Cosmetics Regulation 2026/909: What Will Change for Your Formulations Starting January 1, 2027
Have you already checked your formulations against the new limits? With Regulation (EU) 2026/909, the European Commission has amended the EU Cosmetics Regulation for twelve substances, and as of January 1, 2027, only products that meet the new requirements may be placed on the market. This article explains which substances are affected, what deadlines apply, and what steps manufacturers and distributors should take now.
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What does Regulation (EU) 2026/909 cover?
The Commission adopted the regulation on April 27, 2026, and it amends Regulation (EC) No. 1223/2009, i.e., the EU Cosmetics Regulation. The changes affect entries in Annexes II (prohibited substances), III (restricted substances), V (preservatives), and VI (UV filters). The text was published in the Official Journal on April 28, 2026, and according to SGS, it entered into force on May 18, 2026. However, most substances are subject to their own transition periods, which are listed below.
Which substances will be affected starting in 2027?
Benzyl salicylate and citral have the widest-reaching impact because both fragrances are found in perfumes, creams, deodorants, and many other products. In the future, maximum concentrations will apply to both, based on the product category. In addition, there are aluminum compounds with product-specific maximum limits, as well as a ban on triphenyl phosphate, which many people recognize from nail polish.
| Content | What’s Changing | Sample values from the appendix |
|---|---|---|
| Benzyl Salicylate (Appendix III, No. 75) | Maximum concentrations per product category | 0.5% in other skin and hair care products (excluding sprays), 0.7% in body lotion, 0.2% in facial makeup, 4% in fragrances |
| Citral (Annex III, No. 70) | Maximum concentrations per product category; labeling required at 0.001% (leave-on products) or 0.01% (rinse-off products) | 0.15% in other leave-on skin care products, 0.6% in fragrances, 0.032% in deodorants |
| Aluminum compounds (Annex III, new, No. 379) | Product-specific maximum levels, calculated as aluminum | 7.73% in non-aerosol deodorants, 3.24% in aerosol deodorants, 3.18% in toothpaste |
| Triphenyl phosphate (Annex II) | Prohibited | No limit value; the substance must not be present |
| Water-soluble zinc salts (Annex III, No. 24) | Adjusted maximum levels, calculated as zinc | 1% in toothpaste for users over one year of age, 0.1% in mouthwashes |
| Acetylated vetiver oil (Annex III, new, No. 380) | Maximum levels per category; raw material stabilized with 1% alpha-tocopherol | 0.9% in fragrances, 0.05% in deodorants and makeup |
| DHHB (Annex VI, No. 28) | UV filter remains permitted; impurity limited | No more than 10%; di-n-hexyl phthalate no more than 10 ppm |
Overview of Annex III of the Cosmetics Regulation: Nine of the twelve substances are listed in Annex III, the list of restricted substances, namely zinc salts, citral, benzyl salicylate, aluminum compounds, acetylated vetiver oil, and four hair dyes. Triphenyl phosphate is listed in Annex II (Prohibited Substances), silver-zinc zeolite in Annexes II and V, and DHHB in Annex VI (UV Filters).
When it comes to citral, it’s worth taking a closer look at the raw materials, as the substance occurs naturally in essential oils such as lemongrass. According to MDSS Cosmetics, citral from natural sources is therefore also included in the total content, meaning that even formulations without added fragrance may be affected. In addition, four hair colorants are being added to Annex III, and silver-zinc zeolite is being moved from the list of prohibited substances to the list of permitted preservatives. According to the SGS and the recitals, the regulation does not provide for a transition period for these two groups; they are therefore already in effect.
A note about the search: Triphenyl phosphate is not the same as TPO, the photoinitiator found in gel polishes that often comes up in reports about nail products.
What are the deadlines?
| Effective Date | What Applies |
|---|---|
| January 1, 2027 | Products containing triphenyl phosphate, citral, benzyl salicylate, aluminum compounds, zinc salts, acetylated vetiver oil, or DHHB may only be placed on the market if they comply with the new requirements |
| July 1, 2028 | Non-compliant products may also no longer be made available on the market |
| August 1, 2028 | This later date applies to the citral isomers (E)- and (Z)-3,7-dimethylocta-2,6-dienal, i.e., geranial and neral |
“Placing on the market” refers to the initial making available of a product on the EU market, whereas “making available” refers to any subsequent transfer within the supply chain up to the end consumers. Products that were already placed on the market before January 1, 2027, may therefore continue to be sold until mid-2028. New batches, however, must comply with the new limits starting at the beginning of the year.
The timeframe through 2028 seems generous, but in practice it is tighter than it appears, because the deadline for placing the product on the market begins in just over two months. By then, a modified formulation must be developed, safety-assessed, and approved with an updated label—and each of these steps requires lead time.
What does this mean for the formulation, CPSR, and label?
The first step is classification: For each product, it must be determined which category it falls into, because the permissible level depends on that. For example, a body lotion may contain more benzyl salicylate than any other skin care product, and when it comes to aluminum, the limits differ significantly between deodorants, toothpaste, and makeup. If a formulation exceeds the limit, it must be reformulated, which typically requires a new Cosmetic Product Safety Report (CPSR). This report is part of the Product Information File (PIF) maintained by the responsible person. We explain the difference between the CPSR and the PIF on our page on Compliance for Cosmetic Products.
The label is also worth a look. Citral and benzyl salicylate must be listed in the ingredients list if their concentrations exceed the specified thresholds, and for aluminum, the appendix requires warning labels—for example, on talcum powder, which should be kept away from children’s noses and mouths. Retailers carrying multiple variants of a product should also clarify which ones differ in their ingredient composition, as each must then be evaluated individually.
Conclusion
Here’s how BAYOOCARE can help you
BAYOOCARE reviews your product portfolio against the revised annexes, assesses where formulations need to be adjusted, and updates your documentation—including the CPSR—to ensure your cosmetic products remain compliant even after the deadlines have passed. Please feel free to contact us; we’ll work with you to create a schedule that fits your batches and approvals.
