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- Regulatory Compliance Analyst at Euverify, specialising in EU and UK product compliance, risk assessments, and technical file audits. Experienced in interpreting directives and standards, conducting conformity assessments, and maintaining detailed compliance documentation. Dedicated to ensuring products meet regulatory requirements with accuracy and consistency across markets.
- January 9, 2026Regulatory FrameworkHow to Register Products in EPREL: Step-by-Step Guide for EU Energy Labelling
- December 5, 2025Industry InsightsPFAS in Cosmetics: What the EU PFAS Ban Means for Beauty Brands
- November 14, 2025Industry InsightsCosmetic Claims Compliance: How to Market Products Without Violating EU and UK Regulations
- October 29, 2025Industry InsightsUpcoming Cosmetic Ingredient Bans in the EU: What Brands Must Reformulate (and When)
UK Cosmetic Regulations: Newly Banned & Restricted Ingredients Explained
The UK cosmetics market is in the middle of a major compliance shake-up. Since January 2025, new rules have banned dozens of ingredients and tightened the limits on others. These changes aren’t happening all at once. There are phased sell-through deadlines running into late 2025 and early 2026. That means many brands are still reformulating products, updating labels, and revising documentation.
If you make, import, distribute, or sell cosmetics in Great Britain, it’s vital to know what has changed, when each deadline applies, and what steps you need to take. Missing these requirements could lead to enforcement action and costly recalls.
This article walks you through the UK framework after Brexit, highlights the latest bans and restrictions (including CMR substances, kojic acid, BHT, and methyl salicylate), sets out the key transition dates, and gives you a step-by-step compliance checklist you can use right away.
The UK Cosmetics Framework at a Glance
Since Brexit, the UK has kept the core of the EU Cosmetics Regulation (EC) 1223/2009 but now runs its own system for Great Britain (England, Scotland, and Wales). In simple terms, any cosmetic sold in Great Britain needs a UK-based “Responsible Person” (RP) to take legal responsibility for the product. It also has to be registered with the Office for Product Safety and Standards (OPSS) through their online Submit Cosmetic Product Notifications (SCPN) service. Northern Ireland, however, is different. It still follows the EU rules.
Two points many brands overlook:
- Responsible Person & product notification: These are UK-specific requirements. You can’t rely on EU CPNP notifications for the Great Britain market. You must complete them separately in the UK.
- Transitional labelling: The rules around how the UK Responsible Person’s address appears on labels have been extended several times. According to OPSS and industry updates, the current deadline runs until 31 December 2025. Make sure your labels and RP details match the latest requirements.
In addition, the UK updates its ingredient lists through Statutory Instruments (SIs). The most significant recent update is SI 2024/1334, which took effect on 31 January 2025. It bans 64 new CMR substances (Annex II) and restricts kojic acid (Annex III). Earlier in 2024, the UK also restricted BHT (Butylated Hydroxytoluene), and in 2025, it introduced new restrictions for methyl salicylate. We’ll break down each change below, along with the exact sell-through deadlines you need to track.
Newly Banned Cosmetic Ingredients: Expansion of CMR Prohibitions
What changed:
The Cosmetic Products (Restriction of Chemical Substances) (No. 2) Regulations 2024 (SI 2024/1334) updated Annex II of the GB Cosmetics Regulation to ban 64 additional substances classified as CMR (carcinogenic, mutagenic, or reprotoxic). This change took effect on 31 January 2025.
Key transition periods (from the statutory instrument):
- Substances with reference numbers 1680–1730 (Schedule 1 of SI 2024/1334):
Products placed on the market by 20 April 2025 can continue to be sold until 20 October 2025. - Substances with reference numbers 1731–1743:
Products placed on the market by 2 September 2025 can continue to be sold until 2 March 2026.
These periods only allow sell-through of stock already on the market before the cutoff dates. Therefore, manufacturing or placing new products on the market after these dates is not allowed. Brands need to review inventory and supply chains to ensure compliance.
Industry summaries (e.g., Obelis, ChemLinked) follow the same timelines and the 64-CMR expansion, but the statutory instrument (SI) is the official source.
What this means in practice:
- If your products contain the newly banned CMRs, you must have stopped placing them on the market by the cutoff date and finished selling existing stock by the end date.
- Reformulation is required if you want to keep selling a product that included a now-banned ingredient.
- Make sure your Product Information File (PIF) is up to date with reformulation details, safety assessments, and updated label proofs.
(a) Kojic acid: capped at 1% for face/hand products
What changed:
SI 2024/1334 adds kojic acid to Annex III, capping it at 1% for face and hand products after a UK scientific risk review. The change aims to reduce health risks while allowing safe use at lower levels. The SI text and explanatory notes include the change and transition dates.
Key dates:
- Placement cutoff: 20 June 2025 – products exceeding 1% should not be newly placed after this date.
