Key Changes in Cosmetic Legislation (EU, UK & US)
As the regulatory landscape for cosmetics continues to evolve across major markets, formulation and compliance teams face the ongoing challenge of keeping up with regional updates that affect everything from permitted ingredients to labelling and product claims. This month’s round-up highlights key regulatory developments in the UK, EU, US, and Canada as of July 2025, with a focus on contextualising their impact for professionals working at the intersection of product development, testing, and market access.
Oxybenzone Restrictions Signal Further Regulatory Divergence
The UK government has now formalised its position on oxybenzone (benzophenone-3), with Statutory Instrument 2025 No. 901 bringing new restrictions into effect. From 21 January 2026, cosmetic products in Great Britain may only contain oxybenzone up to the new prescribed limit. A six-month grace period extends to 21 July 2026 for removing non-compliant products from sale.
While the UK has aligned with the EU in restricting oxybenzone, it has opted not to mirror the EU’s revised limits on homosalate—an active UV filter also under scrutiny. This decision introduces further divergence between UK and EU regulatory frameworks, particularly for brands manufacturing products with global formulations.
Impacted Products: Sunscreens and other SPF-containing formulations sold in the UK. Reformulation may be necessary depending on existing UV filter content.
Major Shifts in Safety and Sustainability Priorities
Several significant regulatory changes are underway in the EU, reflecting the bloc’s continued emphasis on consumer safety, ingredient transparency, and environmental claims.
1. Omnibus VII Regulation (EU) 2025/877
Coming into force on 1 September 2025, this legislation introduces a ban on 21 substances classified as carcinogenic, mutagenic, or reprotoxic (CMR). Notably, there is no sell-through period—products containing these substances must be off shelves by the enforcement date. Manufacturers and Responsible Persons must ensure formulas are fully compliant ahead of time.
2. Homosalate Limitations
As of 1 July 2025, homosalate is restricted to 7.34%, and its use is now confined to face products in non-spray form. This restriction stems from concerns raised by the Scientific Committee on Consumer Safety (SCCS) regarding potential endocrine activity at higher concentrations.
3. EU Cosmetics Regulation “Fitness Check”
A comprehensive stakeholder consultation is underway, with responses due by 28 July 2025. The European Commission is seeking feedback on how the core regulation (EC) 1223/2009 is functioning in practice—particularly around topics such as green claims, online sales, and digital labelling. While not an immediate regulatory change, it may set the tone for substantial reform in the years ahead.
Impacted Products: Face creams, sunscreens, nail and hair products, and any cosmetics containing CMR-classified substances. Manufacturers exporting to the EU should audit formulations now to ensure uninterrupted market access.
MoCRA Implementation Continues
While there are no specific July changes to note, the US regulatory environment remains in a state of transition due to the ongoing implementation of the Modernization of Cosmetics Regulation Act (MoCRA). MoCRA represents the most significant overhaul of US cosmetics law in decades, introducing mandatory facility registration, adverse event reporting, and expanded FDA oversight.
At this stage, focus remains on ensuring cosmetic manufacturers and distributors meet new registration and reporting obligations, with particular scrutiny around safety substantiation and potential harmonisation with international standards.
Impacted Products: All cosmetics marketed in the US, especially those manufactured overseas or containing ingredients newly restricted in other markets.
Fragrance Allergen Labelling Introduced
Health Canada has finalised changes to its Cosmetic Notification Form (CNF) Guide, with a significant update around fragrance allergen disclosure. From 12 April 2026, cosmetic products must declare 26 designated fragrance allergens on both the CNF and product labelling, mirroring thresholds found in EU regulation (0.001% in leave-on products; 0.01% in rinse-off products).
In addition, any CNF submission must now include a Canadian address for the importer or manufacturer, reinforcing traceability and enforcement capabilities.
Impacted Products: Any cosmetics sold in Canada containing fragrance compounds—especially moisturisers, perfumes, and rinse-off cleansers. Early formulation review is recommended to ensure accurate labelling and notification compliance.
Looking Ahead
For brands operating internationally, the July updates reinforce two key trends: the continued push toward safer, more transparent formulations—and the growing complexity of maintaining compliance across jurisdictions. While some regulatory themes echo global alignment (such as allergen labelling and UV filter reassessment), others underscore a more fragmented landscape post-Brexit and amid shifting US priorities.
As always, ADSL remains committed to supporting clients with up-to-date guidance, testing solutions, and regulatory insight. For specific queries or support in reviewing formulations and preparing compliant documentation, please don’t hesitate to contact our team.
How ADSL Can Help
We support brands and manufacturers in navigating global regulatory change through:
✅ Ingredient & INCI reviews
✅ Reformulation support for banned/restricted substances
✅ SPF claims and testing guidance
✅ MoCRA product/facility listings
✅ UK/EU regulatory divergence checks
✅ Canadian label updates
📩 Need help interpreting or applying these changes?
Contact your ADSL project lead or email us at [email protected]
ADSL – Advanced Development & Safety Laboratories
Technical Team | Paignton, UK
