1. Ingredient Restrictions
As of February 1, 2025, the EU has implemented new restrictions on several cosmetic ingredients. Formulators and brands should ensure compliance with the following updated concentration limits:
- Genistein (CAS 446-72-0) – Maximum concentration of 0.007% in ready-to-use products.
- Daidzein (CAS 486-66-8) – Limited to 0.02% in ready-to-use products.
- Kojic Acid (CAS 501-30-4) – Permitted up to 1% in face and hand products.
- Alpha-Arbutin (CAS 84380-01-8) – Allowed up to 2% in face creams and 0.5% in body lotions.
- Arbutin (CAS 497-76-7) – Permitted up to 7% in face creams.
Products exceeding these limits are banned from the EU market effective February 1, 2025, with a full withdrawal deadline of November 1, 2025.
2. Nanomaterials Prohibition
From February 1, 2025, the EU has banned several nanomaterials from cosmetic formulations:
- Styrene/Acrylates Copolymer (nano) and its sodium variant
- Copper (nano) and Colloidal Copper (nano)
- Colloidal Silver (nano)
- Gold (nano) and Colloidal Gold (nano)
- Gold Thioethylamino Hyaluronic Acid (nano)
- Acetyl Heptapeptide-9 Colloidal Gold (nano)
- Platinum (nano) and Colloidal Platinum (nano)
- Acetyl Tetrapeptide-17 Colloidal Platinum (nano)
Additionally, Hydroxyapatite (nano) (CAS 1306-06-5) is now restricted to 10% in toothpaste and 0.465% in mouthwash, with stringent requirements for particle shape and size.
3. France’s Ban on PFAS in Cosmetics
Effective February 20, 2025, France has enacted a ban on per- and polyfluoroalkyl substances (PFAS) in cosmetics. The regulation will take full effect on January 1, 2026, prohibiting the manufacture, import, export, and sale of PFAS-containing cosmetic products in France.
4. EU Evaluation of Cosmetic Product Regulation
The European Commission has launched an evaluation of EU Cosmetic Regulation 1223/2009 to assess its effectiveness. A public consultation is open from February 21 to March 21, 2025.
5. Enforcement of Toxic Substance Regulations
A recent European Chemicals Agency (ECHA) study found that 6% of 4,686 tested cosmetic products contained restricted toxic substances, including PFAS. The findings have led to calls for stricter enforcement and the establishment of a European Testing Facility.
1. California Proposition 65 Amendments
- Short-Form Warning Labels – As of January 1, 2025, Proposition 65 (Prop 65) short-form warnings must include the name of at least one listed chemical.
- Transition Period – Businesses have until January 1, 2028, to comply. Products labeled before this date can continue to be sold under the old regulations.
2. Increased Enforcement and Notices of Violation
- 341 Notices of Violation were filed in February 2025.
- 37 notices targeted body lotions and facial scrubs, while 16 notices were issued for cosmetics such as mascara and lip balm due to the presence of diethanolamine (a known carcinogen).
3. Industry Response to Prop 65 Regulations
- 78% of businesses have reformulated products to eliminate Prop 65-listed chemicals.
- 81% of manufacturers are using Prop 65 guidelines to source safer raw materials, influencing product formulation beyond California.
Conclusion & Recommendations
February 2025 marks a period of significant regulatory changes in both the EU and US. Key takeaways for cosmetic brands and formulators include:
✔ Review formulations to ensure compliance with newly restricted ingredient levels.
✔ Assess nanomaterial content in products, particularly for those sold in the EU.
✔ Prepare for France’s PFAS ban by identifying alternative ingredients ahead of the 2026 deadline.
✔ Monitor Prop 65 enforcement trends in the US and consider reformulation strategies to eliminate flagged substances.
✔ Stay updated on EU Regulation 1223/2009 evaluation and participate in the public consultation where relevant.
For assistance with regulatory compliance, formulation adjustments, or safety assessments, contact the Technical Team at ADSL. We are here to help ensure your products meet the latest cosmetic regulations.
ADSL – Advanced Development & Safety Laboratories
Technical Team | Paignton, UK