- Sell-through end: 1 November 2025 – existing stock placed before the cutoff can continue to be sold.
These dates are commonly reported in regulatory briefings, but the SI is the official legal source.
Action points:
- Review all brightening or hyperpigmentation products (serums, creams, soaps) for kojic acid content.
- Reformulate and reassess efficacy if your product exceeds the 1% limit.
- Update labels, Product Information File (PIF), and notifications (SCPN) as needed.
Commercial note:
Kojic acid is a high-interest ingredient for consumers. If reformulation is required, consider alternative actives and communicate changes clearly to avoid confusion while maintaining efficacy claims. Media coverage highlights the market attention around this trend.
(b) BHT (Butylated Hydroxytoluene): restricted, not banned
What changed:
In April 2024, the Cosmetic Products (Restriction of Chemical Substances) Regulations 2024 (SI 2024/455) added BHT to Annex III (restricted substances). The aim is to align safe use with scientific advice by limiting categories and concentrations.
Transition dates:
Industry sources point to a placement cutoff around 24 February 2025 and a sell-through end on 24 June 2025. Since the permitted categories and limits can be complex, always check your product type and maximum concentration against the official SI text rather than relying only on summaries.
Action points:
- Review SKUs that use BHT as an antioxidant (often in lipsticks, creams, sunscreens).
- Confirm permitted product categories and concentration limits in Annex III.
- Reformulate if needed and update your PIF with revised safety assessments.
(c) Methyl salicylate: new specific restrictions
What changed:
In 2025, the UK introduced restrictions on methyl salicylate based on product type and intended use. SI 2025/413 (Cosmetic Products (Restriction of Chemical Substances) Regulations 2025) sets out the rationale and transitional rules.
Transition dates (per SI 2025/413):
- Products placed on the market before 30 September 2025 can continue to be sold until 31 March 2026.
What brands need to do:
- Check methyl salicylate levels in products (commonly fragranced or warming products).
- Make sure they meet the new category limits.
- Update documentation and labels to reflect compliance.
UK Cosmetic Compliance Deadlines: Transition, Enforcement & Key Dates
It’s important to distinguish between “placed on the market” and “made available”:
- Placed on the market = the first time a product is supplied in Great Britain (to a distributor or end-user) — i.e., entering the supply chain.
- Made available = any later supply of that product, such as selling through existing stock.
Under SI 2024/1334, different groups of banned CMRs have different grace periods (until 20 Oct 2025 or 2 Mar 2026) as long as products were placed before the cutoff. New placement after the cutoff is not allowed.
Enforcement and oversight:
OPSS, together with Trading Standards, can request PIFs, carry out market checks, and enforce stop-sale, withdrawal, or recalls for non-compliance. Brands must be able to prove traceability, timely reformulation, and accurate labeling.
Your Responsible Person (RP) and notification duties remain key. The RP is the regulator’s first point of contact.
UK vs EU Cosmetics Rules: Key Differences to Watch
The UK is still broadly aligned with the EU on ingredient rules (e.g., restricting kojic acid and adding CMRs), but timelines can differ. Great Britain now issues its own SIs and runs its own scientific reviews. The UK tends to move quickly with a safety-first approach (shaped by post-Brexit and post-Grenfell enforcement), while the EU often pairs safety with sustainability goals (like wider cosmetic labelling rules, microplastics, and the ESPR framework).
For brands selling in both markets:
- Track GB SIs and EU amendments separately.
- Watch for subtle differences in deadlines and scope.
- Keep two compliance calendars (GB and EU) and plan to meet the earliest applicable date to avoid risk.
How to Meet UK Cosmetics Regulations
Use this checklist to handle the latest UK changes with as little disruption as possible:
A) Audit your formulas against updated GB ingredient lists
- Review all SKUs against Annex II (prohibited) and Annex III (restricted), as updated by SI 2024/1334, SI 2024/455, and SI 2025/413 (methyl salicylate).
- Flag any products containing newly banned CMRs and plan reformulation or withdrawal once placement deadlines pass.
- For kojic acid, check that levels are ≤1% in face and hand products, or consider re-categorising if relevant.
- For BHT and methyl salicylate, confirm category-specific limits and update batch records accordingly.
B) Build a transition calendar and align with suppliers
- CMRs (refs 1680–1730, 1731–1743): Follow placement and sell-through cutoffs exactly.
- Kojic acid: Placement cutoff 20 June 2025, sell-through ends 1 November 2025.
- BHT: Check category-specific limits and stop placement of non-compliant SKUs by the deadline.
- Methyl salicylate: Placement cutoff 30 September 2025, sell-through ends 31 March 2026.
Share this calendar with procurement, QA/RA, distributors, and retailers so no one accidentally places non-compliant products.
C) Update the Product Information File (PIF) and safety assessments
- For any reformulation, update the Cosmetic Product Safety Report (CPSR) as well as stability and compatibility data.
