What is the EU Cosmetics Regulation?

The main EU law for cosmetic products is Regulation (EC) No 1223/2009. It applies to cosmetic products placed on the EU market, including skincare, shampoo, soap, deodorant, toothpaste, perfume, makeup, hair products, nail products and many other personal care items.

The European Commission explains that EU cosmetics rules are designed to protect consumer safety and ensure the functioning of the internal market for cosmetic products. Cosmetic products must be safe, correctly labelled, supported by technical documentation and notified through the Cosmetic Products Notification Portal, known as CPNP, before they are placed on the EU market.

For companies, this means EU cosmetic compliance is not only about checking the final label. It also requires control over formulas, ingredients, safety assessments, supplier data, Product Information Files, claims, CPNP notifications, artwork and post-market responsibilities.

What are the latest EU Cosmetics Regulation updates?

The latest EU cosmetics updates affect several areas:

These updates are especially important because several deadlines are close together. Companies with large cosmetic portfolios should review formulas, labels, supplier documentation and marketability status as early as possible.

Key EU Cosmetics Regulation deadlines for cosmetic companies

The European Commission confirms the microplastics transition periods for rinse-off cosmetics, leave-on cosmetics, and makeup, lip and nail cosmetics, including the label indication requirement from 17 October 2031 to 16 October 2035 for certain makeup, lip and nail products.

What is Regulation (EU) 2026/909 and why is it important?

Commission Regulation (EU) 2026/909 is one of the newest and most important cosmetic ingredient updates for 2026. It was published in the Official Journal on 28 April 2026 and amends Regulation (EC) No 1223/2009 for the use of several cosmetic ingredients.

The regulation covers:

• Benzyl Salicylate
• Triphenyl Phosphate
• Ammonium Silver Zinc Aluminium Silicate
• Aluminium
• water-soluble zinc salts
• Acetylated Vetiver Oil
• Citral
• HC Blue No 18
• HC Red No 18
• HC Yellow No 16
• Hydroxypropyl-p-phenylenediamine and its dihydrochloride salt
• DHHB

This update matters because it affects several common product categories, including fragrances, deodorants, oral care, sunscreens, hair dyes, makeup, nail products and leave-on or rinse-off cosmetics.

For many affected products, non-compliant products may no longer be placed on the EU market from 1 January 2027 and may no longer be made available from 1 July 2028. Some Citral-related cases have a later making-available date of 1 August 2028, so companies should check the exact entry and transition provision for each affected substance.

Which products may be affected by Regulation (EU) 2026/909?

Regulation (EU) 2026/909 may affect many cosmetic product types.

This is why brands should not only ask, “Is this ingredient allowed?” They should also ask:

“Is this ingredient allowed in this product type, at this concentration, with this warning, after this deadline?”

What changed for CMR substances in cosmetics?

CMR substances are substances classified as carcinogenic, mutagenic or toxic to reproduction. Under the EU Cosmetics Regulation, substances classified as CMR category 1A, 1B or 2 are generally prohibited in cosmetic products unless specific exemption conditions are met.

The European Commission lists Omnibus VII as applying from 1 September 2025, Omnibus VIII as applying from 1 May 2026, and Omnibus IX as under preparation with an indicated application date of 1 February 2027.

This matters because CMR updates can immediately affect whether a cosmetic product can remain on the EU market. Companies should screen formulas against the latest Annex II and Annex III changes and identify products that may need reformulation, relabelling, stock blocking or withdrawal.

What is Omnibus VIII in cosmetics?

Omnibus VIII, formally Commission Regulation (EU) 2026/78, is another major 2026 cosmetics update. It applies from 1 May 2026 and is linked to CMR substance classifications. The European Commission’s CMR page lists Regulation (EU) 2026/78 as the eighth cosmetics Omnibus act, with an application date of 1 May 2026.

Omnibus VIII matters because products containing affected substances must be reviewed before the application date. Companies should check formulas, raw material specifications, supplier declarations and stock status to determine whether products can continue to be sold in the EU.

Is TPO banned in EU cosmetic products?

Yes. Trimethylbenzoyl Diphenylphosphine Oxide, commonly known as TPO, is prohibited in cosmetic products from 1 September 2025.

This is especially important for UV-cured nail products. The European Commission confirms that from 1 September 2025, cosmetic products containing TPO cannot be placed on the market or made available on the market. It also clarifies that professional users, such as nail technicians and salons, cannot use TPO-containing products on clients from that date, even if the product was purchased before the deadline.

