The Cosmetic Products (Restriction of Chemical Substances) Regulations 2025
The Cosmetic Products (Restriction of Chemical Substances) Regulations 2025, effective September 30, 2025, amend Annex 3 of (EC) No 1223/2009 to restrict methyl salicylate in cosmetics.
The regulation sets varying maximum concentrations based on product type, ensuring safe levels according to Scientific Advisory Group advice. A transitional period until March 31, 2026, allows existing stock to be sold.
Arguments For
Protecting Consumer Health: The regulations aim to safeguard consumers from potential harm by limiting the concentration of methyl salicylate in various cosmetic products based on scientific evidence of its safety. This is supported by the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products and aligns with the EU's Regulation (EC) No 1223/2009.
Harmonizing with EU Regulations: The regulations bring UK legislation into line with EU standards for cosmetic safety, ensuring consistency across the market and facilitating trade. This is implemented through amending Annex 3 of Regulation (EC) No 1223/2009, providing a legal framework.
Risk-Based Approach: The regulations establish different permissible levels of methyl salicylate depending on the specific cosmetic product type, reflecting varied exposure and risk profiles. The varying concentration limits in the schedule are based on the scientific evidence and reflect the differing risk of use.
Gradual Implementation: A transitional period allows businesses to adjust to the new regulations without immediate disruption, mitigating potential economic impacts. The March 2026 deadline facilitates a smooth transition for businesses managing existing stock.
Arguments Against
Economic Burden on Businesses: The regulations may impose costs on businesses to reformulate products and manage outdated stock, particularly small and medium-sized enterprises (SMEs). This includes reformulating products and disposing of existing stock that does not meet the new standards, affecting profit margins.
Regulatory Complexity: The different concentration limits for varied cosmetic product types can create complexity for businesses, increasing compliance costs and potential for error. This is especially true given the numerous product categories identified within these regulations.
Potential for Overregulation: The restrictions, while scientifically informed, might be criticized as overly cautious or disproportionate, potentially affecting the availability or affordability of certain cosmetic products. The lack of significant predicted impact may be questioned, requiring more thorough future analysis.
Limited Impact Assessment: The absence of a full impact assessment may raise concerns about the thoroughness of the regulatory process and its potential unforeseen consequences. Further study may yield a broader understanding relevant to both the economic impacts on businesses and the public health effects on consumers.
- Citation, commencement and extent (1) These Regulations may be cited as the Cosmetic Products (Restriction of Chemical Substances) Regulations 2025. (2) These Regulations come into force on 30th September 2025. (3) These Regulations extend to England and Wales and Scotland.
This section provides the official title of the regulations, their effective date (September 30, 2025), and states that they apply to England, Wales, and Scotland.
- Amendment to Regulation (EC) No 1223/2009 In Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products, at the end of the table in Annex 3 (list of substances which cosmetic products must not contain except subject to the restrictions laid down), insert the entry set out in the Schedule to these Regulations.
This section details the amendment made to Annex 3 of the EU Regulation (EC) No 1223/2009.
It specifies the addition of a new entry, found in the Schedule, which restricts the use of methyl salicylate in cosmetic products.
- Transitional Provision Where a cosmetic product containing the substance set out in the Schedule is placed on the market on or before 30th September 2025, it may continue to be made available on the market until the end of 31st March 2026.
This section establishes a transition period.
Cosmetic products containing methyl salicylate that were placed on the market before September 30, 2025 can continue to be sold until March 31, 2026.
Schedule Amendment to Annex 3 [Table detailing permitted concentrations of methyl salicylate in various cosmetic products]
The Schedule provides a detailed table outlining the permitted concentrations of methyl salicylate in various cosmetic product categories (e.g., rinse-off, leave-on, lip products).
The table specifies different concentration limits according to the product type and intended user age.