In a significant regulatory development, the United Kingdom has notified the World Trade Organization (WTO) of a draft amendment to the GB Cosmetics Regulation. This amendment, dated 3 October 2024, adds 13 more chemicals to the list of banned substances in cosmetic products, all classified as carcinogenic, mutagenic, or reprotoxic (CMR). The UK’s decision marks a clear divergence from the European Union’s approach, with some chemicals now being restricted exclusively in the UK.
A Growing List of Banned Substances
The UK first introduced a wave of CMR bans in April 2024, prohibiting 52 hazardous chemicals in cosmetic products. With this latest amendment, the number of restricted substances has increased further, emphasising the UK’s commitment to consumer safety. These newly banned chemicals include:
Thiophanate-methyl – CAS: 23564-05-8
Mancozeb – CAS: 8018-01-7
Carbendazim – CAS: 10605-21-7
Trinickel disulfide – CAS: 12035-72-2
4-vinylcyclohexene diepoxide – CAS: 106-87-6
1,2,4-triazole – CAS: 288-88-0
Flumioxazin – CAS: 103361-09-7
Tellurium – CAS: 13494-80-9
Daminozide – CAS: 1596-84-5
Dimoxystrobin – CAS: 149961-52-4
2-(2-methoxyethoxy) ethanol – CAS: 111-77-3
Divanadium pentaoxide – CAS: 1314-62-1
Salts of 2-ethylhexanoic acid
These substances are exclusively banned in the UK but remain permitted in the European Union. Conversely, the EU maintains its own list of chemicals restricted from cosmetics, some of which are not prohibited in the UK, such as Azamethiphos, Clothianidin, and 4-methylimidazole.
Implications for Cosmetics Brands
Cosmetic manufacturers looking to market their products in the UK and EU markets now face the growing challenge of complying with two distinct regulatory regimes. Brands must be aware of the specific substances banned in each market and adjust their formulations accordingly to avoid penalties and ensure consumer safety.
In addition to expanding the list of banned CMR substances, the UK has revised the deadlines for compliance with the new regulations:
20 April 2025 – Final date for placing products containing newly banned substances (such as the 13 recently added CMR substances) on the UK market.
20 October 2025 – Final date for making such products available for sale.
In a similar way to Europe, the UK is restricting the use of Kojic Acid (a famous skin-lightening agent) to a maximum concentration of up to 1% in “face and hand products”.
The deadlines for compliance in the UK are:
20 June 2025 for new products, i.e., the first to make available a product containing Kojic Acid (up to 1% concentration) on the British market.
1 November 2025 for products already on the market, which must adhere to the new restriction.
The deadlines for compliance in Europe are:
· 2 February 2025 for new products, and
· 1 November 2025 for products already on the market.
UK’s Independent Regulatory Path
This regulatory update underscores the UK’s determination to maintain a higher safety standard for cosmetic products post-Brexit. While the EU also restricts the use of certain CMR substances, the UK's proactive approach to banning additional chemicals not yet prohibited in the EU demonstrates a clear regulatory divergence.
Businesses operating in both regions must diligently stay abreast of these changes. Beauty brands, in particular, need to adapt their product lines to align with the regulatory frameworks in each jurisdiction, ensuring that their products remain compliant and available to consumers.
As these deadlines approach, companies are encouraged to seek regulatory advice and make necessary product adjustments to avoid disruptions to their market operations.
How Crème de la Crème Can Assist Health and Beauty Manufacturers with Regulatory Compliance
As UK regulations on banned substances in cosmetics evolve, including the recent amendment adding 13 new chemicals to the list of banned substances, Crème de la Crème (www.creme.uk.com) can play a pivotal role in helping health and beauty manufacturers stay compliant and competitive.
Here’s how Crème de la Crème can provide support:
1. Regulatory Consultancy and Guidance
With their expertise in cosmetics compliance, Crème de la Crème can guide manufacturers through the complexities of UK and EU regulations. By offering clear advice on the specific substances now banned in the UK, such as Thiophanate-methyl and Mancozeb, they help manufacturers navigate the differences between the two regions’ regulatory frameworks.
2. Ingredient Formulation Adjustments
Crème de la Crème can assist manufacturers in reformulating their products to ensure they exclude newly banned CMR substances. This includes recommending safe alternatives that are compliant with both UK and EU markets and ensuring that brands maintain their product performance without compromising safety or legality.
3. Timeline Management
With the newly imposed deadlines—such as the 20 April 2025 deadline for placing products with banned substances on the UK market—Crème de la Crème can assist in managing the compliance timeline. They can help manufacturers restructure production and marketing strategies to ensure their products meet the UK deadlines while also remaining compliant in the EU.
4. Cosmetic Safety and Labelling
In addition to regulatory advice, Crème de la Crème can review product labels and marketing claims to ensure they align with the UK and EU’s mandatory classification and labelling regulations. This includes ensuring proper ingredient disclosure and hazard warnings, if applicable, are displayed as per the new guidelines.
5. Continuous Monitoring and Updates
Crème de la Crème provides ongoing support, keeping their clients informed about future regulation updates. This allows manufacturers to be proactive and maintain compliance as regulatory changes continue to unfold, ensuring minimal to no disruptions in their supply chain or market access.
By partnering with Crème de la Crème, health and beauty manufacturers can focus on product innovation and development while ensuring full compliance with both UK and EU regulatory landscapes.
For more information on how we can assist your business, visit our website and contact our team of experts. Let's work together to create a safer, more sustainable future for cosmetics.
Reach out to us by sending an email to creme@creme.uk.com or submitting a web form via https://www.creme.uk.com/contact-us