Companies selling nail products should check:

• whether TPO appears in any formulation
• whether affected products are still in stock
• whether distributors, salons or professional users still hold affected products
• whether replacement formulas are documented and assessed
• whether CPNP notifications and labels need updates after reformulation

What are the new EU fragrance allergen labelling requirements?

Fragrance allergen labelling is one of the biggest label updates for cosmetic companies.

Commission Regulation (EU) 2023/1545 amended the EU Cosmetics Regulation regarding the labelling of fragrance allergens in cosmetic products.

The key practical point is that fragrance allergens must be declared in the ingredient list when they exceed the relevant concentration thresholds:

For companies, this means fragrance data must be updated at formula level. A general fragrance name such as “parfum” is not enough where specific allergens exceed the applicable thresholds.

Companies should request updated allergen declarations from fragrance suppliers and check whether product labels must be revised before the relevant transition deadlines.

Do cosmetic labels need to be updated in 2026?

Many cosmetic labels may need updates in 2026.

The most important label-related updates include:

• expanded fragrance allergen declarations
• new or updated INCI names
• formaldehyde-releaser warning requirements
• nanomaterial labelling with “nano” where applicable
• restricted ingredient warnings under Annex III
• product-specific precautions and warnings
• revised concentration or warning conditions under Regulation (EU) 2026/909

This is why companies should not update labels one rule at a time. A better approach is to run a full label compliance review across formulas, supplier data, INCI names, warnings, restrictions and artwork versions.

What is changing with the INCI glossary in 2026?

The EU updated the glossary of common ingredient names used for cosmetic labelling through Commission Implementing Decision (EU) 2025/1175.

The updated glossary applies from 30 July 2026. The EUR-Lex record confirms that the decision lays down rules for the glossary of common ingredient names for use in cosmetic product labelling and repeals the previous Decision (EU) 2022/677.

This matters because cosmetic labels must use common ingredient names. Companies should review ingredient lists, artwork and internal formula systems to ensure label names are aligned with the updated glossary.

Important note: the INCI glossary is not a list of authorised cosmetic ingredients. A substance may have an INCI name but still be prohibited, restricted or unsuitable for a specific cosmetic use.

What are the formaldehyde-releaser labelling requirements?

Formaldehyde itself is prohibited in cosmetic products, but some preservatives gradually release formaldehyde in the finished product.

Commission Regulation (EU) 2022/1181 amended the preamble of Annex V to Regulation (EC) No 1223/2009 for formaldehyde-releasing preservatives. The regulation concerns the warning requirement for products releasing formaldehyde.

The key 2026 issue is stock and label compliance. Businesses had a sell-through period for existing stock, with the relevant deadline ending on 31 July 2026 according to regulatory reporting on the implementation period.

Companies should check:

• whether preservatives in the formula release formaldehyde
• the formaldehyde release level in the finished product
• whether the label includes the required warning
• whether older stock remains in distribution
• whether the Product Information File reflects the current formula and label

What are the EU rules for nanomaterials in cosmetics?

Nanomaterials are subject to specific controls under the EU Cosmetics Regulation. The CPNP includes a separate Article 16 module for cosmetic products containing nanomaterials, in addition to the standard Article 13 notification. If the Commission has concerns about the safety of a nanomaterial, it may request a Scientific Committee on Consumer Safety risk assessment.

Cosmetic companies should verify:

• whether any ingredient is present in nano form
• whether the nanomaterial is permitted for the intended cosmetic use
• whether Article 16 notification is required
• whether the label correctly identifies the nanomaterial
• whether supplier data supports the nano status and safety assessment

How do microplastics restrictions affect cosmetics?

The EU microplastics restriction under REACH affects intentionally added synthetic polymer microparticles in several product categories, including cosmetics.

For cosmetics, the transition periods differ by product type:

The European Commission also states that makeup, lip and nail products containing microplastics need to bear a label indication from 17 October 2031 until 16 October 2035 to continue being sold.

Brands should identify whether any formulas contain intentionally added synthetic polymer microparticles and plan reformulation, supplier changes or labelling actions before the relevant deadline.

What changed for Vitamin A, arbutin and kojic acid in cosmetics?

Commission Regulation (EU) 2024/996 amended the EU Cosmetics Regulation regarding the use of Vitamin A, Alpha-Arbutin, Arbutin and certain substances with potential endocrine-disrupting properties in cosmetic products.

This update is important for skincare, anti-ageing, brightening and hyperpigmentation products. Companies using Retinol, Retinyl Acetate, Retinyl Palmitate, Alpha-Arbutin, Arbutin, Kojic Acid or related substances should check applicable concentration limits, transition dates, product categories, label implications and safety documentation.

