Since Brexit there have been growing divergences between the UK and EU regulations for cosmetics. Here we will outline some of the more frequently used chemicals affected:
CTPA tracker may be found in the link below.
https://www.ctpa.org.uk/uk-cosmetic-regulations-amendments
I would recommend formulators to examine their formulations for the ingredients below and implement reformulation and update the PIF (Product Information File), labelling and EU/UK portals accordingly.
Titanium Dioxide (CI 77891)
Used as a sunscreen and a colourant.
EU - Restricted certain particle sizes from October 21
UK - Particle size restrictions have not been implemented.
Azadirachta indica seed extract (neem seed extract)
Common and trending ingredient for cosmetic products.
EU - Banned from 1 December 2023 due to CMR status.
UK - Currently unrestricted, but expected to be implemented at a later date.
Pentasodium pentetate
Currently used in a lot of melt and pour soap bases.
EU - Banned from 1 December 2023 due to CMR status.
UK - Currently unrestricted, but expected to be implemented at a later date.
Butylphenyl methylpropional (lilial)
Commonly used fragrance ingredient and a declarable fragrance allergen.
EU - Banned from 1st March 2022
UK - Banned from 15.12.2022
Salicylic acid
Used as an active ingredient and preservative in cosmetic products.
EU - Annex III – restricted at 3% in rinse-off hair products; 2% in other products except body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant; 0.5% in body lotion, eye shadow, mascara, eyeliner, lipstick, roll-on deodorant; not to be used in specific types of products and related labelling requirements). Applied from 17 June 2021.
UK - For the 0.5% restriction the placing on the market deadline is 15.12.2022, making available deadline is 15.03.23
DHA
Used in self tanning products.
EU - restricted to 10% in self tan and 6.25% in non oxidative hair dye from 22nd April 2022.
UK - Currently unrestricted.
Methyl-N-methylanthranilate
Commonly used fragrance ingredient.
EU - Leave-on products – at a maximum concentration of 0.1%,
Rinse-off products – at a maximum concentration of 0.2%.
Not to be used in sunscreen products and products marketed for exposure to natural or artificial UV light.
Applies November 21st, 2022 for making available on the market.
UK - Currently unrestricted.