- Keep version control so you can show how the formula and compliance records have evolved if OPSS or Trading Standards request it.
D) Refresh labels and digital listings
- Make sure claims still hold after reformulation (e.g., brightening or antioxidant claims if kojic acid or BHT levels change).
- Update ingredient lists to reflect new formulas, and avoid reusing old printed labels that could put outdated products back into circulation.
- If you’re using transitional RP labelling allowances, remember these end on 31 December 2025 and plan your final label updates in time.
E) Update GB notifications (SCPN)
- If the product formula changes significantly, update the SCPN so first responders (e.g., National Poisons Information Service) have the correct formulation details.
F) Train internal teams and retailers
- Inform marketing, e-commerce, and retail teams to ensure non-compliant SKUs aren’t sold past their deadlines.
Confirm procedures for returns and withdrawing any stock found to be out of compliance.
Common UK Cosmetics Regulation Errors (and How to Avoid Them)
1: Assuming EU compliance equals GB compliance
Post-Brexit, GB has its own SIs and deadlines. Always check GB requirements separately, even if they seem similar to EU rules
2: Misunderstanding “placed on the market” vs “made available”
Missing the placement cutoff means non-compliant stock cannot legally enter the GB market, even if earlier batches are still selling. Make sure supply chain partners understand the difference.
3: Not updating PIF and labels after reformulation
Any formula change can trigger CPSR, INCI, claims, and notification obligations. Keep strong change-control processes in place.
4: Missing methyl salicylate timelines
The 2025 update is easy to overlook. Note the 30 Sept 2025 placement and 31 Mar 2026 sell-through deadlines if applicable.
What’s Next for UK vs EU Cosmetics: Labels and Sustainability
While this guide focuses on ingredient bans and restrictions, two broader trends are shaping the regulatory landscape:
Labelling and RP presentation: GB has allowed extended transitional labelling, but this ends on 31 December 2025. Plan your final UK label layouts with RP details well ahead of time.
Sustainability and eco-design: The EU is advancing wider sustainability initiatives (e.g., ESPR, Digital Product Passports) that will affect cosmetics packaging and disclosure standards. GB isn’t required to follow the EU timeline, but brands selling in both markets should prepare for different expectations and consider these in packaging decisions. (For ingredient restrictions, continue to monitor GB SIs.)
UK Cosmetics Compliance: Real-World Examples
Scenario A: Brightening serum with 2% kojic acid
Issue: Concentration exceeds GB’s new 1% limit for face and hand products.
Action: Reformulate to ≤1%, review efficacy claims, update labels and PIF, and stop placing non-compliant batches after 20 June 2025; complete sell-through by 1 Nov 2025.
Scenario B: Lipstick using BHT as antioxidant
Issue: BHT is restricted by product category and concentration; check your specific allowance.
Action: Confirm the formula against Annex III, reformulate if necessary, and follow placement and sell-through deadlines outlined in the BHT SI and guidance.
Scenario C: Cooling sports gel with methyl salicylate
Issue: 2025 restrictions depend on product type and intended use.
Action: Verify allowed concentration, adjust if required, and follow the 30 Sept 2025 placement and 31 Mar 2026 sell-through deadlines.
UK Compliance Checklist for Cosmetics
- Map ingredients in all GB SKUs against Annex II/III updates (CMRs, kojic acid, BHT, methyl salicylate).
- Create a transition calendar with placement and sell-through cutoffs for each affected ingredient group.
- Reformulate non-compliant products and run updated safety assessments (CPSR).
- Update labels (INCI, warnings, RP details) and plan for the 31 Dec 2025 end of extended RP labelling provisions.
- Refresh notifications in the SCPN portal if compositions change.
- Train teams and distributors on deadlines and withdrawal procedures.
- Keep the PIF audit-ready; OPSS/Trading Standards may request it.
Final Takeaway
The UK’s 2024–2025 changes are more than routine updates. They tighten ingredient controls with real operational impacts. The 64 new CMR bans (effective 31 Jan 2025 with phased sell-through), the 1% kojic acid limit (with June/Nov 2025 milestones), BHT restrictions (from 2024 with early-2025 compliance), and methyl salicylate limits (with Sept 2025/March 2026 transitions) mean brands must audit formulas, manage stock carefully, relabel, and update PIFs and notifications.
Addressed proactively, these changes don’t just reduce risk. They can enhance product quality, build trust with retailers and regulators, and position your brand as a compliance leader in a competitive market.
As a member of the Cosmetic, Toiletry and Perfumery Association (CTPA), Euverify stays in step with the UK’s changing cosmetic regulations and best practices. Our team helps brands understand new requirements with clarity and confidence, making sure their products stay safe, compliant, and ready for market.
For a deeper understanding of cosmetics compliance, including practical steps and expert insights, download our free guide and start your EU/UK market launch with confidence.
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