What must companies do to comply with the EU Cosmetics Regulation?

To comply with the EU Cosmetics Regulation, companies should manage compliance across the full product lifecycle.

EU Cosmetics Regulation compliance checklist

1. Assign the Responsible Person

Every cosmetic product placed on the EU market must have a Responsible Person established in the EU. The Responsible Person is responsible for ensuring that the product meets the requirements of Regulation (EC) No 1223/2009.

2. Screen formulas against ingredient restrictions

Check each ingredient against:

• Annex II prohibited substances
• Annex III restricted substances
• Annex IV permitted colourants
• Annex V permitted preservatives
• Annex VI permitted UV filters
• CMR-related amendments
• Regulation (EU) 2026/909
• nanomaterial requirements
• fragrance allergen rules
• microplastics restrictions

3. Perform a cosmetic product safety assessment

Before placing a cosmetic product on the EU market, the product must undergo a safety assessment by a qualified safety assessor and have a Cosmetic Product Safety Report.

4. Build and maintain the Product Information File

The Product Information File should include the product description, Cosmetic Product Safety Report, manufacturing method, GMP statement, proof of claimed effects and relevant animal testing data where applicable.

5. Verify cosmetic labelling

Labels should be checked for:

• Responsible Person name and address
• nominal content
• date of minimum durability or period after opening
• precautions and warnings
• batch number
• product function, unless obvious
• ingredient list
• fragrance allergens
• nanomaterial indication
• formaldehyde-releaser warning where required
• country language requirements
• Regulation (EU) 2026/909 warnings or conditions where applicable

6. Notify the product through CPNP

Every cosmetic product must be notified to the CPNP before being placed on the EU market. HPRA describes the CPNP as a free online notification system created for the implementation of Regulation (EC) No 1223/2009.

7. Control claims

Marketing claims must be truthful, supported by evidence and aligned with EU cosmetic claims criteria.

8. Monitor post-market obligations

Companies should be ready to handle complaints, undesirable effects, serious undesirable effects, market surveillance requests, recalls and corrective actions.

9. Keep supplier documentation updated

Supplier documents should be controlled and reviewed when formulas, raw materials, fragrance compositions, preservatives or regulatory requirements change.

10. Monitor regulatory updates continuously

EU cosmetic compliance is not static. Companies should track Omnibus updates, SCCS opinions, Annex changes, REACH restrictions, labelling changes and national enforcement expectations.

Why is EU cosmetics compliance difficult to manage manually?

Manual compliance management is risky because cosmetic compliance data is spread across many functions.

A single cosmetic product may involve:

• formula data
• raw material specifications
• supplier declarations
• fragrance allergen statements
• toxicological data
• safety assessment inputs
• Product Information File documents
• CPNP notification data
• label artwork
• claims evidence
• country-specific language rules
• marketability decisions
• stock and distribution controls

When this information is managed through spreadsheets, emails and disconnected folders, companies may struggle to answer urgent questions such as:

Which products contain Benzyl Salicylate, Triphenyl Phosphate, Citral or DHHB?
Which labels must be updated before 31 July 2026?
Which products are affected by Regulation (EU) 2026/909?
Which supplier documents are missing?
Which products can still be sold in the EU after 1 January 2027?
Which products should be blocked from sale?

This is where product compliance software can create value.

How can ComplyMarket help with EU Cosmetics Regulation compliance?

ComplyMarket product compliance software helps companies manage product compliance in a structured, traceable and scalable way.

ComplyMarket describes its Product Compliance Management Software as a centralized platform for manufacturers, importers and product managers to manage regulatory obligations. The platform supports regulatory libraries, product-specific requirement assignment, evidence tracking, marketability checks, collaboration with teams and suppliers, and structured compliance management.

For cosmetics companies, this can support EU Cosmetics Regulation compliance in several practical ways.

1. Identify which cosmetic regulations apply to each product

ComplyMarket can help companies organize applicable legislation, standards and requirements in a structured regulatory library.

For cosmetics, this may include:

• Regulation (EC) No 1223/2009
• Annex II–VI ingredient restrictions
• Regulation (EU) 2026/909
• Omnibus VIII and future Omnibus updates
• fragrance allergen labelling requirements
• INCI glossary changes
• microplastics restrictions
• formaldehyde-releaser warning rules
• nanomaterial requirements
• claims and documentation obligations

Instead of managing requirements in scattered spreadsheets, teams can connect regulatory obligations to the relevant product, formula, material or substance.

