater scrutiny of impurities and contaminants, with a stronger reliance on SCCS scientific opinions. Cosmetic compliance is becoming more detailed and more data-driven. Ensure your PIF and INCI lists are impeccable.
The brands should identify every product that contains the substances mentioned above. Sometimes these ingredients are “hidden” as components of a complex botanical extract or fragrance blend.
How Cosmeservice supports your compliance strategy
The EU cosmetic landscape is arguably the most rigorous in the world, and while these updates might feel like a headache for R&D teams, they strengthen consumer trust. When a consumer buys a product in the EU, they do so with the confidence that the “latest science” is guarding their skin.
Cosmeservice, as your Responsible Person (RP) and Safety Assessor, can help with the changes. Even if your concentration hasn’t changed, the justification for its safety might need to be updated in the PIF to reflect the new SCCS opinions referenced in Regulation 2026/909.
If the thought of auditing all your SKUs for compliance check makes your head spin, that’s what we’re here for. We don’t just read the law; we translate it into a strategy that keeps your brand moving forward.
Want to ensure your products are ready for the 2027 deadline?
Complete the contact form, and our team will get back to you as soon as possible. You may also reach us via info@cosmeservice.com or by calling us!
FAQS
1. Which ingredients are affected by EU Regulation 2026/909?
Regulation (EU) 2026/909 introduces new restrictions, bans, and conditions of use for several cosmetic ingredients under the EU Cosmetics Regulation.
The main affected substances include:
- Benzyl Salicylate
- Triphenyl Phosphate
- Aluminium
- Water-soluble zinc salts
- Citral
- Acetylated Vetiver Oil
- DHHB
- HC Blue No 18
- HC Red No 18
- HC Yellow No 16
- Hydroxypropyl-p-phenylenediamine and related salts
- Ammonium Silver Zinc Aluminium Silicate
The amendment updates multiple Annexes of Regulation (EC) No 1223/2009, including prohibited substances, restricted substances, preservatives, and UV filters.
At Cosmeservice, we help cosmetic brands identify affected ingredients across their full portfolio, including fragrances, colorants, and raw material blends.
2. What are the compliance deadlines under EU Cosmetics Regulation 2026/909?
The regulation entered into force on 18 May 2026, with transitional periods applying depending on the ingredient and product category.
For many affected products, the main compliance deadline is linked to 2027, meaning non-compliant products may no longer be placed on the EU market after the applicable date.
Because reformulation, testing, artwork updates, and CPSR revisions can take months, brands should begin reviewing their products as early as possible.
Cosmeservice supports brands with compliance planning, regulatory gap analysis, and transition strategies to help avoid disruptions before the deadline.
3. Do I need to reformulate my cosmetic products because of EU 2026/909?
Possibly. Some ingredients are now prohibited, while others are subject to new concentration limits or conditions of use. Whether reformulation is necessary depends on:
- the ingredient,
- its concentration,
- the product type,
- and the latest SCCS safety conclusions.
Products containing prohibited substances such as Triphenyl Phosphate will likely require reformulation.
In other cases, the formula may remain unchanged, but the product could still require:
- updated safety documentation,
- revised labels,
- new warnings,
- or additional testing.
Cosmeservice can review your formulas and determine whether reformulation or regulatory updates are required.
4. Can products already on the market still be sold after Regulation 2026/909?
It depends on the transitional provisions for each ingredient.
In general, products already placed on the market before the deadline may continue to circulate for a limited period, while newly placed products must comply with the updated requirements.
However, retailers and distributors may apply stricter internal policies and request updated compliance documentation before the legal deadline.
Cosmeservice can help assess your existing stock situation and define the safest regulatory strategy for EU market continuity.
5.How does EU 2026/909 affect cosmetic Safety Assessments and CPSRs?
This amendment can significantly impact Cosmetic Product Safety Reports (CPSRs).
Safety Assessors may need to reassess:
- ingredient safety,
- exposure calculations,
- Margin of Safety (MoS),
- inhalation exposure,
- and updated SCCS opinions.
Even if the formulation has not changed, the CPSR may still require revision due to the new regulatory conditions.
At Cosmeservice, our regulatory team and Safety Assessors can review your CPSRs and update the technical documentation according to the latest EU requirements.
6. Will cosmetic labels and allergen declarations need updating under EU 2026/909?
Yes, in many cases. Some affected ingredients are linked to:
- fragrance allergen declarations,
- revised warnings,
- updated conditions of use,
- and INCI list changes.
If a product is reformulated, labels, artworks, and CPNP information may also need updating to remain fully aligned.
Cosmeservice supports cosmetic brands with label review, artwork compliance verification, and regulatory updates across EU cosmetic requirements.
7. How can cosmetic brands check if their products comply with Regulation (EU) 2026/909?
Brands should carry out a full regulatory review of their products, including:
- Formula screening
- Ingredient concentration checks
- CPSR review
- Label verification
- Allergen declaration assessment
- Raw material documentation review
- Compliance timeline evaluation
Many brands underestimate how much documentation may need updating under this amendment.
As an experienced cosmetic regulatory consultancy, Cosmeservice helps brands manage the full compliance process, from formula review and safety assessment to labelling, claims verification, and EU market support.
8. Does EU Cosmetics regulation 2026/909 apply to the UK?
Not entirely. Since Brexit, Great Britain follows its own UK Cosmetics Regulation and does not automatically adopt new EU cosmetic amendments. However, Northern Ireland continues to align with EU cosmetic legislation under the Windsor Framework. Cosmetic brands operating across both the EU and UK markets should therefore monitor regulatory divergence carefully, as ingredient restrictions and compliance timelines may differ between jurisdictions.
References
- Commission Regulation (EU) 1223/2009
- EUR-Lex full legal text (EU) 2026/909
→ Complete Annex changes (II, III, V, VI) - EFTA factsheet on Regulation (EU) 2026/909
→ Structured overview of the regulation - Scientific basis: SCCS opinions referenced within the regulation (Benzyl Salicylate, Aluminium, Zinc salts, etc.)