2. Track compliance evidence and missing documents

ComplyMarket enables companies to manage compliance evidence and documentation in one platform. Its product compliance software page highlights evidence tracking, regulatory management, marketability checks and collaboration features.

For cosmetics, this can help manage:

• supplier declarations
• fragrance allergen data
• formula documents
• safety assessment inputs
• Cosmetic Product Safety Reports
• Product Information File documents
• label reviews
• claims substantiation
• CPNP-related records
• GMP evidence
• corrective action records

This makes it easier to prove compliance during customer requests, internal audits or authority checks.

3. Detect affected products when regulations change

When a new EU cosmetics update is published, companies need to know which products are affected.

For example, after Regulation (EU) 2026/909, a company may need to identify all products containing Benzyl Salicylate, Citral, Triphenyl Phosphate, aluminium-containing ingredients, water-soluble zinc salts, hair dye substances or DHHB.

ComplyMarket’s platform brings together product data, supplier input, legislation, evidence, warnings, compliance status and marketability in one environment, helping companies manage lifecycle-related requirements across products, components, materials and substances.

4. Improve supplier collaboration

Cosmetic compliance depends heavily on supplier data. A company may need updated information from fragrance houses, raw material suppliers, contract manufacturers, packaging suppliers and testing partners.

ComplyMarket includes collaboration features that allow teams to assign tasks, request documentation and communicate with suppliers or internal teams within the platform.

This helps reduce email chasing and improves traceability when supplier documents change.

5. Monitor marketability by country or region

ComplyMarket allows users to enter countries where products are sold and assess whether the product is marketable in each region.

For cosmetic companies selling across the EU and other markets, this is important because marketability depends on more than formula compliance. It may also depend on language requirements, labels, documentation, local expectations and product-specific restrictions.

6. Support scalable compliance for large cosmetic portfolios

The larger the product portfolio, the harder it becomes to manage compliance manually.

ComplyMarket can help companies centralize:

• product data
• formula-related information
• supplier documents
• regulatory obligations
• evidence status
• warnings
• marketability checks
• internal tasks
• audit trails

This can help cosmetic companies move from reactive compliance to proactive compliance management.

EU Cosmetics Regulation FAQ

What is the EU Cosmetics Regulation?

The EU Cosmetics Regulation is Regulation (EC) No 1223/2009. It sets safety, labelling, documentation, notification and market access requirements for cosmetic products placed on the EU market.

What are the latest EU Cosmetics Regulation updates?

The latest updates include Regulation (EU) 2026/909, Omnibus VIII, the TPO ban, fragrance allergen labelling updates, INCI glossary changes, formaldehyde-releaser warning requirements, nanomaterial controls and microplastics transition periods.

What is Regulation (EU) 2026/909?

Regulation (EU) 2026/909 is a 2026 amendment to the EU Cosmetics Regulation covering several cosmetic ingredients, including Benzyl Salicylate, Triphenyl Phosphate, Citral, aluminium, water-soluble zinc salts, certain hair dyes and DHHB.

What is Omnibus VIII in cosmetics?

Omnibus VIII is a CMR-related amendment to the EU Cosmetics Regulation. The European Commission lists Regulation (EU) 2026/78 as applying from 1 May 2026.

Is TPO banned in EU cosmetics?

Yes. TPO is prohibited in cosmetic products from 1 September 2025. The Commission confirms that sale, supply and professional use must stop from that date.

Do cosmetic labels need to be updated in 2026?

Many cosmetic labels may need updates because of expanded fragrance allergen labelling, updated INCI ingredient names, formaldehyde-releaser warnings and ingredient-specific restrictions or warnings.

What is the deadline for EU fragrance allergen labelling?

The updated fragrance allergen labelling rules are based on Regulation (EU) 2023/1545. Companies should review product labels and supplier fragrance declarations before the 2026 transition deadline for placing new products on the market.

What is CPNP notification?

CPNP stands for Cosmetic Products Notification Portal. Cosmetic products must be notified through CPNP before being placed on the EU market.

What is a Product Information File?

A Product Information File, or PIF, is the technical documentation that supports cosmetic product compliance. It includes the product description, Cosmetic Product Safety Report, manufacturing method, GMP statement, proof of claims and other required information.

How can software help with EU cosmetics compliance?

Compliance software helps companies centralize regulatory requirements, connect them to products and ingredients, manage supplier evidence, track missing documents, monitor regulatory changes, control marketability and reduce the risk of selling non-compliant products.

Can ComplyMarket help with EU Cosmetics Regulation compliance?

Yes. ComplyMarket can help companies manage product compliance requirements, evidence, supplier documentation, warnings, marketability and regulatory changes in one structured platform.